ML20043F707
| ML20043F707 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/18/1990 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20043F709 | List: |
| References | |
| NYN-90111, NUDOCS 9006180031 | |
| Download: ML20043F707 (240) | |
Text
{{#Wiki_filter:_ _ _ _ _ _ - . . . . . - - - .. a e New Hampshire w c. e. Senior Vice President and: Chiel Operating Officer t ? NYN-90111 May 18, 1990 United States Nuclear Regulatory Commission " P. # Washington, DC 20555
- Attention: Document Control Desk 4 .4 _
References:
(a) Facility Operating License No. NPF-86 Docket No. 50-443 (b) NYN-90073, dated March 15, 1990, " Response to Late-Filed Allegations ' T.C. Feigenbaum to USNRC (c) Union of Concerned Scientists Letter dated April 10, 1990 - R.D. Pollard to Representative Peter H. Kostmayer (d) USNRC Letter dated 4)$rdi 27,1990 - V. Nerses to E.A. Brown
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Subject:
Request for Additional Inforination on INPO Evaluations of Seabrook Station Otntlemen: The NRC Staff requested additional information concerning the status of New Hampshire Yankee (NHY) actions taken in response to INPO evaluation reports of Seabrook Station during the period 1983 through 1989 (Reference (d)).. Enclosures 1,.2, and 3 identified below, provide the NHY response for
'the- reports issued in 1983, 1984 and 1987. NHY responses for-the reports
-issued in 1988 and 1989 were previously transmitted to the NRC on March 15, 1990,-(Reference (b)). !As indicated in our March 15, 1990 letter all of
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these' reports were reviewed prior to license issuance. The INPO reports are provided as Enclosure 4. Enclosure 1 Status Update of NHY Response to INPO Report on the October 1983 Construction' Project Evaluation for Seabrook Station Enclosure 2 Status Update of NHY Response to INPO Report on the December'1984 Construction Project Evaluation for Seabrook Station Enclosure 3 Status Update of Response to INPO Report on the November 1987 Pre-Operational Review and Assistance Visit to Seabrook Station E 9006180031 900518 " b {DR ADOCK 05000443 PDC fh 0 P g()I
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New Hampshire Yonkee Division of Public Service Company of New Hampshire g P.O. Box 300 e Seabrook, NH 03874
- Telephone (603) 474 9521
q United States Nuclear Regulatory Commission .May 18, 1990 Attention: Document Control Desk Page two The INPO evaluations and assistance visits are intended to assist utilities that own nuclear plants in ongoing efforts to promote excellence in plant operations. INPO evaluation teams make findings and issue recommendations that are based on performance standards of excellence rather than regulatory requirements. Areas of recommended improvement are not necessarily, or even typically,-indicative of unsatisfactory performance. It is INPO's policy that if, in the course of an evaluation, a condition that is judged to be reportable in accordance with The Code of Federal Regulations is discovered, INPO encourages the utility to report the condition. If necessary, INPO will initiate action to report the item in accordance with federal regulations. There were no items required to be reported to the NRC as a result of the findings and recommendations in these INPO reports. Mr. Pollard's claims (Reference (c)) of long-standing safety deficiencies and violations of NRC regulations are simply unfounded. Examples of Mr. Pollard's misinterpretation or misunderstanding of the INPO reports include the characterization of findings and recommendations concerning INPO Significant Operating Experience Reports, as well as the findings regarding station design requirements. Mr. Pollard implies that recommendations pending in 1983 were still not resolved in 1989 and that significant safety deficiencies have remained uncorrected for years. In fact, of the more than 500 action items that NHY has identified from the review of
-Significant Operating Experience Reports, approximately ninety percent have been completed. The balance of the items have been reviewed, with follow-up actions identified and scheduled for implementation when they are appropriate for Seabrook-Station. The schedules and prioritics of the renmining items are periodically reviewed by management. None of +he cutstanding actions involve issues which as..ersely affect safe plant operation or involve violations of NRC raquirements.
