ML20012E163
| ML20012E163 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/26/1989 |
| From: | Pate Z INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | Duffett J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| Shared Package | |
| ML19324G680 | List: |
| References | |
| NUDOCS 9003300149 | |
| Download: ML20012E163 (101) | |
Text
y institute of gM 1-Nucle:r power Operations Suite 1500 1100 Carew 75 Parkway Atlanta, Georgia 30339 3064
%eonome 404 953 3600 December 26. 1989 Mr. John C. Duffett President and CEO Public Service Company of New Hampshire 1000 Elm Street Manchester, NH 03105 L
Dear Mr. Duffett:
As recuested and authorized by Mr. Ted C. Feigenbaum's letter dated December 18, 1989, attached are the results of INPO's evaluation of Public Service Company of New Hampshire, New Hampshire Yankee Division's cor: orate support and monitoring of Seabrook Station, conducted from October 2 l
through 6, 1989.
Copies of previous drafts should be returned at this ti.?e.
In accordance with INP0's Evaluation Release Policy, this letter and the attachment are provided to you and INPO's Board of Directors.
If you should decide to provide copies to the NRC, or to otherwise release the attachment outside your organization, we request that you notify INPO in advance, io follow the timely completion of the improvements included in the responses, INPO requests a written status report by June 1990.
A final upcate will be requested six weeks prior to the next evaluation. We appreciate the excellent cooperation and response from all levels of your organization.
Sincerely, Zack T. Pate President ZTP/bm Attachment (as stated) 1 1
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EXECUTIVE
SUMMARY
I The Institute of Nuclear Power Operations (INPO) conducted an evaluation of Public Service Company of New Hampshire, New Hampshire Yankee Division's corporate support and monitoring of Seabrook Station from October 2 through 6,1989.
As a basis for the evaluation,INPO used the December 1987 Performance objectives and Criteria for Corporate Evaluations these were applied in light of tne experience of INFO's team memoers, ihPO's observations, and good practices within the industry. Information was gathered from discussions, interviews, reviews of documentation, and the concurrent j
Seabrook Station evaluation.
Several beneficial practices and accomplishments were noted, including the followings o
the positive attitude and stability of the staff I
efforts to enhance. teamwork and exce!!ence throughout the organization and, in o
particular, the effective engineering and technical support interface effective independent reviews performed by the Independent Review Team that l
o draw on the experience within the Yankee organization, are of sufficient depth and scope to identify substantive problems, and that result in recommendations that are well accepted by the organization In addition, improvements were recommended in a number of areas. The following are considered to be the most significant areas in need of improvement:
1.
Corporate management needs to communicate expectations for standards of performance in some important areast Timely action has not been taken by the corporate organization to address a.
and resolve ;ome important problem areas that could affect station operation. (Finding 1.2A-1) b.
The goals and objectives program needs to be more effectively used to support the achieve. rent of the organization's priorities.
Corporate direction of materials management activities has been c.
insufficient to provide effective and timely support of plant materiel needs. (Finding 2.2A-1) 2.
Corporate and station managers and supervisors are of ten not held accountable for timely completion of assigned actions or improvements to the station.
(Finding 1.2A-2) l l
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3.
Consistent direction needs to be provided to the New Hampshire Yankee organization to facilitate the nuclear station's transition from the support role they held during construction, to that of the princi support during power operation. (Finding 1.1B-1) pal department requiring Findings and recommendations are listed under the applicable performance objectives.
1 Findings describe conditions that detract from meeting the performance objectives.
Particularly noteworthy conditions that contribute to meeting performance objectives and i
that are unique are identified as good practices, it would not be productive to list as good practices those things that are commonly done properly in the industry sir.ce this would be of no benefit to New Hampshire Yankee or to INPO's other member utilities. As a result, most of the findings highlight conditions that need improvement.
The recommendations are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the ut lity should, in addition to correcting or improving specific conditions, pursue underlying causes and issues, j
INPO's goal is to assist member utilities in achieving the hit sest standards of exce!!ence in I
nuclear plant operation. The corporate findings and recomm;ndations are based on i
apparent New Hampshire Yankee needs and on best practices, rather than minimum acceptable standards or requirements. Accordingly, areas where improvements were recommended are not necessarily indicative of unsatisfactory performance.
The findings and recommendations listed herein were presented to New Hampshire Yankee management at an exit meeting on October 18,1989. Findings, recommendations, and responses were discussed on December 1,1989, and the responses are considered satisfactory.
1 To follow the timely completion of the improvements included in the respenses,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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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE NEW HAMPSHIRE YANKEE DIV!510N Response Summary As the operating agent for Public Service Company of New Hampshire's Seabrook Station.
New Hampshire Yankee finds the Institute of Nuclear Power Operations'(INPO) evaluation of our corporate support and monitoring of the station to be both insightful and useful. New Hampshire Yankee supports the overall goals of INPO and the nuclear ir.dvstry in assuring 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 improvements. New Hampshire Yankee is committed to iraproving our programs and procedures to correct these areas of weakness. Specifically, New Hampshire Yankee will strengthen its pregrams and the implementation of company policies in the following areas:
1.
Communication of corporate management expectatiens associated with standards of performance will be improved overall and specific !!y in the following areast taking timely actions to address and effectively resolve problem areas that o
could affect station operation ensuring the achievement of the organization's priorities through more o
ef fective utilization of the New Hampshire Yankee Goals and Objectives Program providing effective and timely support of the plant materiel needs through o
stronger corporate direction of the materials management activities 2.
Personnei accountability measures for corporate and station managers and supervisors will be strengthened. These measures will specifically incluce the timely and ef fective accomplishment of their assigned actions and identification of improvements within their areas of responsibility.
3.
Clear and consistent direction to the overall New Hampshire Yankee organization will be provided to complete the transition of the production organization from l
the support role that it held during construction, to that of the principle i
orgtnization requiring support during power operation.
In summary, New Hampshire Yankee supports both INPO and the industry in the pursuit of excellence in nuclear power plant operations. We believe that the implementation of the improvements committed to in this evaluation will help us in that offort.
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ORGANIZATlONA1. STRUCTURE PERFORMANCE OBJECTIVE A. The corporate organization is established in such a -
manner that the functions, assignments, responsibilities, and reporting relationships of individuals are clearly defined, understood, and offactively implemented. All major aspects of the nuclear operation are encompassed, with emphasis on line management control of safety and reliability.
Finding (1.l A-1)
A lack of nuclear station experience exists at the corporate manager level and in key corporate staff positions. Only one member of the corporate staff at the director level has nuclear
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station experience, and one other has current operational experience from another utility. This reduces the operational perspective in the corporate organization and restricts available 1
career paths for station employees. Contributing to this is a perception that currently exists among corporate employees that station experience is not an important factor in career advancement.
Recommendation Estatush career development for selected corporate and station personnel, including rotation between the two organizations, to gain added experience and perspective at the corporate level.
Revise corporate policies to include nuclear station experience as an important factor in employee development and advancement.
Response
Career development, for selected corporate and station personnel, will be enhanced through the implementation of a Key Manager Development Pro 5 ram. This program will be introduced in January 1990, and will be supplemented with a corporate and station position rotation program that will be established and implemented by June 1990.
Greater use will be made of station personnel in the conduct of Independent Review Team tasks to provide station employees with broader corporate experience and influence. In line with the New Hampshire Yankee promote-from-within philosophy, the Job Posting and Key Management Development Programs will emphasize the importance of station operating experience.
Revised job descriptions, which willindicate a preference for station experience for appropriate corporate positions, will be completed by September 1990.
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13agel PERFORMANCE OB3ECTIVE B. The corporate organization affactivel station (s) and minimizes the assignment of duties to the station staff (s)y supports the to day-to<iay plant management.
not directly related -
Finding (1.lB-1)
Consistent direction needs to be provided to the New Hampshire Yankee organization to facilitate the nuclear station's transition from the support role it held during construction, to that of the principal department requiring support during power operation.
The station has not taken a leadership role in the management of day-to-day activities. Contributing to this is that, until recent.y, the focus of corporate management has been on external factors associated with licensing the Seabrook Station. Additionally, some responsibilities ass:gned to the production organization do not directly support its mission and impact existing resources. Examples of these areas are the review and implementation of vendor manuals, implementation of design changes, and procurement engineering.
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The following areas require additional corporate emphasis or i
resolution for the station to complete preparations for power operations:
The solid radioactive waste handling group has not n.
been staf fed. As a result, procedure development and waste handling personnel training have not been completed despite the impending power ascension testing. (See Finding 2.10A-1) b.
Additional assistance in preparing and revising procedures has not been provided to the operations department despite requests for assistance since 1987. During the recent Seabrook Station evaluation, weaknesses were identified in the technical content and human factors of operations department procedures, c.
Maintenance training was recently cance!!ed due to insuf ficient resources in the maintenance department to complete both scheduled work and training. The training department cance!!ed additional training due to its priority on preparing for accreditation of the maintenance training programs. Senior plant and corporate management were not aware of these decisions or the impact on the maintenance department's readiness for power operations.
Recommendation Define the operational responsibilities and priorities of the station to the entire New Hampshire Yankee organization.
Review the existing division of responsibilities to identify areas where work can be transferred from the production l
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organization. Provide additional corporate support to resolve outstanding issues impacting the preparations for startup, such as those identified above.
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Response
The responsibilities of the production organization, and other New Hampshire Yankee organizations that support the production organization, are included in the New Hampshire Yankee manual system. These responsibilities will be reinforced and further defined on an ongoing basis. New Hampshire Yankee i
senior production management will chair regular meetings with appropriate station supervision and corporate support supervision. At these sessions, production priorities will be -
clearly and unambiguously defined, and the necessary support to resolve problem areas and negative trends will be identified and allocated. These weekly meetings will be held at the station beginning in December 1989.
In November 1989, a Materials Management Task Force was established to resolve existing problems and to identify l
organizational realignments to assure an efficient long-term materials program structure that will effectively support station operations. The new Radioactive Waste Handling Group and the new Operations Support Group are scheduled to be staf fed by l
December 1989. In addition, a review of existing organizational responsibilities will be conducted. This review will include, but i
not necessarily be limited to, the review and implementation of vendor manuals, implementation of design changes, and procurement engineering. The review will identify anc. if necessary, will result in the reassignment of activities currently I
assigned to production that could be more appropriately t-performed by other New Hampshire Yankee support i
organizations. These reviews will be completed by June 1990,
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and any identified responsibility realignments will be implemented by September 1990.
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MANAGEMENT INVOLVEMENT AND COMMITMENT PERFORMANCE OB.7ECTIVE A. Corporate management directs, monitors, and assesses nuclear station operations and provides support, guidance, and assistance to attain and enhance safe and reliable operation. Corporate managers assigned responsibilities for nuclear matters have direct involvement in significant decisions that could affect their responsibilities. Management commitment to the operation of the nuclear station (s)in a safe and proper manner is evident from personal involvement, interest, and knowledge.
Finding (1.2A-1)
Timely action has not been taken by the corporate organization to address and resolve some important problem areas that could e
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.I Pa'ge" 7 affect station operation. In several cases, these problems were previously identified from within the organization, but corrective action was not adequately implemented. Corporate management's focus in the past on the many unique licensing and regulatory issues associated with the Seabrook Station contributed to the lack of timely action. Examples of 3'
significant problem areas are as follows:
l During the recent Seabrook Station evaluation.
a.
several significant weaknesses were identified in the operating experience program. These included weaknesses in the application of industry opersting experience, as well as the use of in-house exp<erience. For example,25 significant operating experience report recommendations were found to be not satisfactorily implemented, a number 3
considerably higher than typically seen at other utilities. Problems were also found in the use of l
in-house experience due to an inadequate threshold and mechanism for identifying in-house events.
i Corporate managers were aware of weakness in the operating experience program, but have not implemented effective corrective action.
i b.
Procedure adherence problems were repeatedly identified in the executive summaries of semiannual quality assurance trend reports since 1987.
However, management action to address this problem was not initiated until early in 1939, and was not effective in preventing an event in June 1989 that was, in part, attributed to nonadherence to a test procedure. Additionally, some weaknesses in the adherence to station policies and procedures was observed during the recent Seabrook Station evaluation. For example, vendor manuals are i
routinely used in place of approved procedures contrary to station requirements, i
c.
A number of check valve failures have occurred at the station, including failures in the residual heat removal system, diesel generator Jacket cooling water system, and containment building spray system. The significance of check valve problems was reported to the industry in Significant Operating Experience Re wt 86-3, " Check Valve Failures or Degradation,",ssued in October 1986, and emphasized in a subsequent INPO letter to senior corporate management. Despite the check valve l
failures at Seabrook and the above correspondence, an effective check valve preventive maintenance l
program is not yet in place. Additionally, a design review of check valves is not scheduled to be completed until April 1991.
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Recommendation Take action to address important problem areas, including those identified above. Monitor the effectiveness of the corrective actions implemented to verify that improved performance is achieved.
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Response
New Hampshire Yankee has initiated formal reviews to identify open issues and problem areas to be addressed prior to fuit j
power operation. Each issue will be reviewed by New Hampshire,
Yankee senior management, assigned a completion schedule, and !
tracked until closure. This review will be performed by j
December 1989. For the longer term, senior management is i
meeting with employees ort a weekly basis to obtain feecback regarding operational or organizational issues, and to provide additional monitoring of the effectiveness of corrective actions implemented.
The Operating Experience Program will be strengthened to
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assure effective and timely implementation. Action plans have been developed for the 25 significant operating experience report recommendations that have not been resolved. A goal has been established for new SOER: issued in 1990 to assure timely implementation of industry operating expense. In addition, the current procedure for review of in-house operating events will be revised to ensure these events are thoroughly investigated and corrective actions completed in a timely manner. As part of this revision, the initiating threshold for i
event reviews will be lowered to conform with corporate management expectations. These actions will be complete by February 1990.
Procedure compliance training has been conducted for nearly all site personnel and will be completed by December 1939. An initial review of training elfectiveness has been completed, and a followup evaluation will be conducted by February 1990.
A task team has been established to address vendor manual i
issues, and a comprehensive check valve design and monitoring i
program is under development. Correct:ve actions associated with these issues will be fully implemented by December 1990,-
and October 1990, respectively.
Finding (1.2A-2)
Corporate and station managers and supervisors are often not held accountable for timely completion of assigned actions or improvements to the station. Examples of problems noted are as follows:
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Page 9 Approximately one-quarter of approximately 1,250 a.
items on the integrated commitment tracking system are past due. Many involve quality deficiencies and lessons learned from industry operating experience.
In many instances, personnel are not held accountable for completing items on time. Due dates are sometimes established without the concurrence of managers responsible for the tasks, contributing to the problem. As a result, the e
tracking system is not fully effective as a management tool.
b.
Although many of the New Hampshire Yankee goals and objectives for 1989 will not be accomplished due to changes in senior management priorities, i
responsibilities for these goals have not been formally removed or modified. As a result, a lack of i
accountability and loss of credibility have developed toward the goals and objectives program. Based on a recent status report,29 of 47 corporate goals (62
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percent) will not be achieved in 1989.