With respect to station design requirements, Mr. Pollard implies, for example, that findings involving single-failure criteria, failure effects analysis, clearances between major components for earthquake protection, and other design requirements remained uncorrected. Mr. Pollard is simply incorrect. As discussed in the Enclosures, the technical issues addressed in the INPO reports have been appropriately resolved. I would like to again emphasize the fact that each of the INPO findings and recommendations has been carefully reviewed and none of the INP0 findings and recommendations involves any existing safety issues or concerns that would prevent the safe, conservative startup and operation of Seabrook Station. Furthermore, none of the INPO findings and recommendations involve issues which are violations of NRC regulations. Appropriate actions have been taken in response to all of the INPO recommendations. For those issues which have been reviewed, but for which implementation of the follow-up actions has not yet been , appropriate, management continues to periodically review the status, schedule and existing priorities. New Hampshire Yankee considers that these matters have been appropriately addressed.
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jf ' United States Nuclear Regulatory Commission May 18, 1990 i Attention: Document Control Desk Page three
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[.. Should you~ require additional information regarding this matter, please contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474 9521, 3 1 ' extension 3772. T Very truly yours.
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.f& b T. C. Feigenbaum ,
I l Enclosures cci Mr. Thomas T. Martin Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Noel Dudley NRC. Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 Mr.' Victor Nerses Sr. Project Manager Project Directorate I-3 Division of Reactor Projects U. S. Nuclear Regulatory Commission f Washington, DC 20555 j { f
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3 Status Uodate of NHY Resoonses to'INPO Findinns '[' 1983 Construction Proiect- .j . Evaluation of Seabrook Station ' i {
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n. ISSUE: Improvement needed in several aspects of management direction and control (timely problem resolution, defining and promulgating responsibilities, and accountability). < INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (OA.1-1), page 5 NHY RESPONSE STATUS: The response to this finding stated that PSNH was conducting an assessment of every aspect of the Seabrook project. As a result of these reviews, a new integrated project management team was established and a separate organizational entity, the New Hampshire Yankee Division of PSNH, was established in 1984 to manage the construction, startup, and subsequent operation of the Seabrook project. This revised < organization structure was established to enhance the ability of senior and upper level management to provide effective project direction, control and accounta-bility. NHY's sole mission was at that time, and remains, the successful completion and operation-of E Seabrook Station. The sole responsibility of NHY's management team is the safe operation of Seabrook- ; Station. NHY has reviewed INPO Finding OA.1-1 together with the corrective action taken. We have determined that the corrective action taken was effective and that no issues exist which would adversely affect safe plant operation. !~ l~ ,u 1 l'
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-ISSUES ~ Senior management effectiveness in resolving problems identified by the
~l Quality Assurance (QA) program.
INPO
REFERENCE:
November 1983/ Construction Project Evaluntion Finding (OA.2-1), I page 6. l l NHY RESPONSE STATUS: Beginning in December 1983, the Yankee Atomic Electric ; Company (YAEC) Construction Quality Assurance Manager participated in the weekly Project Management meetings. j This participation ensured that quality assurance ] problems and the required corrective actions were , accurately communicated to senior site managers. When escalated management actions were required, they were , formalized through Immediate Action Requests. A trending l program, to identify recurring deficiencies, became fully functional by August 1984. The trending results were > summarized and reported to management. A Management Action Report Program was implemented by August 1984. This program identified middle management accountability for resolving identified problems and proviced for proper monitoring of corrective actions by senior site managers. NHY has reviewed INPO Finding OA.2-1 together with the corrective action taken. We have determined that the corrective action taken was effective and no issues exist which would adversely affect safe plant operation. l. l l l l . \ t
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. ISSUE: Increased effort is needed to ensure supervisors in the areas of instrum'ent and control (I&C) and measuring and test equipment (M&TE) understand and assume their responsibilities.
INPO REFERENCE - November 1983/ Construction Project Evaluation, Finding (OA.3-1), page 7
-NHY RESPONSE STATUS: To provide the necessary information, a program equivalent to the Supervisor Responsibility Development !
Program was put in place. This program required that, 1 prior to commencing work, each individual filling a supervisory position be cognizant of the procedures for l which they were responsible and receive training in I their respective discif . 9. A matrix or list was established for each pc . ton giving the procedures, , classes, and reading required to be completed in order I to meet the requiremento of the program. These requirements clearly delineated the responsibilities of the respective positions and were comprehensive in scope. The IEC contractor (Johnson Controls) was removed from the project in early 1984 by the new NHY management team discussed in the response to Finding OA.1-1, page 5. A system for evaluating the effectiveness of all training was implemented in June 1984. This system identified weaknesses that existed in the area of supervisor training and reported those weaknesses to the management personnel -responsible for correcting them. I
; NHY has reviewed INPO Finding OA.3-1 together with the corrective action taken. We have determined that no issues exist which would. adversely affect safe plant operation.
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4 it y ISSUE: A'more effective system is needed to ensure all dynamic fluid
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transients are considered and translated to the final design documents. INPO
REFERENCE:
' November 1983/ Construction Project Evaluation, Finding (DC.1-1), page 9 NHY RESPONSE STATUS: The following actions were taken in response to this findings
- a. Those transients that were expected to happen with a reasonable frequency and have potential for-significant effects were considered.
To improve the program that ensured dynamic fluid transients were considered in the final piping design, a generic list of events for fluid transient considerations was developed. Analyses were then conducted to provide documented t verification for each system to establish which postulated transient was applicable, not applicable, or' covered by a more severe bounding condition. Hydraulic analyses were then conducted on those systems that are expected to. undergo a hydraulic transient for postulated events,
- b. Engineering programs were established to ensure' !
that a hydraulic and thermal transient analysis was : performed on each applicable system to verify the piping and support system integrity. Subsequently, during the closcout phase of the project, the Task Team Program formed the Hydraulic Transient. Task Team to re-verify that all dynamic loadings were considered in the final piping system design (refer to Finding DC.2-1, pages 14 and 15). It was concluded that all transient loadings were formalized and incorporated into the Seabrook Comprehensive Piping and Pipe Support Closecut Program (PAPSCOTT) which combined the piping as- ; built effort, stress analysis reconciliation and l r pipe support verification programs (refer to L Finding DC-1.2, page 10). All activities associated with system loading were finalized and verified. PAPSCOTT verified that the design, installation and subsequent testing met the ASME code requirements prior to achieving the ASME stamp certification. / NHY has reviewed INPO Finding DC.1-1 together with the l corrective action taken. We have determined that no issues' exist which would adversely affect safe plant operation.
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(~ ISSUE: The requirements for single failure criterion need to be considered when establishing the bounding' design conditions for the ASME Section III pipe streer analysis. Some fluid temperature excursions resulting fror single failures exceed pipe stress analysis values. i INPO
REFERENCE:
No'< ember 1983/ Construction Project Evaluation, Finding ! (*JC .1- 2 ) , page 10 I NHY RESPONSE STATUS: A task force, the Pipe and Pipe Support Close Out Task j Team (PAPSCOTT), was established to review the l integrated ASME' piping and pipe support design ! requirements including the analysis of hydraulic ! transient and fluid temperature excursions following single failure. All work was completed. The PAPSCOTT was a comprehensive program which verified that the actual installed piping system configurations l reflected the analytical design packages. This -; verification program, which occurred after the piping , systems were completed, combined the.following attributes: e The as-built verification of the piping ; configurations by physical plant walkdowns of the l piping and support systems. This as-building effort was performed by engineering and design personnel and was in addition to the normal QC in- ! process piping / support inspections. L e The piping stress reconciliation effort which i required either the reanalysis or reconciliation of the stress analysis packages (including the ; equipment nozzle loadings, the hydraulic transient loadings, the thermal expansion operating loads and { the piping seismic loadings). ! e The pipe support reconciliation effort which reviewed and reconciled the loadings on the piping supports / restraint designs. ; e The ASME N-5 stamping program which required the piping systems to be designed, fabricated. l- installed and tested in accordance with the applicable code requirements prior placing the ASME code stamp.