Managers and supervisors are not consistently held c.
accountable for completing annual personnel i
performance appraisals in a timely manner. For example,48 percent of the annual appraisals for.
exempt personnelin the station staff are overdue.
(See Finding 2.6B-1 for additional details.)
d.
A number of issues identified in this and the recent station evaluation are similar to those identified in the 1986 and 1987 INPO corporate and station visits. For example, recommendations were provided for improving equipment tag verification of valve lineups,ging, independent evaluating in-house operating exarience, and improving worker industrial safety practices. Although some improvements in these areas are evident problems continue to exist. In many cases, respons,ible Individuals were not held accountable to verify that I
the improvements were effective.
Recommendation Strengthen measures to hold personnel accountable for their areas of responsibility. This should include verification that desired actions in areas such as those noted above are effectively accomplished..
Response
A Core Values and Work Ethic Program has been instituted as a foundation for strengthening overall attention to detail, accountability, and general. corporate management expectations regarding high quality work with appropriate attention to commitments, cost control, and work effectiveness.
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Performance will be reflected in performance appraisals that will be done on a yearly basis. Specific criteria have been 1
included in the New Hampshire Yankee manuals and formally presented to employees.
j The integrated commitment tracking system will be revised to implement a new priority system, tighter controls on commitment date changes, and closer tracking of progress. A weekly review of the integrated commitment tracking system will be conducted with station and corporate managers. These changes will be implemented by December 1989.
I, Accountability for established goals will be emphasized in writing to all managers by December 1989, and goals status reporting will be improved to permit closer corporate management monitoring of arogress. The goals program will be j
, reviewed on a quarterly bas.s to assure that established goals are consistent with senior management priorities. Coals will be formall review.y modified or removed, as necessary, based on this 3
Personnel will be held accountable for completion of corporate and station findings by use of the improved integrated commitment tracking system. Accountability for completion of performance appraisals will be assured by requiring that performance appraisals be a prerequisite to annual wage and salary actions.
l MAINTENANCE AND OUTAGE MANAGEMENT PERFORMANCE OBJECTWE A. Corporate management ensures maintenance activities at the nuclear station (s) are offectivet in maAntaining equipment in a high state of readiness and in good materiel condition to support safe and reliable plant operation.
Finding (2.l A-1)
Corporate monitoring of some aspects of station maintenance activities has been insufficient to identify problems and provide the support needed to achieve timely corrective action.
Maintenance performance problems that persist include use of vendor manuals during the performance of safety-related work contrary to station policy, an increasing backlog of maintenance t
work, insuf ficient maintenance worker productivity, and inadequate scheduling of maintenance tasks. Contributing to this problem is a lack of clearly defined responsibilities for performing reviews, trending, and evaluating maintenance data for identification and implementation of corrective actions.
Examples in this area include the following:
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The semiannual trend analysis report generated by a.
the Nuclear Quality Group is limited to reviews of station c ality assurance, quality control NRC, and other qua.ity-related problem reports. The analysts does not include reports generated by station planning and scheduling, reports from the cost control group in Production Services, or Independent Review Team results.
b.
In discussions with a quality assurance manager, it was noted that inappropriate vendor manual use by maintenance personnel performing work in the f' eld had been previously identified in several surveillance -
reports. The manager was unaware that similar problems with incorrect use of vendor manuals during field work still exist, as identified in the recent Seabrook Station evaluation.
c.
The Maintenance Group Activity Report for February 1989 identified that all maintenance training was cancelled until June 1949 to prepare for INPO accreditation of the non-license training programs. During the recent Seabrook Station evaluation, management was unaware that maintenance training had been cance!!ed.
d.
Some corporate nianagers interviewed indicated they relied on the station manager to monitor maintenance activities and were not aware of some problem areas needing maintenance improvements.
For example, the September 28,1989 Production Maintenance Report indicated that the cumulative maintenance worker productivity for corrective maintenance performance was inadequate when compared to the projected performance standard.
Additionally, the recent Seabrook Station evaluation identified that maintenance actiuties are of ten ineffectively coordinated or deferred as a result of inadequate scheduling.
Recommendation Assign corporate responsibilities for monitoring maintenance activities to support the timely identification and resolution of problems and adverse trends. Irnprove the i!:2 of station and corporate generated reports to identify areas needing improvement and to monitor the effectiveness of corrective actions. Followup on identified problems, including those noted above. INPO 83-038, Guidelines for the Conduct of Maintenance at Nuclear Power Stations, should be used in this offort.
Response
Specifically focused corporate monitoring and trending of maintenance activities and data will be established by March 1990. Existing reports generated by both the station and corporate organizations will be reviewed and improved as l
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necessary by June 1990. These reports will be used to verify that areas needing improvement are identified, and to monitor the effectiveness of corrective actions in progress. INPO g5-03g, Guidelines for the Conduct of Maintenance at Nuclear Power 5tations, will be used m tnis effort, l.
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MATERIEL AND OUTSIDE SERVICES PERFORMANCE OBJECTIVE A. Corporate materiel management ensures that parts and materiel are purchased and maintained in a quality manner and are available when needed.
l Finding (2.2A-1)
Corporate direction of materials management activities has been insufficient to provide effective and timely support of plant materiel needs. High backlogs of materials management-related work prevent materials from being ordered, received, and processed in a timely manner. As a result, consumables and spare parts are of ten not available to support plant maintenance and design change installation.
Contributing to these deficiencies are a lack of clearly defined expectations by corporate management for performance of the materials management activities and in effective coordination and communications between the groups performing materials management functions. Elements of this problem include the following:
a.
A significant backlog of work related to materials procurement activities exists. Examples include the following:
l.
Approximately 290 speed memos, documenting material order problems, are in backlog awaiting processing. The trend of the speed memo processing backlog is increasing. The average processing time for speed memos is approximately 133 days.
2.
Over 900 purchase requisitions for materials are in proccas. Of the 900, over 400 requisitions are on hold awaiting speed memo resolution or responses from vendors. The balance of purchase requisitions are awaiting buyer action. Additionally, during interviews, it was reported that some requisitions have been outstanding for correction and resolution since 1986.
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3.
There is a six to seven week backlog of materials awaiting receipt inspection. As a result, some materials arriving on site are not processed and included in the station inventory m a timely manner. Additionally, unnecessary calls to vendors are sometimes made to locate material already received. Other receipt i
inspection problems include frequently i
changing work priorities to resolve problems with vendor billings, and the inability of receiving clerks to spend time processing surplus construction materials for use as station stock.
b.
Spare parts and consumables are unavailable for 1
issue at the stores window approximately 6 percent of the time. Station work planners frequently do not check the computerized stock status for necessary consumable materials before assigning work, resulting in some job delays. Additionally, corporate design engineering groups developing bills of materials for installation of station design changes do not normally include lists of consumable materials necessary to implement the design work.
c.
Expectations for the performance of the materials management area have not been established or communicated by corporate management. For example, goals for availability of spare parts and.
consumables at the issue window have not been determined. Two managers responsible for major materials management activities stated they were frustrated because corporate management's expectations for performance of materials j
management functions had not been established or defined. Problems noted by these managers included
. stock-outs for spare parts and consumables and '
processing time for material receipt inspections.
d.
Activities of station and corporate departments involved with processing purchase requests, purchase orders, and receiving and issuing materials are ineffectively coordinated. The Materials Requirements Department initia!!y handles all purchase requisitj.ons, and is directed by the station planning and scheduling manager. The inventory organization receives and issues materials, but reports to and is directed by the corporate production services organization. The purchasing group places the orders with the vendors, and reports to the corporate Office of Administrative Services.
Monitoring and direction of the groups' actions,
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Pagele goals, and objectives are separate and of ten not coordinated or directed to ensure parts are available in a timely manner.
It is recognized that several eiforts to review and improve matertais management activities are in progress or planned.
These elforts include the currently active Materials Task Force, plans to assign a full-time quality assurance engineer to the material receiving area, and plans for an examination of the
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materials management program by an Independent Review j
Team.
j Recommendation Provide stronger corporate direction of materials activities.
l Prioritize and resolve materials management pro, gram weaknesses, including those noted above. Continue with activities to review the materials management program, identify problems, and implement corrective actions. INPO SS-038, Culdelines for the Conduct of Maintenance at Nuclear i
l Stations, shoutc be used in this effort.
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Response
In November 1989, a Materials Management Task Force was established. As part of this task force and on an interim basis, all procurement activities will report to one individual within the production organization.
This task force has been assigned the responsibility of resolving existing problems, including those noted above, and identifying organizational realignments that will assure an etficient, long-term materials program structure that effectively supports station operations. INPO 83-038, Guidelines for tne Conduct of l
Maintenance at Nuclear Power Stations will be used in inis ef f "t. The results of this task force will be documented, and an action plan to address the problems will be issued, by June 1990. In addition, expectations for performance within the materials management area will be formally established in the goals program. This wi!! be completed by February 1990.
4 HUMAN RESOURCES PERFORMANCE OBJECTIVE B. Corporate management provides for the career development of selected personnel, recognizing the importance of nuclear plant operational experience for nuclear managers.
Finding (2.6B-1)
Some important aspects of the professional and career development program need to be more effectively implemented. Problems exist with the conduct of performance l.
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Page 0 appraisals and with identification and development of candidates for succession to key positions. For exarnple, periodic personnel i
performance appraisals are frequently not conducted in a timely
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manner. Currently,33 percent otperformance appraisals of exempt personnel are overdue. Contributing to this is that periodic status reports to management do not indicate the total length of time appraisals are overdue. Efforts to hold managers 1
accountable for completing appraisals on time have been ineffective. Additionally, identification and development of candidates for succession to important positions has not occurred in some areas. Some managers stated they had no viable candidates for succession to their positions. Other managers identified pctential candidates with development j
needs but had not acted to address those development needs. It is recognized a formal succession planning program has been recently approved, but not yet implemented.
Recommendation Hold managers accountable for timely completion of performance appraisals of their subordinates at the frequency specified by corporate policy. Implement the approved succession planning program, and periodically assess its elfectiveness.
Response
Performance appraisal tracking and policy revisions will be implemented by December 1989. A revised performance appraisal procedure will aufst managers who are responsible for timely completion. Periodic status reports will be issued to executive management. Salary increases for employees will be processed only af ter receipt of completed performance appraisals.
i A Key Management Development Program will be introduced in January 1990, and the initial implementation will be completed in April 1990. A progress review will be held af ter six months, and the process wl!! be reinitiated annually.
RADIOLOGICAL PROTECTION PERFORMANCE OBJECTIVE A. Corporate managemer.t ensures radiological protection activities at the nuclear station (s) are offactive in minimizing radiation exposure, preventing the spread of contamination, and minimizing the generation of radioactive waste.
Finding (2.10A-1)
Insufficient management attention has been given to the development and implementation of a radioactive waste handling program. As a result, although generation of l
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Page 16 fr radioactive waste has begun and the plant expects to begin power ascension in the near future, key segments of the radioactive waste program are not in place. Examples include the followings Responsibilities for processing solid radioactive a.
waste are unclear. The corporate radiological protection organization is assigned responsibility for radioactive material shipments by procedure.
However, based on an interface agreement approved in July 1989, the principal health physicist considers this responsibility to have been shif ted to the station maintenance utilities manager. The utilities manager considers the interface agreement to be contingent upon staffing the utilities / radioactive waste organization (staffing positions not yet approved) and has not accepted radioactive material processing and shipment responsibilities. As a result, neither group is modifying procedures to accomplish.
the shif t in responsibilities, b.
Reorganization and staffing to create the proposed l
utilities / radioactive waste organization is incomplete. As a result, progress is not being made in training and procedure revisions, and development of long-term plans for interim radioactive waste storage pending resolution of final waste disposal options have been delayed.
t c.
The radioactive waste minimization committee has not met in over 2 years, and has not addressed existing station practices that contribute to i
unnecessary generation of radioactive waste.
Management oversight has not been effective in identifying and correcting this problem. Recently, the responsibility of the radloactive waste minimization committee chairman was transferred to the utilities manager; however, resources are not yet avaliable to support these new responsibilities.
d.
Plans and milestones have not been communicated for the temporary storage of radioactive waste prior to availability of facilities for long-term storage.
Despite the long lead times involved for some temporary facilities, plans have not been implemented. Yarlous managers in the plant and corporate organizations have communicated different plans for interim storage of radioactive waste ranging from flatbed trailers parked in the protected areas to a new storage building.
Recommendation Develop and implement the radioactive waste program. This L
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March 13, 1990
- melosure 2 to Imf. lot 91 Status Utdate of WHY Rmanaaman te IMPO Findimme Trip Report of Special Assistance Visit to Seatrock Station. January 1984
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ISSUE Organisation. Bevoral NEY emergency-plonning personnel unaware of their seeilnod duties and responsibilities.
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REFERENCE:
Trip Report 2/6/08. Item IV.A.1. page 3 9
ALLt0tR'S STATEMENT
'teetimony, page 3.
'Under 'Organisation. ' INPO stated that: 'Several New Hampshire Yankee personnel interviewed did not know their complete assigned duties and responelbilities and indicated they had never seen their position descriptione.'
WHY RESPONSE:
Zeeue included se Observation 05 of quality Assurence Audit Report No. 84.A01 01.
leeue related to the understanding that NMY's tr.orgency Plannin6 staff has of its duties and responsibilities.
this cheervation is the result cf an expectation by the 1
auditors that the Seabrook Station emergency preparednese efforts and, therefore, the organisation assi ned to perform them were stable. There have been many issues that have constantly forced New Hampshire Yankee to roast.
Each issue has resulted in organisational reactione and adjustmente. Personnel seeigned to certain functions on a given day have, out of neceselty, been reassigr.ed to the current priority task..It's likely some of the personnel interviewed se part of the beets of this observation now have entirely new assignments or possibly, are no longer.
l here.
This item has been corrected. by the development of job descriptions f or Energency Planning staff positions and i
the. reduction in staffing to a conetont workforce.
This issue is not directed towstd duties and responsitiltime of Emergency Responders.
L l
-+
.;. ' ' L: c l
, issue:-
'Orgsalaatien. Position descriptiene for 60me coergency L
plannin5 etaff are not available.
INp0 REPgttRCE:
Trip Report 210/88 atta IV.A.R. page 3 ALL80ER'S STATEMENT:
Testimony, page 5
[Soverat New Maapehire Yankee persehael) 'had not ever seen their position descriptiones' teeue included se Observation OS of quality Assurance NNY RESPON8ti Audit Report No. 88.A02 01.
Zeeue related to the understanding the NHY's hmergency Planning eneff has of its duties and responettilitsee.
This item has been corrected by the development of and distribution of job descriptione for Emerlency Planning staff positions.
This issue is not directed toward Emergency Response position descriptions.
\\
EP.2 l
.~
ef
-186Vt.c Organisation.- ps _dtcumentatism of all responsibilistes of.
the hattologital' Assessment Manager..
INP0 REFEntNCEt' Trip Report illl88 Item IV.A.3, page 3 ALLEGER'S STATEMSM7:
'There is no document, form or system in piece that describes all the duties and responsibilities of the Radiological Asessement Manager.'
' NET RESPONSE:
Issue included to Observatten C6 of Quality Assurance:
o Audit Report No. 88.A02 01.
Issue related to the number of responsibilities of a single Beersency Planning staf f position.
The number of tasks assigned to the position of Radiological Assessment manager in the NPER procedures that were current at the time of the audit has been greatly reduced by revisione to appropriate procedures.
1 LThis cccurred during March. 1988 and now properly reClacte the NNY taergency Preparednese and Community Relatione subdivision or6anisation and the breakdown of its responsibilities. The transition to the proper responsibility assignmente as a result of the emergency preparedness reorganisation had not been completed at the time of the audit.
The item has been corrected by the reassignment of responsibilities to other amargency Planning staff pooltione and the redefinition of the Radiological Assessment Manager position to that of the Radiological Technical Specialist in 318.4 This poottion discussion does not deal-with Dnergency Response positions.
IP.3
13 B'Jt i -
Orgonisttion. !nadequate dscumentation of mandatory toergency Planning program activities.
,,a t
INPD REFT 1tHCIi' trip Report 2/8I66. Ites IV.A.6, page-3' ALttGER'S BTATEMENT:
None W8Y RttpoWSti Issue included so Cheervation 06 of Quality Assurance
- Audit Report No. 88-A01-01.-
Zeeue related to the trackin6 of routine, prograsmatic activities.
Baergency Planning staff has addressed this issue by employing the activity trackin5 tools avai'able within the NNY eystem. These includes the Integrated Commitment Tracking System. Repetitive Task Sheets and departmentei administrative procedures 90300 and 91120.
e IP-6
3 4,*
' ' e.
e 188Ugs Emergoney P&On/Prccedures. *etters of Agreement J
INP0 REFR UCEi.
Trip Report 2/8/88. Item IV.8.1 page 4 V
ALLBCE'5'8TATEKENT -
None NNY R38 POW 8te
!seue included se Finding F4 of Qual &ty Assurance Auait 1
Report No. to.Aot.01.
Issue related to 3 of 7. letters of agreement not being reviewed within the previous year.
l All letters of agreement have been updated and are on file.- commitment added to the toebrook station Radiological Emergency Plan to review 1stters on an annual basis and update if needed. Department procedure 904c0
- sils for annual review of letters of agreement.
Finding closed by NHY Nuclear Quality Croup. Status Update for Audit Report No. 98.A02 01 dated 9/30/88 ($87841288) i 4
e p
1 i
. e --
- stuti
-Emersoncy PlaniProcedures. Errors and inconsistenctee an the esorgency plan and procedures.
. NPO REPERREt:
Trip Report 218188 Ites IV.8.1. page 4-ALLBCit*4 8tAttHENT '
Testimony, page 6
'Under 'Dnergency Plan and implementing procedurse ' WP0 meted-that: '%e emergency plan in some instances is not consistent with the emergency plan implementing procedure andler businese se it is being conducted
NNY RttPON88:
Issue included as Observation 01 of quality Assurance Audit Report No. 88-A08-01.
Discrepencies.between the Seabrook Station Emergency Plan and its implementing procedures were corrected in a plan revteion dated April 1988 and in subsequent reviolone, as-appropriate.
All revisione reviewed by Change Control team in accordance with department procedure 90300.
"' I
. c, i
~
eJ ssugi teergeley' Plan /PecccCures. "Jee Of an unauthorised change
'~
control program for laplementing procedures.
INPC REptRENCti
' Trip Report 2/4/84. Iten IV.S.2. page 4 A1.1.20ER'S $7AT!HENT:
Teettsony, page 6
' Revisions te on. site procedures are being accomplished through the use of an unauthorised change control program.
administered by the emergency preparednese group outside of the approved process. * *
- Interviews and document reviews indicated that 'short cute' are being used to speed up even this process and user impacte are not being considered. No documentation esists' for this unauthorised process.'
NEY RESPONSta Issue included es Finding P1 of quality Assurance Audit Report No. es.A02 01.
The Change Control Program established a Change Control Team (CCT) charged with the responelbility within the thergency Preparedness and Community Relatione subdivision to review and approve every revision to an implementing procedure within the Production and Enertency Response Manual (NPER) (as well as procedures within the Seabook Plan for Massachusette Cosenmities and the New Hampebire i
trtP) that is proposed. The CC; must review the concept
('
represented by the proposed MPER change gag. Eggt ianortantiv, the impact of the proposed change on the plan 1
and procedures within the SPMC and NERERP. This impact assosoment occurs Agiggg a revieton is approveo by the CCT. with approval only a result cf a conclusion that the revision is both needed and does not negatively impact either the SPHC or the WMRERP.
t Pollowing CCT approval, the proposed RE17 procedure revision is then submitted.to at least one Independent Reviewer for approval, to SotC for approval and finally to the Station Manager for approval before the revision is made to the NPER.- Thus, the CCT step is upfront end additional to the neraal procedure review and approval process. not a bypese.
The IP6CE eubdivision procedure 90300 documenting tnie process was issued on 8/19/84. The finding was closed and verified by NNY Nuclear Quality Group. Status Update for Audit Report 88.A02 01. cated 9/30/08 (SEP 881248).
i l
EP.7 i
4 g ;
- 188UE, training. Emergency preparenness tenining prograOs do not comply with other station training proStaas.
l
/
. INPC RtttR:N0gi Trip' Report !tta IV.C.1, page &
ALL80RR'S STATEMENT:
'Under ' Training,' INP0 noted thats 'Esergency prepare 4asse training pro $rame'do not currently comply with the requiremente specified by precedure. ***
Raergency prepareaness training instructors are not being qualified or selected in accordance with the criteria specified in [a procedure containing well. defined criteria for seleeting and training esorgency preparedness training instructors).*
NNY RESPONSE:=
teeue included as Finding F6 of Quality Assurance Audit
=
Report No. 88 A02 01.
The procedures referenced in the *.NPC Trip Report are Seabrook Training Center (8?C) procedures that were developed for operator training programe. They were not applicable to other training programe. A series of Nuclear training (NT) procedures were developed that apply generally to trainin5 Programs at seabrook Station. These NT procedures superseded STC and other training procedures. The appropriate emergency plan implementing procedure (ER 4.2) wee revised to be consistent with the NT precedures. An emerlency response organisation training program descriptica has.been developed that references applicable NT procedures.
Finding closed by NNY Nuclear quality Group. Status Update for Audit Report No. $4.A02 01, dated $/31/89 (SSPl90809) t II.S l
7 IO 888UE4 -
training. No decumentattor. cf EAL reviews eith off site authorities.
-!NPC K2?tEENCts Trip Report 2/0 /88
- tem IV.C.2. page - 5 ALL8CER'S 8TATEMENT:
None 3
. WNY R$8p0N82:
1seue intladed se Observation 03 of Quality Assurance Audit Report No. 48.A02.oi.
Documentation of emergency pian training conducted on 12/8 8187 and subsequent years for state organisatione esists showing that emergency action levels for Seabrook Stetton, in addition to other topics, were covered.
However, the documentation for 1887 was not readily available during the audit.
A complete set of documentation has been placed in the records showing the course agenda, handouts, and attendees. This training has been added to the emergency plan training matria SSREP Fi ure 12.1 for tracting l
purposes.
188UE:
Tr0Laing. :r.adeguato ccordination to ensure completion of all trainin5 INP0_REFERENCEi-Trip Report 2!8f 48. Item IV.C.3 page 3 ALLEGER'S STATEMENT None NNY RESPONSE leeue included at Finding FS of Quality Assurance Audit Report No. 84.A01 01.
The then current version of the Energency Preparedness Training Procedure (ER.S.E) did not reflect the train &ng program due to changes at the time of the audit.
Procedure ER 8.2 was revised on 9/13/88 to include changes to the EP training program and addressed the noted concerne. Responelbilities for the administration of ERO training-including training of security and operatiens personnel were updated.
Finding closed by NHY Nuclear Quality Group. Statue Update for Audit Report No. 88 401 01, dated 9130/88 (SSP 881288).
u EP.10
o:
i o.:
ISSUE:
Training. Rtquired r00 ding progr43.
570 REFERh ets-TripReport2I8/89,btesIV.C.4.page5 o
ALLEGER'S $7ATEMEN?i-None WMY RE8PONSE:
Issue included as Finding FS of Quality Assurance Audit Report No. 88.A08 01.
The then current version'of the Emergency. Preparedness
~
Training Procedure (ER.8.2) did not reflect the training program due to chanlee at the time of the audit. The required readin8 pro 6 tam romaans as part of the training program and le reflected in the most current version of R.8.2..
Pinding closed by NHY Nuclear Quality Group, Status Update for Audit Report No. 88.A02 01, dated 9/30188 ($5P881288).-
s EP.11 l
l l
.g
~-;s8;12 -
Public Inferration.- 'taprovo seeignment of'roeptnetbility anC coordination between 3mergehty preparedness and u
J Corporate Cammunicatione staffe.-
INPO REFERENCEi l Trip Report 218/60, Ites IV.D.1.4 c. page 6 ALL8GER's STATEHENT:
None MNY RESPOWsti-teoue included as Observation 07 of Quality Assurance Audit Report No. 88 A08 01.
The toergency Preparednese and Corporate Communicatione sub divietone have implemented corrective measures to ensure joint participation in the emergency public-inf orastion end education progress. Theet measures have saciuded recommendatione and resoluttone in the following functional areas
- Media concept of operation
- Information flow analyets
. Functional positione and personnel ass 1 nmente 5
- Revised and new procedures
- Revised facilities and equipment
- 8 tate participation.
- Pereoanel training Corporate Communleatione personnel provide independent review of es:h revision of ER-3.4, "Seabrook Statlan News Service operation" and ER 3.5. 'Hedia Center / Joint telephone Information Center' procedures and-indicate their approval by signing the cover sheet.
Energency Preparednese and Corporate Communicattone have jointly produced Snorgency Preparednese public inforWetion materiale such ae calendere and flyers.
The preparer of'the emergency public information materiale is not required to retain detailed knowledge of the NHY ERO Media Center Procedures to develop adequate materiale.
The change Control team provides oversight of-all procedure reviolone to ensure consistency.
P i
I:
L.,.. :V
.)
I
. 288Ut -
Pablic 2nformation. Oiserepancies betwe:n the plan and procedures.
P
!WP0 REFrtt.10ts trip Report 2/8148 Itan IV.D.2. page 6 ALLSCft'$ STATEMENT:
None NNY RESPONSES Issue included as Observation C1 of Quality Assurance Audit Report No. 40-A02-01.
The 58129. Section 11.3 has been revised to correctly
' reflect activitiae regarding the types and distribution means for Public Information. -these updates were issued in April 1988 as Revision 3.
The appropriate procedures (ER 3.4) direct s the contact of the control room by the appropriate Seabrook News Service personnel. 'The referenced procedures therefore did not require revision.
i 9
l 2P-13
.-(
385U3 -
- Pubit.c Inf ormation. - '.Inavaliability et m2dia traintng 3
doc uentation.
i-1970 R3?tRENCE: -
Trip Report 2felet.- Item IV.D.S. page 6 ALL80ER'S STATEMENT:
None.
WHY RESPONSE:
. Issue included as Observation 09 of Quality Assurance Audit Report No. $8.A02 01.
Attendance recorde for the documentation of. future
. eupplemental training will be maintained. Provisions for documenting supp* omental trainin8 are addressed in Emeegency Preparedness Training (51 8.8).
h EP-16
,'.!'r e
' s 5
~
r
- ?
188V8 Public Inforestion. Teatr.ing dscument retrieval difficulty.
INP0.REPfAENCE:-
Trip Report !!B188.' Item IV.D.3. pale 6.
ALL80ft
- 7. STATEMENT I None WNY 188PON88:
1eone included as Observation oli of Quality Assurance.
Audit Report No. 44.A01 01.
einee the audit the precedures have bows. revised to better refleet the personnel who are responsible for tP.e types of documentation restuosted by the auditore... The EP Specialty Training ereup now retains hard copy of training records as well as a cesputer data base to simplify retrieval of training records.-
r 4
1 l
l.
V IPol$
1.
l
. ;. _9 18 8'JE i -
Public :nformaticn. Media callout list.
f INPO kRFERENCE:
Trip Report 2/8/86, Itta IV.D.3. page 7
' ' -E ALLEGER's f;.LIEMENT:'
Hone NEY RESPCNSta teous included as Observation 010 of Quality Assurance Audit Report No. 88-A01 01.
The generation and maintenance of a media contact list le an everyday function and responsibility of the Corporate Cosegunications Department. It is neither pruaent not necessary to add such an ites to the emergency response procedure. The pro:oduce would be out of date within days of issuance.
9 EP.16 TOTAL F.23
1 Jbfs g.
j x
f.
I i
New Hampshire Yankee March 15, 1990 i
Ericlosure 3 to NYN.90273 Status Undate of NW Raanentee to INDO Findinen i
t Evaluation of Public Service Company of New Hampshire New Hampshire Yankee Divistora's Corporate suppcrt and Monitoring of Seabrook Station. Cetober 2 throu6h t. 1989
\\
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<m9 #M
..~
i
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e:
i I S S*Jt i organisatten 6tructure j
INpC
REFERENCE:
INp0 Corporate tvaluations. aated December 24, 1989.
Finding 1.1A.1. page L
- ALLECtt's STATEMENT:
None.
.NNY RESPONSE:
New Hampshire Yankee is taking a number of initiatives to
}
furtner enhance the experience and depth of an altesty strong operating team. The init&atives include the implementation of a Key Manager Development Program.
This program is designed to escure the continuity of well.
qualified managere for key NHY management positions by identifying and developing employees with the potential to move into those positione. Training and implementation of the program is already active and ongoing. It wiki be supplemented with a formai corporate and station position rotation program to broaden the esperience bene of the individuale involved and the organisatiDR as a whole. NMY already has for sometime, rotated staff throughout the organisation. The purpose of the new program is to formalise the procese and give more people the opportunity to benefit from it.
NNY is also in the procese of upgrading and improving its job descriptions that will stress the importance of anc indicate a preference for station emperience for appropriate corporate positione. This task is in progrees and will be completed by September 1990.
NNY considers the above organisational development initiatives to be sound and prudent. They reflect NNY's commitment to operational esce11ence.
Also, during the NLC 01AT Inspection, conducted in November 1909, and documented in Enepection Report 89 93, the NLC reviewed Seabrook's annagement, staffing, qualifications, and management structure. The NRC concluded that key staff members were iound to have the proper safety perepcctive and demonstrated a good understanding and a conservative approach to seabrook operations.
NHY has reviewed INPC Finding 1.LA.1 together with the status of NNY's constitments to INp0. Ve have determined that no issues exist which would adversely affect este plant operation.
-.-. - - - ~ -, - -
'4 U
L*
l-t I
t
- 88Uta Organisational Structure INPC )gFERENCE
INFC Corporate Evaluatione, dated December 26. 1949 Finding (1.18-1), page 3.
ALLEGER'S STATEMENT:
Under 'estimony, p. 14 ALLE0tt'S CEARACTER:ZATICN CF INP0 FINDING
' Consistent direction needs to be provided to the New Hampshire Yankee organisation to facilitate the nuclear station's transition from the support role it held during construction, to that of the principal department requiring support during power operation.' Among the areas cited by INPC as requiring
- additional corporate
[.
I emphasis or resolution for the station to complete properations for power operations' was the following:
'The solid radioactive waste handling group has nnt been staffed.' in addition. 'Maintetaance training was recently cancelled due to insuf ficient resources in the maintenance department to complete both the seneduled work and training. *
- e Senior plant and corporate management were not aware of these decisions or the impact on the maintenance department's readinese for power operatione.'
ALLE0ER'S CEARACTERI2ATION CF NNY RESPCNSE:
Many of the actione taken by PSHH auch as reinforcing and further defining respor.eibilities and staf fing the radioactive waste handling group were scheduled to be completed by December 1989. However, ongoing reviews to Adentify and if necessary to rosseign activities are not scheduled to be completed until June 1990 *and any identified responsibility reassignments will be Laplemented by Bentember 1990.* (emphasis added.)
NHY RESPCN6E Ybe responsibilities of the Productica organisation and othe New Hampshire Yankee organisations that support the l
Producs\\on organisation, are insiudad in the New Hampshire Yankee manual system. These responsibilities will be reinf orced and further defined on an ongoint basis. New
(
Hampshire Yankee senior Production management now chaire regular meetings with appropriate station supervision and corporate support supervision. At these sessione.
1 Production priorities are clearly and unambiguously defined, and the necessary support to resolve probleme areas and negative trende are identified and allocated.
Mr. Pollard's characterisation of the PSNH Response le misleading and out of context.- By selectively deleting sentences from the INFO Finding in his testimony, he gives the impression that the ' ongoing reviews' and
- responsibility reassignmente* due for completion in June and September 1990 refer to the items he guetes from the
_. _ ~
4.
I 6
j j
I INPC Finding.. A reading of the INp0 Report will reveal 1
- this not to be the case. The review that is actually otheduled to be completed by. June 1990 La one designea to j
enhance the structure of organisational responettiitties including vender manuals. design changes, and procurement engineering.
A Materiale Managenest Task Force has eleo been established to resolve problems and identify improvements to the organisation that will assure an efficient lor.g.
term materiale program structure.
t The Radioactive Waste Mandling Creup and the Operations
(
Support 3roup have been staffed.
4 With relard-to Maintenance training, the IN* O Tindir.g has ;
been fully addressed. A maintener.co training schedule has been established. This training is on track and is being implemented in e manner anat will fully support Stetion operatione. NHY sensor management has assured that adequate resources and attention are bein6 *PPli*d in this area to correct the condition noted in the INPC Finding-h In sunmary, NNY hee reviewed INPO Finding (1 18-1) l togetht; with the statue of NNY's cammitments to INP0.
Ve have determined that no issues eniet that raise any regulatory issues er that would preclude safe and f
conservative plant operation. The outstanding ccamassent items are enhar.comente related to increasing station efficiencies.
1.
t lb-
-w
issue:
Mamalement involvement and Casaltanat IWP0 R8PERENCE:
1890 Carporate tvaluation, dated December 26. 1989.
Findin6 (1.2A-1)
Page 6.
ALLECBR'S STATEMENT.
tlader Testimony, page II..
ALLEGER'S CHARACTERttATICN CF INPO FINDINCi
' Timely action has not been taken by the corporate organlaation to address and resolve some Lasportant problem areas that could affect station operation. In several casse, these problose were previcuely identified frees within the organisation. Wt corrective action was not adequately implemented.'
one of the three lengthy ensamples of $ significent problem areas' cited by INp0 was the following:
' Procedure adherence problems were repostedly identified in the esecutive aussaries of semi-annual quality soeurance trene reports since 1987. Newever, management action to address this problem was not initiated until early 1989 and was not effective in preventing an event in June 1999 that was. In part, attributed to non-adherence to a test procedure.'
INP0 also noted that 'despite the check valve failures at Seabrook and (previone INFO correspondence emphaelains the significance of check valve failures), an effective check valve maintenance program te not yet in place.
Additionally. a design review of check valves is not scheduled to be completed until April 1991.*
o ALLEGER'S CHARACTERIZATICN OF NHY RESPONSE:
Most of the actione discussed in the NNY respones were scheduled to be completed by February 1990. However. WHY stated:
"A taek team has been established to addrese vendor annual issues, and a comprehensive check velve design and monitoring program is under development.
Corrective actione associated with these issues will be fully implemented by December 1990, and October 1990, respectively.'
NNY RttpCHSE:
New Hampshire Yankee developed a program to identify open issues and problem areas that needed to be addressed prior to full power operation. These issues were consolidated into an Integrated Readinese Document, reviewed by New Hampshire Yankee senior annagement, seeigned a completion schedule, and tracked until closure.
.,1 >
- e:
A program has ales been established whereDy senior management meets with employees on a weekly basis to obtain feedback regardias operational or organaastional tesses, and to provide addittoa41 monitoring of the effectiveness-of corrective actisas Laplemented.
The operating Esperience Review Program (CEEP) has been-significantly strengthened._ The-0ERP implementing precedure (NNY Procedure'18910..Rev. 2) has been revised in a manner that will assure thorough, effective and timely evaluations, dissamination and action on operating-experience issues.= Corporate asnagement has issued
-direction to lower the threshold for the initiation of event reviews. In addition, as part of the low-power and power ascenelon readinese reviews, NHY reviewed the CERP and the individual recessendations associated with each Sir,nificant Operating gaperience Report (80ER) for their impact on plant operation and determined that there are no open Sott recommendations which impact esfe plant operations.
Procedure compliance trainia6 has been conducted for all site personnel and was completed on December 12, 1989. An initial review of the trainJa6 offectivenees has ateo been completed indicating a peeltive trend.
The existing vendar manual program is adeguate. A task team, however has been establiehad to enhance the vendor manual program. These enhancements will be onplemented by December 1990. In the interia, we have revised the appropriate maintenance procedure (MA 2.1. Revision 7) to address the INP0 finding by providing specific administrative controle to ensure vendor manuaLe are not Laproperly used.
Regarding check valves. Procedure NT 7.2. Inservice Testing of Valves. currently addresses the applicable regulatory requiremente for check valve performance as delineated La the ASKE aciler and Pressure Veenei Code.
Division 1.Section XI. Subsection IWV. A design review of check valves for applicability with respect to EPRI Report NF.S&79. Ana11emeina cuida11nes For check valves in Muelaar Power Planta. Leeued January 1988, and INP0 SOER 88 3. as well as preventive maintenance activittee, will increase system and plant reliability. This review is scheduled f or c4apletion in October 1990 (not April 1991 as stated la Alleger's testimony).
NNY has reviewed INPQ Finding 1.2A.1 together with the statue of NEY's commitmente to IntPC and the late filed allegation. We have detemmined that no issues exist which would adversely affect safe plant cperation.
4y l.
Issute Managenoot 2nvolvesant and ceamit, ment INPO
REFERENCE:
INp0 Corporate Evaluatione, dated Desember 28, 1989 Finding 1.1A.t. page 8.
ALLEGER'S STAT 1HENT:
Under testimesy Pf6 ALLEGER'S CMARACTERIEATION OF INPC FINDtNC:
' Corporate and station managere and supervisors are often not held accountable for timely completion (, assi5ned actione or improvemente to the station.' Emaaples cited by INPO included the following
'Approximately one.
guarter of 1.280 items en the integrated caemitment tracking system are past dues bases on a recent status report, 29 of 47 corporate goals (82 percent) will not be achieved in 19893 48 percent of the annual appressale for esempt, personnel in the station staff are overdues a number of issues identified in this and the recent station evaluation are stallar to those identified in 1996 and 1987 INPC corporate and station visits.'
ALLBCE1'8
.CHARACTERI8ATICH CF NHY RESPCM8Ei The PSNH. response consiste primarily of neoulous efforte such as instituting a
- Core Values and Work Ethic Program" to strengthen attention to detail, accountability, and annagement espectations, all of which were scheduled to be completed by December 1989.. One P8HN action that may be effective in correctin6 one problem is that ' completion of performance appraisale will be soeured by requir:.ng that performance appraisals be prerequisite to annual wage and salary actione.'
NHYRESPbHSE:
A Core Values and Work Ethic Program has been instituted as a foundation for stren6thening overall attention to detail, accountability, and general corporate mana6***nt espectatione regarding high quality work with appropriate attention to ceamitmente, cost control, and work efieesiveneee.
Performance le reflected in performance appraisale done on a yearly besie. Specific criteria have been included in the New Beapshire Yankee manuale and formally presented to employees.
The Integrated Cosemitment Tracklag System (ICTB) has been revised to implement a new priority system. tilhter controle on commitment date changes. and ciceer trackin5 of progress. A weekly review of the ICTS is conducted with station and corporate asnagers. These changes have already yielded significant improvemente in the timeliness of completion of assigned ICTS iteaa. As of March 13.
1990 the number of past due ICTS itea has been reduced to
q....
f i
1
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s tsgege.
Matatemance end Outage Manageoemt INPC REFERErcti IMPO corporate tretuatione. 44ted Cecember 26.198e.
Finding 1.LA4 page 10.
M.1,80ER* 8 $!ATEMENT :
None
- WWY RESPON8Ei In etter to tapeeve the esisting Staties senitoring ana treneing program, a specifically focueee corporate overview of the maattering and treading of esintenance activities and data ell 1 be estat11ehed as part of HNY's INPC commitment. Ealstia6 reposte generated by both tae station tae corporate organisations will be reviewed sea imptowed as aseeeeary by June 1990. These reporte vt11 De used te verify that areas needin6 improveesat are identified. sad to anaster the effectivenees of eerrective actione in progrees. 1N90 88 058. 6 P
'--e af sealms- --a at Numinae 9 amer semetana, win to usea in this eftert.
With relare to the Plading 1.1A.1 b vender naamal Leeue, see NET neeposee to INPQ Piadial lala*L (December 24, 1989. Corporate Bvoluatical.
With regard to the Findial 3.1A-1 e asiatenance training lesus, see NWT responee to INPO Fladias 1.31 (Decemeer to. 1999 Corporate Svaluaties).
This 1570 Findlag. Ippo's Reeeemendasten. sad the NMY toeposee all involve improvemente te estetta6 programe and de not tapact safe operation of the piant er NEY'e readinese for a fait power operating 11 cease.
NWY has reviewed INFO Finding 1.1A.1 telether with the status of WuY's sesautamate to INto. We have setermined that no issued esist which Deuld adversely affect este piant operation.
i i u
i
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u I
l spesosisately 1.8f.
Accounted 111ty for establast.e4 gesle has been emphasised in writial to til managere. A goals statue reporting program will be improved to pesait cleoer c6eparate annageesat monitoring of progress. The goale proStaa to beine rev6ewod on a quarterly boele to neoure tant estee11shed goals are consistent wtth senaer emnessment priorities. Geele wall be feranily medalled or removed.
as necessary, beood on thle review.
Personaei are beta 6 held eccountaM e tot completion of 1NPC's corporate and statina (Indlage by use of the improved latogroted Camattaset Tracking System.
accountabi1&ty f or complotles of performance appralosia le betal assured by requirtas taet periosasase appressale se a prereguielte to annual wage ans estaer actione.
All of the lessee identified in shie INPC Fineing the IlrPC teceanendatisa and the pirY seeponee relate to methose of introving admialstrative effectivenees and do not impcts safe operation of the plaat.
MuY hoe rev& owed INPC Fladin61.2A.2 together with the statue of M5Y's ceaudtamate to lupo end the late filed allegatten. We have determined that no leeues emies vnich woule adversely affect safe piens operation.
188Uti Material and Cutside Services
!NPC REFERENCri INPC Corporate 8valuatione, dated December 26. 1989.
Finding 2.1A 1. page it.
ALLB0ER'8 STATEMENT:
Nene.
HNY RESPopsg In November 1980, a Materiale Manalement Task Force was established. As part of this task force and on en interim basis, all procurement activittee report to one individual
-)
within the Production organisation.
1 This task force has been seeigned the responsibility of resolving probleme and identifyin6 orlanisational realignmente that will assure an efficient. Long term materiale program structure t. hat effectively supporte station operations. INPC 43-038, cuidelines fer the
. conduct of Maintenance at !4ucinar Power Stations will be used in this effort. The results of this task force will be documented, and an action plan to address any program enhancements will be issued, by June 1990.
The INPO Finding. INPC Recossendation and NHY Response all involve improvemente to existing programs and do not-impact safe operation of the plant or NEY's readiness for a full power operating license.
i;
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- ggggg, Human Rescurces INto RSFERENCE, INp0 Carporate Evaluations, dated December 26. 1989.
-Findine (2.88 1). page 14.
ALLECtt's STATEMENis Home.
Performance apprateal tracking sad policy revisione have NNY RESPOW88:
been implemented. A revised performance appasieal procedure has been Laplemented to aseiet manalers who are responsible for tLasty completten.. Periodic. statue reporte are provided to esecutive management. Salary increases for employees will be processed only after receipt of completed performance appraisals.
A Key Har.agement Development Program has been introduced and initiated. A progreen review will be held after ela montha. and the procese will be re.initiatec annually.
None of these issues has any bearing on safe plant operation or NnY's readiness for a f all power operating licones.
NNY has reviewed INP0 Finding (2.68-1) together with tho' status of NEY's commitments to INPC. We have determined that no issues esist which would adversely affect safe plant operation.
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188U3 -
Radiological 7:etestion
-;HPC
REFERENCE:
INp0 Corporate Evaluations, dated December 26. 1989 Finding 2.10A-1. page 13 ALL8021'8 STATEMENT:
Under feetheony, page 16 ALLEGER'S CHAAACTERIZATION OF INp0 F3NDINGs
' Insufficient management attention has been given to the development and implementation of a radioactive waste handling pro 6taa. As a result, although generation of radioactive waste has begun and the plant espects to begin power ascensica in the near future, key segmente of the radioactive weste program are not la place. Emamples include the following
'a.
Keeponsibilities for the processing of radicactive vaste are unclear. The corporate radiclogical' protection organisation is assigned responsibi'ity for radioactive waste snipmente by procedure. However based on an interface agreement approved in July 1989 the principal health physicist considers this reopensibility to have been shifted to the station maintenance utilities manager.
The utilities manager considers the interface agreement to be contingent upon staffing the utilities / radioactive waste organisation. (staffing positione not yet approved),
and has act accepted radioactive material processing and shipment responsibilities. As a result. neither group is modifying procedures to accomplish the shift in responsibilities.'
'b.
koorganisation and staffing to create the proposed utilities / radioactive waste organisation is incomplete.
As a result, progrees is not being made in training and procedure revisione, and development of long-term plans for interim radioactive waste storage pending resolution of final waste disposal options hae been delayed.'
'c.
The radioactive weste air.iaisation committee han not met in over two years, and has not addressed saleting station practices that contribute to unnecessary generation of radioactive weste. Management oversight has not been effective in identifying and correcting this probism.'
'd.
Plane and a11eetones have not been communicated for the temporary storage of radioactive waste prior to availability of facilities for long-term eterage. Despite the long lead times involved for some temporary facilities, plane have not been implemented. Various managere in the plant and corporate organisatioso have communicated different plane for interia storage of radioactive vaste ranging f rom flatbed trailere parked in the pectected areas to a new storage building '
)
E
ALLS $ER'8 "asARACTraigAttog or NNY ktSPON$ts
'A comprehensive radiosetive waste pr(gram will be developed by January. 1990. The progran v111 clearly i
)
define the respemeabilities, resources. sad preteeutee 1
necessary to handle espected vetumes of redlesetive weste.
Steps are heing takta te filt radioective waste toebe,teten positions. Temporary storage of eclid low level warte will be in place by M. A training preltam for reaieactive waste sechstelane has been estasitehed and will be-fully Lapleensted in the first guarter of 1890.'
(taphaste saaed.)
PHY RttPONSEs See Finding 177 1 of INPO Evaluation of Sestreek Stetten l
(Enclosure 31.
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New Hampshire Y6nhoe March 13. 1990 l
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te tMD0 Findinan gus t'adata of WNY teemaraan t
EvoluotiOR of $4Sbf00k St8tiCA. $4pt9ED$f. 1989 i
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188U8:
Station Crganisation and Admintetration INp0 kEFERNNCri INpo 3 valuation of Seabroek Station, dated 8eptember 1909. Flading (OA.1 1). page 6.
AL'.80ER'S STATD$ TNT:
None WWY RE$r0NSE:
NNY has publiehod its operational and incentive scais 1
pectrase for 1990. These protrame addrese all arose set out in the NNY reopense to INp0. The Operating taperience Review Program wee improved and reissued in January 1990.
l Further improvemente to the precedure will be made on an l
engeth6 beets se opportunities for improvemente are l
identified. Management's espectatione en minialains i
(3evaste have been eenvoyed to Station employees in out newsletter the ' Station Manager's Messenger'. reinforced with an incentive goal and v111 be reviewed at depersment meetings periodically. All of those are ir?revemente in omistlas acceptable programe se recomented by INPO and agreed to by NNY. Current prograno aset er escoed industry standards and reguistory requiremente.
NNY has reviewed INp0 pinding (OA.i.1) together with the status of NNY's commitments to INp0. We have determined that no issues exist which would adversely affect este plant operation.
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188VE:
Management Assessment INP0
REFERENCE:
int 0 etelastion of Seabrook Station. dated September 1989.
Flading (04.8 1), page 7.
ALLEGER'S STATEKtN1:
Yes. Page 7 ALLEISER'S CdAkACTER!!A!!ON OF INP0 FINDING:
' Monitoring of plant activities and prograne and supervisors is often ineffective in identifying needed improvements.' Cne esemples
- Senior station managers were unaware that vender manuais are used to conduct station activitise contrary to station policy. Interviews with Lnetrument ans centret technicians indicated that vender manuale are routinely uses to troubleshoot and repair procese equipment. Vendor manuale do not receive the equivalency of station operatir.g review e.osenittee approval, and a program is not in place to keep the manuale up to date.'
ALLEGER's CHARAct3122A!!0N OF NNY KESPCNSE
' Station maragement's espectatione of supervisore and mass ers regarding their presence in station work arose e
will be restated and reemphasised.' The remainder of the i
l WNY reopense did not specifiaally address the wee of vendor manuale in place of approved prc,cedures.
i NNY RE5FONSEs the Station Managenest Manual has been revised te clearly state espected management oversight in the workplace for nemagere. department supervisore and supervisors includin5 a summary of these activities to to submitted to the Station Manager on a monthly beste. The upgraded Suidance for supervisory walkdowns is written and being initiated. Approved procedures are in place, where required. for maintensace of safety related equipment.
The administrative controle governing use of vender manuale in the performance ef work are contained in the Station Maintenance Manual Procedure MA 2.1 section a.3.1.
The esisting programe meet regulatory requiremente.
however, improvemente have been agreed to by NNY ar.d !NFO ta the pursuit of escellence.
FEY hae soviewed INPC Finding CA.3 1 together with the status of WNY's condtmeate to INP0. Ve have determined that ne leeues esist which' would seversely affect safe plant operation.
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!$$Uta Industrial safety INP0 kEFERENCE:
INPC Evolution of Seabasek Static,n. dated September 1949.
Finding (0&.5 1). page 4.
ALLEGEk'8 STATDtENTs None NNY ktSPON83:
NNY instituted a multi. pert program to upgrade pereennel safety at Seabreak Station. ?kie included revising the pereennel safety program to increase supervisory monitoring of work practicee. implementing progreenive
]
disciplinary actions for violatione and interfacin6 the j
safety pro 6 ram with employee evalaations. Notifications 1
were slee made to site peroommel, reemphaetatng the importance of industry safety policies.
NNY has reviewed INPC Finding CA.51 together with the status of NNY's cosmitmente to INPO. We have determined that no issues exist which would adversely affect safe i
plant operation.
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Pitnese for Duty Program 1spo tapgtspect.
Ippo twelustion of seatreek station, dated september test.
Finding (OA.8 1). page 9.
AkkBOSR'S 87ATEMENT Wome
'NEY L58 POW 82:
Yhe NNY Fitnese For Duty Program was uPeresea en December 4 1989 to interparate the new requirements of 10 CFR 26.
NNY instituted a comprehensive Fittees For i
Duty training program. including behavioral observation techniques. for oli NNY and contractor pereennel who have unescorted access inte the Protected Area. Effectlye i
January 1.1990 Protected Area unescorted accese woe restricted for anyone not hawlas completoe the required training.
NNY has reviewed INFC Finding 0A.8 1 together with the statue of NWY's commitments to INPO. Ve have determined that ne issues esist which westd adversely ef f ect este plant operation.
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!S8tte Is.Nouse operating taperience Review typ0 targatwege INpo tvaluation of Seabrook staties dated September 1989.
I Finding (03.2 1). page 10.
ALLt0ER'S STATEKINie ALLEGER'S CHARACTERIZATION CP
!NPO PIND N0s
'The station has esperienced a number of recurring evente due to inadequate identification and Lavestigation of in.
house operational events.'
One of ein essaplee cited by INPO wee the followings 'Setween August 6 and leptember 9, 1949, water wee inadvertently drained from the refuel'ing water eterage tank er the condeneste storage tank on three occasione. The first event was due to a volve beins open that wee thou6 t to be danger tagged h
shut. The second event woe due to not performing a required volve lineup. The third event occurren while i
restoring oi ht valves that were discovered to be l
previously mispeettioned.'
It should be meted that the refueling water eterage tank and the condemente storage tank are Laportant safety equipment because they are the sources of water for plant safety systems, such as the emergency core coollas systems and the emergency feedwater system that are needed in the I
(
event of an occident.
I ALLEGER'S CEALACTERIZATICN OF NNY RESPON8E:
'The Station ;Aformation Report ($1R) procedure will be revised or a new reporting method will be developed to ensure that in. house operati.ng evente. such as thcee noted, will be investigated thoroughty and completed in a timely manner. This procedure will be updated and implemented by February 1990.'
l NEY RESPONSte New Kampshire Yankee has reviewed the guidance provided by l
Ipp0 for the use of operating esperience and has established the following proStam enhancements to ensure that in. house operat1#6 *#Pertence evente are Lavestigated thereughly asd completed in a timely manner. The station Informaties Report will continue to be used to document the investilation and evaluation of operational events which may require regulatory a68#87 ##tifiC*ti'# **
involve si$alficant problems that may require a root g
cause analyste or a human performance evaluation. The operating Emperience Review Program has been revised se that Operating taperience Review personnel review completed Station Information Reporte (811) to determine the required distribution of information. The Operatin5 taperience Program will be additianally enhanced so that
i s.
the operatir.g Espertence peroommel review site at their inception to facter inaustry esperiente into the SIR review process. This revision will be inserporated by
- 1 March 31, 1990.
i A new Operating taperience Review desument, tentatively titled the Operating Esportance Notice (DEN) will be developed to address in. house operattag owperience evente l
that do act meet the threshold of am 8!R. The OEN will be reviewed by Cperating Esportence personnel when it is initiated to ensure industry emperAonce le incorporated into the evaluation and at the templetion cf the revtev to i
ensure that the information le provided to the appropriate personnel. The CEN will be incorporated into est program
^
by March 31, 1990.
Additionally, the operating Esperienee program will be enhanced to include Operating tapertence personnel review of the Control Rosa Late portsdically to deteraane if any events.. that de not meet the thresheid of an 8:R..
have occurred. Such events will be decamented on sa otN.
This enhancement will be incorporated in the program by I
March 31st.
Additionally, each of the evente la question received estensive evaluation by NNY utilising the ett process. In each case the root cause wee determined and appropriate corrective actione developed. WHY has discussed each of these SIRE with the WRC. New Hampshire Yankee has also recently implemented a Human performance Sveluation System (Hyts) program to review similar evente from a human performance standpoint with the goal being the prevention of such evente in the future.
NNY has reviewed INP0 Finding C8.21 together with the statue of NNY's commitmente to IMP 0 and the late filed allegation. We have determined that no issues exist which would adversely affect safe plant operation.
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ISSUS:
Industry Operating taperience Review
(
INpC REFELDCts Station Evaluation 05.8 1. page 13 l
l ALL30ER'8 8fATStENT l:
ALLEG R'8 CMARACTER18AT10N CF IWp0 FIpp1NCi Some evente have occurred at the [Seabrook) Stetten that could have been prevented by istproves application of industry operating esperience. Zaplementatten of corrective actions to prevent occurrence of evente described in significant operating experience reporte (80ER) Le frequently rot effective or timely.' INp0 cites three esamples, involvin6 auttiple failures of safety equipment at Seabrock, which were the evbject of 50ERe Lesued before the failures occurred at sesbrook.
P l
'Cerrective actions taken in response to 118 80ER recommendations were reviewed durin$ the evaluation. Of these. 23 station respor.ees were determined to be not eatisfactory due to either 1stufficient progrees being ande, or the actions taken not being laplemented completely or ef fectively.'
'neview of e16aificant event reporte (SER) le frequently not complete or tiasly se indicated by the followtngs a.
Five 8tte one 1987 and four 1984 were closed out withcut being reviewed for applicability and appropriate I
corrective actiones b. Five lite 8tte have not received I
initial screenin6 for applicability.'
ALLEGER'S CEAAACTER11ATION OF M Y RElp0NSE
'The New Naapshire Yankee industry operating esperience review program will be impreved and strengthened to ensure effectivenese sad timelinese in the implementation of lessons learned f rom industry operating experience. A echedule has been developed f or the review and Laplementaties of outstanding Sone and Sme. The ggekloa of aman te.faa will be reviensed and terrective actione datamined.by. 0ttnha.r 1990. *
[Saphaele added.)
NNY Ltlp0NSti New Etapehire Yankee has revised the Operating Experience Review Program to goals of to days to review Red Tab S0 ne and implement recomesendations. Other sono and 881e are new reviewed and implemented within 120 days of receipt.
Additionally, all outstanding sons and their recommendatiene are being reviewed and action repricritized to be consistent with their relative importance. the project schedule and plant availentlity.
As an example. itene such as these related to Mid loop operation will be scheduled as appropriate to coincide with the implementation of design work resulting from Generic Latter 8417 constitaente.
We now teve an effective program in place to handle new
$0Re and SRs in a timely manner. New unapshire Yankee has reviewed all SOR recommenestions that have hen i
issued by INP0 and has deteralsed action plane sad echedules for all of the open SOR recessentatione. We are aggresolvely pureutr.g completion of all SO R resesmondatiene.
j WWir has reviewed INP0 PiswLing CE.31 together with the
)
status of NHY's cosmitsiente tc 1NPO ana the late filed allegation. We have determinea that no teoues estet whien would adversely affect este plant operation.
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IggUti Plant Hodifications INP0 REFEttpCE:
INp0 tvaluation of Seabrook Station. dated September 1989. Finding (TS.3 1), page 17.
ALLEGER'S STATDtENT:
Many plant changes de Aos tsceive appropriate technical review and are not incorporated into plant drawings and precedures.
ALLCGER'S CKARACTER3tA7:0N OF INPO FINDINC:
'Many plant changes do not receive appropriate technical review and are not incorporated into plant drawings sec procedures. The lack of adequate seeign review and documentation has resulted in plant evente and reportable conditione.' INPo cited four examples including the following:
'Escluding temporary modificatione required to support the power ascension test program, there are 64 outstanding temporary modifications with some installed more than four years ago. Fifty two of those 64 require design engineering decisions to be made permanent er cancel.
Twenty.one are being worked or are scheduled to be i
completed by 1990 however.10 are not scheduled f or completion until 1991 or later. and 11 have ne dates currently established.'
l NNY RESP 0M5E The NNY Temporary Modification Program is mocelled af ter the INpo Good Practice. Asessemente of the program nave consistently found the program to be thorough and effective. NIY has committed to review the scope of the temporary modification program. As part of this assosoment, esisting controle ws11 be enhanced to further ensure plant configuration e.entrol.
Previcuely installed temporary modifications that have been made permanent are being reviewed to onoure that maintenance procedures and vendor technical information are accurate. The plant has a program in place to eenAmine the use of future temporary modifications and is attempting to significantly reduce the current backlog.
This issue does not represent a safety concern. The l
temporary modification progras meets or eseeeds all regulatory requiremente. Each temporary nodification Le y
fully reviewed, evaluated, doc eented prior to installation. and periodically re. reviewed. This program has ateo been routinely evaluated by internal disciplines and esternal regulatory agencias and organisations.
NNY has reviewed INP0 Finding TS.S.1 together with the status of NNY's couaitments to INp0. We have determined that no issues exist which would adversely affect esfa plant operation.
9 b
ISSUE:
Plant Performanee Hemitering INP0
REFERENCE:
IWp0 fvaluation of Seabroek Station, dated SeptemDer 1989.
Pieding (78.8 1), Pages 13 to to ALL30ER'5 5TATEKENT ALL33E1'S CMARAC?S111AT10N CF INFO f!NDING:
' Preventative maintenance measures have not been establiehod to identify check valve perioreence presiens or degradation in some important eyetems. Recent tank valve problems, including a case of seat leakage that reesited in the residual heat removal system suction piping overpressurisation and two stuca open volume control tank nitruses supply check valves. demonstrate the mood for such measuree.'
The check volve failures anc ather prettene experienced at leabrook cited by INP0 involve many vital safety systems.
including the followings residual '.asa removal (which to part of the emergency core cooling of* tes): emergency feedwaters emergency diesel generator starting and cooling l
eystems. INPC also noted that " feet and inspection requiremente have not been specified for 66 of the 220 velves listed in the check valve mor.itorisg program.'
IWto also found that the esisting check valve monitoring program at Seabrook does met contain 'guantitative acceptance criteria' which industry experience has shown le necessary. Furthermore, the ' limited testing' of check valves at Seabrook 'may not identify degraded internal conditione such as worn hinge pine. Icose er missing non-pressure retaining parts or erosion of internal parte.'
ALL50ER'S CRARACTER11ATICN OF NNY 118PONSE The reeponee by NNY includee the fallowing atatemente.
'A review of the current check valve design and monitoring program will be conducted and completed by October 19e0.
This effort will include 3
- e a design review of check valves for applicability with respect to IPRI Report i
l NP.3479 (sic) and INPO SOER 86 3. * *
- Preventative maintenance om eclected check valves viii be performed prior to completion of the first refueling outase.'
[ emphasis added.)
this particular subject deserves additional discueston to illustrate its safety significance. A check valve is, l
simply, a valve which is deelsned to permit fluid flow in one direction and Le eupposed to close and prevent flow in the opposite direction if system pressare downstream of the valve le greater than the pressure upstream.
1 1
Q One common use of shock valves is to prevent ever.
pressuritation of lov. pressure systema connected to the
{
high.pressare reactor coolant system. yailare or j
eignificant laakage of cheek valves instelled in this
'interfase' between high.preneure and low. pressure systsee j
can result in what the NLC terms an laterfacing systeme less.of. coolant accident. This is an omtremely serieve 4
and fast moving accident involving destruction of the energency core cooling system, core meltdown, and radiation desee in the 100. rem range to the pualic in about an hour.
Thoaae Murley, a high level NRC officiel, has asseribed the serious nature of such an accident.
'This seguence is important in my judgement because
'it bypasses the containment and it bypasses emergency j
preparedness. It ef fectively bypasses two levels of j
our defense in. depth safety philosophy under the weret circumstances. The weret circumstances (are) thtt you have a break out in the tsa (residual heat 1
removal) erstem which then causes ycu to not only Icse coolant but to lose all your eefety injection (i.e.
emergency core cooling) capability, and which ultimately then leads to core damage and core meltdown to an open conta1 ament.
'That goes straight to the atmosphere anc it can l
happen in a short time. The weret tira calculations that I've seen can lead to core uncoverage in a half hour, core damage in 45 mJnutes, and off. site doses in the 100 rem range in en hour er hour.and.a. half.
l So its the importance of that sequence that caused me i
to consider taking another look at it.
I have no-(
evidence that the probability as ~4ther than what 1:
said in the PLAs (probabilistic Jisk assessments).
(but) I'm starting to see these precareers. so rather than take the PLA results at f ace value. I'm going to be a little skeptical, just because of thle sequence and its conseguences.'
l l
Inalda N.R.C., April 10, 1939.
i Cf coarse, esisting probabilistic risk secessmente (PLAs) rely. In part. on the assumption of an adeguate check valve maintenance program. As INP0 meted, the program at seabrook to inadequate and has already resulted la everpressurisatton of the ENR system due to check valve leakage.
NKY RgSp0NSg The check valves in use at Seabrook Station have been selected. epecified, designed, procured, installed and l
tested to the applicable industry codes and standards.
I Furthermore, the safety related valves meet the design and l
1.
e i
teettag requiremente la section 3.9 of the Seabreek PSAA.
NNY has developed design changes or work requeste to address the check velve iseses referred to in the IWpo i
inspection report. Seversi design changes have been I
implemented and in eene caete reviewed by the NRO. The volume centrei tank (VCT) sitrogen supply check valves are not yet modified. Maintomasco has been performed to i
correct the initial problem and the VCT nitrogen supply check valves are currently operable.
1 In order to enhance the entating check valve siaintenance program, a review of the current check valve uesign and etenitoring program will be Conducted and Completea by l
October teso. This effort will instado:
e a design review of check valves for applicatt11ty with roepect to 371% Report MP.3479. ' Application Guidelines for Check Valves in Nuclear Power Plante* issued January. 1988. and INp0 8031 46 3 Check Velve failures or Degradation. dated October, atte
?
e an asseeement of the appropriate preventative maintenance seasures such as inspection ann leak checks e an aseeeement of acceptance criteria ana provisions to revise test f requencies based cn inspection results.
NRY procedure MT 7.2. Inservice testing of valves.
l currently addresses the applicable regulatory requiremente for check valve performance as delineated in the ASHI Sciler and Pressure Vessel code Diviolon I section XI.
Subsection IW.
NNY has reviewed INPC Findiing TS.5 1 together with the status of NNY's constitaente to INp0 anc the late illed a11 station. We have determined that no issues estes which would adversely affect safe plant operation.
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lasUts Plant Performance Monitoring INPC
REFERENCE:
INPC Evaluation of Seabrook Station, dated September 1989 I
Finding (TS.S.2), pages SC to 43.
j ALLEGER'S STATEMENT:
None i
NNY R18?0N$t The turbine driven emergency feedwater pump was tuete.efully t.et.d in r.oro.ry. :..o.
the test demonstrates governor ramp.up. governor startup contrcl.
proper sequencing of the steam adateston valves. and operation of the steam trap drain system during poet.
modification testing. No waterhammere were esperiences i
and no tutkins overspeeds were esportenced when the syetta wee subjected to a design beste cold start condition. The NRC reeldent inspector and ot.her NRC inspectors were present and observed the consuct of the testing program. The NXY testing program for the turbine driven EfW pusip seats the requiremente of ASME Section XI and the Seabrock Station Unit 1 Technical Specifications.
As.found turbine speed and acceptance criteria for vibration, differential pressure, flow and speed will be incorporated into the emerlency feeewater pump surveillance precedures.
l In the design and laplementation of the final steam adalesien valve deelsn changes. NHY conaucted a thorough review of industry esperience sesociatec with turbine driven emergency feedwater pumps. including INFO Report 45 036, the operational Performance of Aum:11ary Peedwater Systems in U.S. PWRs 1980 198a. sorts of INPO $21e and t
8CERs applicable to emergency / auxiliary feedvater systems, and NRC :nformation Nctices and Bulletine. This review led to several enhancemente.that were implemented in the final desian. The entire desten modification program was further reviewed by independent consultante and their recommendations were considered in the final desi6n and testing.
The successful testing of the steam admission system to the turbine driven EFW pump in February 1990 demonstrates that the design changes meet all of the systes design I,
requiremente.
NMY has reviewed INPO Finding 78.3 2 together with the l
statue of NNY's coeritmente to 1NP0. We have determined l
that no issues exist which would adversely affect safe plant operation.
't i
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- 38pt:
Plant Performance Monitering INP0
REFERENCE:
INPC Ivelustion of seabrook Station dated September 1989, j
1 finding (78.5 1). Page 23.
ALLgstt's STATEMENT:
.Mone NNY RESPONSE:
Sarveillance testing for the reeldaal heat removal.
emergency feedwater, containment building spray, and safety injection pumpe is conoucted in strict compliance with ASMI XI code requiremente. The trending program 1
recosenended by INp0 will enhance the esisting surveillance l
program that meste ASME Section XI and the Seabrook Unit 1 technical specifications. A trending program could seelst la becoming a predictive tool to assese when a porticular piece of equipment. in this case a pump, should be otheduled for maintenance.
Flev testing of the residual heat removal pampe at higher flow rates requires a change to the technical specificatione for seabrook unit 1.
The current flow path asets the testing requiremente for ASHI SectiDn XI testing. Testing at reduced flows has been shown to be acceptable in NNYe resposee to NRC Su11stin 84 04 (NYN.
48093 and NYN-63184).
A comprehensive trending program has been estan11ehod fer the emergency diesel generatore. This trending program includes many parameters which are reviewed on a periodic beste. An effort is currently in proggees to establish
- action' levels for these parameters. se a point of 1
reference, to indicate when corrective action should be taken to maintain diesel generater reliability.
e Diesel generator performance trending to an enhancement to i
the teettag requiremente in the Seabrook Unit 1 technical i
specifications.
The trending program formalises existing practices to maintain diesel generator reliability.
NNY has reviewed INP0 Finding ?$.S.3 together with the statue of NEY's coessitmente to IMPO. We have determined that no leaves exist which would adversely affect safe plant operation.
l 1
188UE:
Document Centrol INP0 REFrRENCE:
INPO tvaluation of Seabrook Station. dated September 1989.
Finding it.7 1, page to ALL83ER'S $7ATDitNT ALLEGER'S CNAAACTER!!ATICN OF 1NPO FINDING:
'Unspproved vender techn& cal manuals are being used to perform verisce maintenance activittee. la addition eene i
of these manuals lack eufficient technical direction for the conduet of maintenance activities.'
ALLt0ER'S CRARACTERIZATICN OF NNY RESPON&E:
'The New Hampshire Yankee program for ver.cor manuale te presently being revised and strengthened. Part of this rev&olon will define wnich vender manuals will to available for use. how they can be used anc what review process must be completed. Full implementation of this program is scheduled for teemaher 1990.* (empheets added)
NNY RE8PONSE NNY's current program and procedures for hanaling vendor technical it.formatson, including manuale, enacreed the requiremonte of INF0 Report 24 010 (Vender Equipment i
l Technical Information Program). This report in turn addresses the requirements of NRC Generic Letter 83 24.
Section 2.2.2 regarding vendor technical informatica.
NNY's present vender manual pregram is effective and it includes the ic11owing objectives i
- Evaluation on the receipt.of vendor technical information and determination of required actions
. Timely performance of the required actione l
- Feedback on the completed Actione
- Records of vendor technical informatica are maintainec nad distributed.
The present program is currently being enhanced and strengthened in the following areas
. Improve the notification of station personnel of venect supplied information
. Provide edditional training on the use of existing procedures regarding control of vendor information
...I' i
. Jpdate station procedures which pertain to the use of vender technical information l
. Identify. cellect and previse contrailed distrabussen of l
any presently uncontrolled venaar manuale t
. Maintain andler establish centset with veneers f or the purpese of identifying and evaluating the need for additional information from the vendor and te ensure i
continuing updates of that information.
i NRY has reviewed INPO finding TS.71 together with the etotus of NW's commitments to INFO ant the late filed l
allegation. We have determined that se issues exist which would adversely affect safe plant operation.
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Conduct of operacione e
IKP0 REFEREECE:
INP0 Evaluation of Seabrook Station, dated September 1989.
Finding 07.2 1, pages SS and 26 ALLEGER'S STATEMENT:
None NKY RESPONSES the $tation Management Manual has been revised to clearly establish Operations as the lead organisation for day to.
dey plant operations. Attention to detail has been J
stressed by the Esecutive Director. Nuclear Production in meetings with operating shif ts and by the Station Manator with other departmente on a continuing basis. Additional staf fing has been provided to the operatione department in the suppstt roles to allow greater operatione management involvement with day-to-day activities.
The station j
Manager has provided guidance to the operattene Manager l
end Assistant Operations Manager concerning expected j
l management presence and communications with operating i
chifte.
The current Operations organisation and management guidance meet accepted 1HP0 standards.
j NKY has reviewed INPC Finding 07.2 1 together with the statue of NEY's commitaante to INPC.
- de have determined that no issues esist which would adversely affect safe plant operation.
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Plant Status Controle 1NPO kEFERENCE:
IFp0 kvaluation of Seabrook Station, dated september 1989.
Finding (OP.3 1), page 27.
ALLEGER'S ITATEMENTa ALLOSER'S CRARACTER12AT20W 0F INP0 FINt1Noi
'The station equipment tagging and Leolation procedure needs improvosent to ensure protection f or personnel and i
equipment.* INPC cited three probleme, some involving eafety systams, where the Seabrook procedures are act adequate to prevent personnel injury or equipment danese.
Akkt0ER'S CRARA0TERZ8AT20N OF KMY RESPONSE:
'The review of the current (tagging) procedure with sugge.eted modifications will be completed Dy June 1990.
The subsequent procedure revisione anc training will be completed by September 1990.
NHY ktSPONSE:
NNY is making enhancemente to the statica tagging control procedure to include tagging camponent control switches.
to provide for tagging order audits en a f requency odequate to identify problems, and to include Guidance for the proper sequence of component isolation and restoration. As part of these enhancemente a review and revision to the esisting tagging procedure vill be conducted during 1990. In the course of tnis review the INPC guidelines for the conduct of operatione and the INPO
+
good practice for tagging will be used and oli of the INPO concerns will be addressed. The taggir.g precedares currently in use provide adequate protection for personnel and equipent.
NKY has reviewed INPC findth's 07.3 1 together with the statue of NEY's commitmente to INP0 and the late filed allegatics. Ve have determined that no leeues esist which would adversely effect este plant operation.
i
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ISSUE:
Plant Status Centrole 1NPO REFEkENCli INPC Evaluation of loabrook Station, dated September 1889.
Pindtag 07.8 8. page 89.
ALLEGER'S STATDitNTi None f
NKY ttSPONSEs NNY meets or estette regulatory reguirements to administratively control the positioning of ccaposente l
which affect the reliability of a system or subsystem.
t this administrative control system speciftee verification of component position for test and surveillance procedure lineaps. tagging restoration. Initaal lineupe and other specified conditions. The program features Indepencent verification. Locked Camponent Verification and Maintaanet Camponent Verification in accordance with ANSI 3.2 and NUREO 0737. Intancements to this program are being j
developed to include additional good practices recommended by INP0.
NNY has reviewed INP0 Flading 0P.3 2 together with the status of NEY'e cceitmeate to INPC. We have determined that no leeuse esist which would adversely affect safe plant operation.
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Operations Procedures med Controle INp0 REFERENCEt INP0 tvaluation of Seabrock Station. sated September 1989.
Finding 07. 5 1. page 30.
ALLEGER'S ETATEMIF? r None i
NMY RESPONIC:
This issue addressee making INPO recommended enhancements l
to station procedures during the periodic review process.
A complete technical adequacy and consistently review of all Operations tepartment surveillance and operating procedures has recently been completed. This review provided many technical and human f actors enhancements.
During power operation, procedure deficiencies identified i
vall be corrected as required. Additionally estety related operating procedures receive a trannual review.
This review will insure that the procedures romaan technically uccurate and up to date wtth current prograss.
The Operations Department has recently completed a staff
)
aulmentation specifically for precocure maintenance. This group is currently using INP0 36 020 (Cood Practice OP.
210). Review of Cperatior.e Departs.ent Procedures.
These station procedures have been tested during the startup test progree durtag the past five years of shutdown operation, and during simulator training and as such have proven their adeguacy.
NHY has reviewed INFC Findang CP.S.1 tcgether with the status of KKY's commitments to INPO. Ve have determined that no leeues exist which would adversely affect esie plant operation.
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Maintenance Organleetion and AdmAnistration. Material condition of the Plant IWPO
REFERENCE:
INPC tvaluation of Seabrook Station, dated september 1939.
Finding (MA.2 11. page 32.
ALLEGER'S STATEKENT:
ALLEGER'S ORA &ACTERIZATICN OF INPC FINDING:
'The material condition cf some plant equipment and piping is cegraded due to corrosion. In addition. many equipment deficiencies are not identified in the werk teatrol systee.' INP0 cited ein emamples of problems including the following.
'Nearly SC percent (13 of 38) of a sample of equipment deficiencies checked were not in the work control system. Zaamples include the follewings excessive horic acid crystal buildup on core sprey and residual heat removal system volves...'
acth systems cited by INP0 are vital plant safeay systone.
ALLEGtt's CHARACTERI!ATION OF NNY Rg5PONSE
' Station management will stress the Laportance of routine reporting of probleme using the work request systes.'
The remainder of the response describes changes to the esisting Seabrook program which will be completed by January 1990 and a new proStan to complement the esisting program which will be completed by September 1990.
NHY RESPON$ta The Station currently has a five. year plan to paint all building areas. Implementation of this plan was starte i in February 1989. The schedule is reviewed periodically.
Station management routinely ro.emphasiese the importance of routine reperting of problems using the work request system. The Station Management Manual to reviewed l
periodically and changed se necessary to ensure that management espectations of Station personnel are clear.
The program for supervisory walkdowne has been upgraded and the walkdowns are being initiated.
A deficiency tagging program is being added to the work control prograa.. This program will complement and enhance routine reporting and supervisory walkdown reporting.
These enhancements will serve to further improve pectrame which meet all esisting regulatory requiremente.
NNY has reviewed INP0 Finding MA.2 1 together with the statue of NNY's commitmeate to INPO and the late filed allegation. We have determined that r.e issues emiet which would adversely affect este plant operation.
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ISSUte Work Control System IWp0
REFERENCE:
DrPC Evoluotion of Seabrook Statian. datea September 1989 Finding (NA.3 1). page 33.
l ALLECER'S STATDtENT:
None
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NNY RESPONSES NNY hat instituted progrounatie changes to enhance scheduling of maintenance activities and tracking of necessary spare parte. A requirement hee been added to
)
t.he scheouling prograse to include, in the Project 2 (P.2) 1 ocheduling network, any asintenance activities that require tagging. This chsnge will serve to ensure that the operations work control desk and other support i
functions are avere of upcomial pisaned work.
In addition changes have been implemented to combine the l
scheduling of routine maintenance taske end technical specification surveillances. Other enhancemente to the progree will be made se appropriate.
NNY has reviewed IMPO findial MA 3 1 together with the l
statue of W8Y's osemitmente to INPO. We have determined that no issues eniet which would adversely af fect safe plant operation.
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ISSUEt Maintenance Pacilities and Equipment INF0 REFEttWCE:
100 Evaluation of Seabrook station. dated September 1989 Findint MA*8 le poles 36 37 ALLBCER's STATEMENT None NNY R18p038E the esisting incilities for shop work on centaminatet equipment include a 'het side' machlae shop, a emell storage area for instrumentation, and a decontamination area for small toole in the Weste Processing Buildint-these facilities will be supplemented as necessary by the use of portable / temporary facilittee.
theos fac111 ties have been evaluated against the anticipated neede of the station for the first operating cycle and have been determined to be adeguate. It should be noted that the esisting facilities have been adequate for the estensive maintenance activities over the last three years since the issuance of the operating license.
As an enhancement to the esieting iaca.ities. the plant's five. year plan for facilities includes fundir.g for a new esponded permanent matatenance and decontamination facility. This new f acility is presently under study and is espected to be in place prior to the first refueling outage. The plans for the new facility include an i
espanded instrumer.tation calibration ana worn area. a decontamination facility and additional low. level radioactive waste storage space. The guidelinee containec in INP0 05 038, cuidaitnam far the conduct of Maineenanea i
l st Nucinar Power itatinag. ana EPRI NP 4330. h Ensinaarina Damian. fan 11alinas ter Maintainability, will be utilised in establishing these facilities.
NEY has reviewed INPC Finding MA.S.2 together with the l
status of NNY'e cosmitmeste to INpC. We have determinee that no issues esist that would preclude oef= and conservative operation of the plant.
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288vte Maintenance Personnel Epew6 edge ana Forformance 1NP0 REFEttEtt:
IMPO tvaluation of Seabrook Station, dated September 1909.
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Finding (NA.iD.11. page 37.
ALLtorR's stAttMENT:
None RET RESPONSES A qualification manual has been developed to provide direction for consistent qualification of techniciane.
]
including Maintenance personnet. T!.e Station Maintenance i
Manual provides direction for assignment of gualified er trainec personnel to accomplish natntenance taske, j
Trainir.g program development is continuing. CJT modules are teing developea and 0.'T instructors are being trained.
The Maintenance and Technical training Croupe have qualifica instructore and evaluators for all job perf ermance measures approved to date.
Continuing training on operating esperience is developed and delivered at least three (3) tisme per year.
An INPC secteditation team visit for the sechanical.
electrical, and instrument and control training is currently on schedule for mid-April.
getablishment of the above mentioned prostaas vill enhance existing programs and will facilitate determination of workers qualifications.
WHY has reviewed INPC Finding NA.101 together with the status of NNY'e commitments to INPC. We have determined that no issues exist which would adversely affect soft plant operation.
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- f gg3uLATORY $ENICE8 1 683 474 ?!21 441 5.01 288UE:
Solid Radioactive Waste
!NPO
REFERENCE:
1370 svaluation cf Seabrook Station. dated September 1939 Piading RP.7 1. page 60 ALLEER'S 87Af tHENTi None WNY RESPCHSE NNY has cospistad development of a comprehensive rad weste program including staffing and training requiremente. A new interface agreement was signed that delineates the reopensibilities for processing radioactive vaste. The Red vasteIUtilities Department has been reorganised and staffed. A training program for rad waste personnel to being implemented.
The chairmanship of the tad waste minimisation coemittee has been transferred to the had Veste/ Utilities Department supervisor. A rad w ete minimiastion program has Dean implemented and final plans of temporary storage of solid lov level rea waste have been completed. anformation on espectations and methods to minimise rad waste have been conveyse to plant staff via the ' Station Manager's Messenger' and are included La pertiene of 87 had Worker training. A program is underway to mark tools for use in the tcA including establishing tool bones in containment.
The present 1e9018 of staffinge training and esperience were reviewed during NRC inspection 30 443/90 03 held January 8 12. 1990 which found to violations and judged the program ready for in11 power operation.
This inspection tacluded reviews of the solid waste processing system capabilities, design and operation status.
NNY has reviewed INP0 Finding RP.7 1 together with the statue of NNY's commitments to INF0. We have determined L
that no issues exist which would adversely affect safe j
plant operation, l
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ISSUE:
kadioactive Contaminaties Centrol
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INP0 ktFERENCE:
INP0 Evaluation. dated September 1989. Finding (k7.91).
page 41.
i ALLEGrt'8 STAttHINT None i
FWY RESPON$t Corrective maintenance to repair leaks from the prLaary eystems were verified to be complete prior to entertag Nede 4 by the Assistant Station Manager, who cor.aucted a system walkdcwn. Other than minor drippage from CE.V 13S se leaks were identified. An ongoing observation progren delineated in the Station Management Manual requires managare and supervisore to perfora such plant weikdowns.
Changes to Health Physics procedures have been completed to improve centrole over leak containment devices and temporary drain lines.
tastneering has been requested to review the RCA Checkpoint layout to Laprove ingress and agrees layout to minis 4 e potential cross.contaminatten, The Radiation Protection Program meets industry stamaarde and regulatory requirements.
STA.28 NEY has reviewed INPo Finding kP.91 together with the status of NNY's commitments to INPC. We have determined that no issues exist which would adversely affect safe plant operation.
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Ohesastry Control INPC
REFERENCE:
INPC Evaluation of Seabrook Station, dates september 1989. Pinding (CY.3 2), page a4.
ALL80E:L'S SYATEMENTs' None NNY RESPON$tr NNY has changed the analyele protocol in Chemistry to t
ensure ste** generator bicwdown Impurities are analysed at the one part per billion level. Additionally. engineering evaluatione are in process to add temperature conditioning.
to the makeup water samples and hotwell samples. Station chemistry analyt.ical capabilities and prograne are in 1
. accord with the Westinghouse requiremente and regulatory requiremente.
NHY has reviewed I.NPQ Fitading CY.3 2 together with the status of NiiY's cossaitments to 1370. We have determined enat no issues exist which would adversely affect safe plant operation.
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Operating Emperience Review INP0 R8PERrt'CE:
80ER 819 Recesinendation 2B
'u Desiccant carryover to the Instrument Air Systems Perform regularly scheduled maintenance en the downstream filter elegients of the instrument air system.
ALLEGER'S STATDtENT:
General reference to $CER's. page 8-paragraph 6 and S WHY RESPCHIE:
The Maintenance Department is developin6 R*P*titive T**k Sheese for the downstream filter elements. Action is scheduled for completion on April 30, :.990.
To date. NHY has not esperienced desiceant carryover in the Instrument Air systemt therefore, proper functioning cf the Instrument Air system has been demonstrated.
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operating Emperience Review Dipo REFEttNCri 60ER 82-9 Recommendation 1 Turbine generater esciter emplosioni Ensure preceduree l
eddress senitoring and trending of hydrogen ges usage.
Procedure eheuld include Guidance for action when usage esseeds a specified level.
A11EGER'S STATEMENT s Centrol reference to SOEE's, page 8 paragraph 4 sad 5 NHY RESPON5ti A hydrogen gas use trending program will commence upon achievement of 1002 power. The trending pro 6 ram will be included in the Technical support Performance Monitorial Pro 6 r,em.
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EW ge%.A F-188Uti operating tsportence nev&ow INp0
REFERENCE:
SOdlk 01=12 Recesuneadatlen S 84 febe rupture due to loose parts en secondary essei train plant pereennel tanaluding contractore n involved with eteen senerator repear ans metatenance en the importance of prevent &a6 atocellanoeue e0jects f rom beans left in eteen seneratore.
ALL,ar,st's stat 3Manti Genere& reference to lost's, page e paragrepn e one 5
- euY EssPopSEs.
A complete revleien to the lesses plan for MA3.3 usuosteoptag. will be developed for hture tatttet tratalA6. Continuing trainta0 en ante 808 will be senducted prior to the first refueling.
Entry late the steam generatore te not espected prior to the first refuellag. In the event en entry to requared prior to first refuelin6. tratr.ing vill be provided praer to entry, e
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1NPQ REP R INCt+
Sott 82 13 kocompetuation 11 Intr 4elon of roein. Lubricating 011. anc organic cheatcele into reactor seelent waters consider scettiensi scocese etope to reeees orgente sostaminettoo if chronic contam& nation by organics esAste.
and 3 Generet teforence to SCER's page 8 paragraph 4 A*.L505E'S ETATRKENT:
check Design Coordinatish tepert 84 236 will tastall e WHY R88PCN9ti
- his alteration valve in the refueling sovity drair. lir.o.
is scheesled for completten praos to the first redde11r8 outt6e.
The refuelias cavity ersia LLae will not be needed until the first refuelih6*
188Uti operating Esperience Review-tWp0 RSTERENCE:
80ER 42 13 Recommendation 12 Training employees on chemiest intrusion into RCS ALLEGER'S STATDGNTi General reference to SOER's. page 8 paragraph 4 and 5 NNY RESPONSE A complete revision to the lesson plan for MA3.3.
Housekeeping, was developed for future initial training.
Closed.
Continuing Training on this 50ER will be conducted during the let quarter of 1990. Training program in place..
Closed.
General Employee Trainint Leeson Plan S-35 vae revised to reference this $0ER for Initial and continuang Training.
Closed.
The current chemistry Department Continuin6 7861#188 program includes trainin6 on chemical intrusion into the RCS.
The mention of t.his SCER will be incorporated into Chemistry Department Continuing Training by December 30, 1990. se an enhancement.
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Operating Esperience koview INPC REFEEENCE:
50ER 8213 Recomuneadation 13 Caution contractor personnel about the potential effects.
of usage of uncontrolled chemicals j
A1. LEGER'8 STATDENT:
General reference to 80ER's, page 8 paragraph 4 sad S Ntrl RESP 0Msti General Employee Training t.eason Plan s.35 wee revised to reference this sort for Initial and continuint Training.
Closed.
Training of centractors on the requirements of this leeson plan has been completed. Closed.
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i ISSUE:
Operating Experience Review INP0
REFERENCE:
80E1 88-15 Recoemendation 1 Freesing of esfoty related equipmenti keview critical system instrumentation and equipment that may ne affected
.j by severe cold weather to identify needed modifications, 1
l ALLE3ER'S STATEMENT:
General reference to $0ER's, page 8 paragraph 4 and 5 NHY RESPCNSE:
The desi5n of critical. instrumentation and equipment was seroviewed for severe cold weather provisione during the construction phase subsequent to the release of NRC IEE Bulletin 79-24.
Since that time, no freeze up of eefety related instrumentation or equipment has occurred as a result of a design deficiency. NHY amintains a 'Freese Los' in the Control Ecom which le reviewed annually to l.
aseees the need to modify systems or structures.- The annual review of this log is scheduled for mid-April 1990, i
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!$$Uti Operati"5 3*Perience Review -
INFO
REFERENCE:
80ER 42 1$ Recommiendation 2 Procedures os freese protection Ensure plant procedures include previolone for protecting critical systeme-ALLECER'S STATEMENT Cenersi reference to 80ER's. page e paragraph 4 and 5 NHY RESPONSES Procedures recosmonded for freese protection of critical systest ir.strumentation and equspoent are written and approved. Closed.
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oposating taperaente Deview 1Np0
REFERENCE:
SOER 8315 Recessioneet ton 3 l
Seasonal resanderg to Operationee Provide seusonal l.
remindere to operatione pereennel concerfdas freese l-protectico of eefety reisted equipment.
A11.8051'8 STATENDff s Genesel soference to 80ER's page e peregraph e and 3 wuy RESpCNSte The toepensee te hecesumessatione 16 2 of thie SQER ensure that these should not ce say f reese protection concerne I
for the beleece of thle wanter. A general procesure to I
identasy plant readinese for cold weather opesessono le
(
under development and will be opproved by June 30, 1990.
This is en enhameement for the fall of 1990.
A seasonal reminder wee sent to Operatione pereennel for the winter of 1989 90.
e tapetitive toen sheet wee developed and pieced on the automatic scheduling system so that a reminder will be sent out annually hereaftar, closed.
Training Development toquest 40-186 will incorporate snie 3081 into Initial and continuir.g Trainsag by september 30, 1990.
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!ssUE:-
Operating Experience R;viev INP0 REFERENcts.
gogR 8213 Recomunendation a training on cold weather operations: Provide continuing training on lessons learned frass cold weather operation.
i; ALLEGER'S STATEMEMti General reference to SOER's, page 8 paralraph 4 and 5 11
(.
IRIY RESPONSES.
Trainin5 Development Request 89-284 will incorporater ongoing cold weather lessono learned at seabrook into Initial and Continuing Tralains by September 30, 1990.
This continuing training will be conducted prior to the next winter..
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IMPO
REFERENCE:
' SOER 82 15 Recosmondetion 3-calibration of thewed equipment. Recalibrate thawed instrument lines prior to returning sc service.
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ALLEGER'S STATEMENT:
General reference to SCER's, page 4 paragraph 4 and 5 NNY RESPONSE:
standard Vork Practice IC.006 has been issued to address maintenance guidelinee-to recover from frosen instrument lines or equipment. Closed.
2 The Standard Vera Practice ensures that proper action will.
be taken'in the field.
Training Development Request 89-o l
286 will incorporate the guidance into Initial and Continuing Training-by September 30. 1990, as an l
enhancement.
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Operating Expersonco Review INPC
REFERENCE:
10ER'82-13 Recommendation 6 Recalibration of thawed equipmenti--All frosen equipment that has bee. thawed should be enantned to ensure structural integrity before returnin5 to service.
ALLEGER'S STATEMENT:
Ceneral reference to 80ER*e, page B paragraph 4 and S NNY RESPONSE:
Standard Work Practice 1C-006 has been issued to address maintenance guidelinee to recoves.from frosen instrument lines or equipment. Closed.
The standard Werk Practice ensures that proper action vill be taken in'the field. Training Development Request 69-284 will incorporate guidance into Initial and Continuing Trainin8 by September 30. 1990, as an enhancement.
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Op'2 rating sup;rience Rsview I
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. INP0
REFERENCE:
.. 50tt 43 4 Recommendation 10-i Reactor Trip Bresher Failures Emeure procedures incorporate esfoty-related vender data and changes into
.l the preventive ' maintenance programe.
AL.1.IG ER ' S S TATEMENT :
General reference to 80ER's, page 8 paralraph 4 and 5 J
NNY RESPONSE:
NEY's current program and procedures for handling vendo-
-l technical information. including manuals, endorsee the requiremente of INP0 Report 16 010. Vendor Equipment.
'i Technical Information Program. - This report in turn-addresses the requirements of NRC Generic Letter 63 28.
Section 2.2.2 regarding vendor technical information.
The current program le being enhanced and strengthened to:
Laprove the notification of, station personnel of l
vendor supplied information:
L
-Provide additional training on the use of existing procedures regarding contral of vendor information:
Update station maintenance procedures-wnich pertain L
to the use of vendor technical information:
L Identify, collect and per ide contro1 Led distribution.
of any prosesitly uncontromled vendor manuales and Maintain and/or establish contact with vendors for the purpose of identifyin5 and. evaluating the nose for additional information from the vendor and to ensure continuing updates of that information.
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tssute operating taperience R; view
.IWp0 REFtttNOts 80ER 83 8 Reconsnendation 12 training should enable appropriate technical stafi and managersloupervisers to:
A. Determine the safety class of equipewat and activities for which they are responsible.
i;
- 3. Implement QAtQC policies in procurement of parts and p
components. and in work on safety.related equipment.
C. Conduct and review post trip analyses.
ALLEGER'S $?ATEMENT:
General reference to 80ER's, page 8 paragraph 4 and 5 i.
NNY RESPONSE:
Training Development Request 89 264 will formally..
l-incorporate this SOCR into lesson plans for Initial and
[
Continuing Training, scheduled for completion during 1990.
NHY has already conducted training for appropriate technical staff includings Detailed' Systems Training.
Event tvaluation Training and Root Cause Analysis Training.
The Material Requirements Department review and the Quality Assurance review of safety-related parts procurement documents ensures current programs are implemented properly. Training for technical staff will enhance implementation of the parts procurement program.
=.
Appropriate technical staff have received training in equipment qualification 10 CFR Part 21. Codes and Standards and Coasnercial Orade Pvdication.
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=ISSUti operatirg Expericace Revicw
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i!NPC REFERENC!i 30ER 83-9 Recommendation 7 Valve Inoperability caused by Motor.0perator Failures:-
Ensure plant procedures require an evaluation of valve operability when valves that perform safety function eget.
be manually seated or backeested. D4clare MDVe that perform a safety function inoperable if they have been si,ther manually seated or backeested until HDV operability is verified by electrically stroking the valve.
ALLEGER'S STATEMENT -
General reference to $0ER's, page 4 paragraph 4 and S
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NMY RESPCNSE:
Plant Procedure CM1090.01, ' Manual Operation of Remote Operated Valves ' has been reviewed and a precaution has been added that addresses evaluation of valve operability if a valve has been manually seated or backsented.
Ciceed.
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SSUEi-Operatins Experience R3 view 3to stitt:NCE:
80ER 84 3 Reconneadation 5 Ausiliary Feedwater fuapo Disabled by Backloakages Raours, PN program includes periodic-inspection or testing of all' check valves in' the Deersency Feedwater' system.
ALLEGER'8-8?ATEMENTi-General ~ reference to 80tr e, page 8 paragraph 4 and 5
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NNY RESP 0588:
Feedwater backflow that stay cause steam binding of an SW pump during EW non running conditions is logged by the roving ausiliary operator twice a shift in modee 4 and h1 her.
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- RFV pump discharge check valves are backflow tested during periodic BW pump surveillance testing.. Acceptable forward food flow of the runnin6 train is measured to.
demonstrate, amont other thin 6e. adequate closure of the non-running pump's discharge check valve.
Check valves FW.V 64 and 70, as well as the downetream check valvee in the EW eystem, are included in the Check Valve Monitoring Program. Enhancements to this program are under evaluation.
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'188Uti Op; rating Experience R: view
.p INPC REFERENCES 80ER 84-7 Recomunendation 3 Pressure !ocking and Thermal Sinding of Gate Velves:
Train operations and maintenance personnel on how to diagnose and recover from the pressure locking and thermal binding valve failure mechanism.-
ALLEGER'S STATEMENT:
General reference to 80ER's, page 8 paragraph 4 and S -
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WNY RESPONSE:
Operatione personnel currently receive training on valve operation and routinely operate valves at seabrook.
Training of Mechanical and Electrical maintenance personnel is an enhancement to er.sure cosmon knowledge of -
4 these type of valve probleme. Training Development Request 89-185 will incorporate this SOER into the lesson plans. Mechanical and Electrical Continuing Training vill be completed by March 30, 1990.
This 80ER is included in Auxiliary operator Initial Trainings Leeson Plan N12701.- Cicted.
This 80ER will be incorporated into Electrical Initial Training by' June 3C. 1990, as an enhancement.
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Y 1288Use Oper0 ting Empertence'10 view INp0 EEFERENCE:
SOCR 85-3 Recommendation 1-Valve Hippositioning Svente Involving Human geror: Train operatore, maintenance and supervisory personnel in procedures used to position and verify valve positions.
Strese need to comply with procedures and need to identify-incorrect procedures.
ALLEGER'S STATEMENT:
General. reference to 80ER's, page 8 paragraph 4 and 5 M RtSPONSE:
Training Development Request 89 286 will incorporate velve mispositioning events into continuing operations Training by May 30. 1990, se an enhancement.
J Leeson Plan 05 regarding the Talging Program will incorporate this 50ER by March 30, 1990, as an j
enhancement.
The licensed operator training pro 6 ram provides training l'
en valve mispositioning evente.
All station personnel have received procedure compliance training to insure knowledge of and implementation of NNY policy.
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l' 148tTEi Cperating Esperie2ce Review 3P0
REFERENCE:
SOER 66 1 Recommendation 3 Reliability of FW1 Aus111ary Feedwater Systems: Test El'W
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pumpe periodically under conditions and configuratione expected during any operational event demand. laciude l
tast, cold starting of the pumps simultaneous and automatic starting of all pumps and testing of the pumps for various steam espply, condensate supply, and pump.
discharge flew configurations that may reasonably occur.
. ALLECER'S STATDtENT:
General reference to 80ER's, page's paragraph 4 and 3 NEY RESPONSE:
Testing of the steam driven EFW pump to demonstrate governor ramp.up, governer startup control. eequencing of steam supply valves, and operation of the steamtrap drain system was completed in February, 1990..No water hammers were superienced and no turbine overspeede were esperienced when the system was subjected so design basis cold start conditions. The NRC resident inspector sad other NRC inspectors were present. Closed.
Acceptance criteria for vibration, differential pressure.
flow end speed were incorporated in-the EFW pump ourvalliance procedures. Closed.
NEY is monitorins-EFW system performance with respect to reliability. Quarterly starts of the steam ariven EFW pump under demand conditions are being evaluated.
Completion is expected on March 31. 1990.
Surveillance procedures will be revised. if necessary, based on the results of Erw pump quarterly start evaluation. Completion is 4cheduled for April 30, 1990.
The use of two normally closed steam supply valves and the requirement for full flow within 60 seconde is being evaluated. in accordance with INPO's recoeunendation.
Completion is earpected by March 31,.1990.
l Testing requiremente for the overspeed trip mechanism are l -
being evt.luated and a recommendation will be provided by June 30 1990.
The overspeed trip mechanism was tested estisfactorily.
The mechanism will be tested on an 18 month frequency (refueling).
Nrt has reviewed EFW eystem performance and INF0 recommendatione and determined that no issues exist that raise any regulatory issues that would preclude safe operation.
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w ISSUES Operating Espericace Revio:
INFO REFIRENCE:
- 80ER 86 2 Recommendation 1 J
Inaccurate closed Position Indication on Nove Identify.
H0ve with remote position indication in watch existing limit evitch settings can result in e closes indication while the valve is actually partially open. Take actior.e where necessary to prevent premature closed ladication due to limit evitch settings.
ALLEGERiG STATEMENT:
General reference to 50ER's. page 5 paragraph 4 and 5 NNY RESPONSE:
Design Coordination toport 86-401 has been completed in the field. The work performed under DCR86 403 addressed-the position indication concern developed by INP0.
DCR99 026 wee issued to address the balance-of the MOVs.
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'I All field work Le scheduled for completion prior to etartup from the first refuellag.
The current plant configuration provides positive indicacion of valve position and neste all regulatory requiremente. DCR89-014 provides en enhancement-for operators. The equipment and associated circuit functions have not changed.
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Operating 1:perse1ce Review fy
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INPC REFEttNCEs-9051 98 3 Recommendation 1 Check Valve Failures er Degradation Establish FM precedures (e.g.. a test and inspection program) that identify esisting and incipient failures of check valves in appropriate systems. The program should include periodic testing, surveillance monitoring to identify seat leakage and other developing problems, and disassembly and tuspection on a sampling basis to ensure check valve -
internals are intact _and are not emperiencing abnormal wear.-
i ALLECEt's s7Afsnruf General reference to sota's, page e paragraph 4 and S NEY RESPONSES Inspection eng testing vill be based on industry and plant esperience.
Preventive Maintenance procedures will be modified based on the results of the desi5n review in 50ER 86-3. Rec. f2.
Completion is scheduled for December 30, 1990.
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Operating Esporience Review 7,
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INP0
REFERENCE:
80ER 88-8 Recommendation 2 Cheek valve design review on valves included in the station check valve PN program. Review should determines proper elao, proper type, proper orisatation, proper locaties. Zaitiate design changes or perform additional PMe and testing for check valves determined to be misapplied.
ALL.ISER'S STATEMENT:
Ceneral reference to 80ER's, page 8 paragraph 4 and 3 NNY RESPCNSEs Check valves have been selected, specified. designed, procured, installed and tested to the applicable industry codes and standards. The safoty-related valves meet the design and testing requirements in Section 3.9 of the PSAR.
NHY has developed design changes or work requeste tc address the check velve issues referred to in the INPO report. Several design changes have been implemented and in some cases reviewed by the NRC. The volume control tank nitrogen supply check valves are not yet modified.
Maintenance has been performed to correct the initial problem.
A review of the current check valve design and monitoring program will be conductsd and completed by October 1990.
This effort will includes an assessment of the appropriate preventive maintenance. measures such as inspection and leak checks: an assessment of acceptance criteria and provisions to revise test frequencies based on inspection results: a design review of check valves for applicability with respect to EPRI Report NP-5479
' Application Guidelines for Check Valves in Nuclear Power Plar.ts.' issued in January 1988.
Procedure NT 7.2 ' Inservice Testing of Velves' currently addresses the applicable regulatory requiremente for check valve performance se delineated in the ASMB Boiler and Pressure Vessel Code. Division 1,Section XI. Subsection TW.
NNY has determined that no issues esist that raise any regulatory lessee er that would preclude safe and conservative operation of the plant.
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ISSUS:
Operatin8 Esperience Review INp0 LEFERENCE:
80 8 88 1 Recessnendation 3 Instrument Air Bretos Failuresi Training on the Laportance and potential for comunen moes failures of Instrument Air systems caused by such things as particulate, hydrocarbon. and water contamination f or operators and maintenance personnel.
ALLECER'8 STATEMENT:
General reference to 80ER's, page 8 paragraph 4 and 5 NNY RESPON8Es Trainin5 Development Request 48-071 will incorporate this 80ER into initial and Continuing Training for Operations and I6C personnel by July 30. 1990.
This is not a safety concern since air eyetess are periodically verified for particulates, hyarocarbon and water contamination. The scheduled training is an enhanceneet, l
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Operatin8 Experience Review.
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IMPO
REFERENCE:
80EB 88 1 Recesineadation 6
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~ Premature Criticality Evente durial teactor Startups I
teacter startup precedure premature criticality
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monitortas.
ALLEGER'S STATEMENT:
General reference to 80ER't. page 8 paragraph 4 and 3 NNY REstousti operatione reviewed plant. procedures os1000.01'and 081000.07. Revisions were made to both procedures to incorporate the concerne of this 80E1. Closed.
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' operating Experience Review fy.
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REFERENCE:
SOER 88 3 Recoeunendation 2-'
Loss of Residual Heat Removal with Redueed Reacter Vessel Water Levels Review the procedures supporting Residust Meat R aoval system eperation to ensure that precedure improvements accessary to support plant actione in response to 80ER 85 6 have been lacorporated.
ALL80ER'S STATEMENT General reference to 50ER's, page 8 paragraph 4 and 3.
NNY RSSF0NSE:
Operations will review plant procedure 081213.01. A revision will be made se appropriate to incorporate the concerne of this 80ER. Completion le scheduled for May 31, 1990 or prior to operating at reduced vesse' water
- level, This is not a safety concern since operation of the RRR eystem with a reduced reactor.veneel water level is not espected to occur until at least the first refueling.
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n-l Encleaura $ to NYN.00073 I
INPQ_Ranort i
Allegation Testimony Cross. Reference l
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