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g _ _ _ _ - _ _ --- l b . l 1 l Requirements for Single Failure Criteria, Page 2 Finding (DC.1-2) (continued) t The PAPSCOTT effort analyzed piping systems as they I were completed and ended in May, 1986 when the final ASME stamping program was finalized. This program initially termed the "As Engineered" program received an "INPO Good Practice' in the 1984 review (refer to December 1984 Construction Project Evaluation Finding (DC.4-1), page 9). NHY has reviewed INPO Finding DC.1-2 together with the l corrective action taken. We have determined that no-issues exist which would adversely affect safe plant operation. l l
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ISSUE: Some additional thermal operating modes need to be considered-in the I ASME III Pipe Stress Analysit. ] l l INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding ; (DC.1-3), page 11 s
.NHY RESPONSE STATUS: The Pipe and Pipe Support Close Out Task ! nam (PAPSCOTT) addressed thermal operating modes that needed to be considered in the ASME III Pipe Stress- l Analysis. All work was completed. _
For further discussion on PAPSCOTT see Finding DC.1-2,- r page 10. NHY has reviewed INPO Finding DC.1-3 together with the corrective action taken. We have determined that no 1 issues exist which would adversely affect safe plant ; operation. ' i l~ ( i l-L I i
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., i ISSUE: Some design documents do not support required considerations for l failure effects analysis.
INPO
REFERENCE:
November 1983/ Construction Project Evaluation, Finding, (DC.1-4), page 12
-NHY RESPONSE STATUS:- This issue involved instruments and instrument lines that are part of the containment isolation boundary. A complete re-review of,the containment penetration arrangements was conducted to confirm that all instruments and instrument lines that-are part of the containment boundary, under the appropriate plant condition, meet the containment isolation requirements of 10 CPR 50. Appendix A and Regulatory Guide 1.11.
NHY has reviewed INPO Finding DC.1-4 together with the-corrective actions taken. We have determined that-no. issues exist which would adversely affect safe plant operation. 9 l 1 L: l l.. o l l 1 l l
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ISSUE: Utilization of design, construction and operating experience. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (DC.1-5), page 12. 1 i NHY RESPONSE STATUS: A program was implemented by August 1984, to formally inform and educate supervisory personnel in Engineering, Construction, Startup, QA, and Production from YAEC, j PSNH, and UEEC on the purpose and use of NUCLEAR NETWORK i (formerly NOTEPAD) system reports, SERs and SOERs. A training seminar, conducted in March 1984, presented an ' overview of the INPO 'SEE-IN' Program to management representatives of the above-mentioned organizations. ; The Document Control Center (DCC) expanded the on-site ' routing of Nuclear Network material to include the I Startup and Construction organizations. Each ; organization conducted its own internal program for evaluating and documenting actions taken in response _to SER, SOER and Nuclear Network Documents. Currently, NHY has implemented a program to review industry and in-house operating experience. The scope of this program includes INPO Nuclear Network, SOERs, SERs, l NRC Information Notices, vendor correspondence and other , pertinent industry information. Industry information is. l reviewed for applicability, recommendations are developed j and assigned for action.- The resulting commitments are ' evaluated for adequacy and tracked to closure. 4 Significant in-house operating experience is reported to the industry in accordance with NHY procedures, i NHY has reviewed INPO Finding DC.1-5 together with the ' corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. ; 1 i
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.y-ISSUE: Control of interfaces among the various design organizations.
INPO REFKEENCE: November 1983/ Construction Project Evaluation Finding (DC.2-1), pages 14, 15. , NHY RESPONSE STATUS: UE&C reviewed the procedures governing discipline interaction as well as the System Engineering Completion Program for potential changes aimed at implementing further improvements. Additional training sessions for key engineering and design personnel were conducted by August 1984, to strengthen the existing discipline interaction. requirements. A Multi-Discipline, Multi-Organizational Task Team Program was established during the completion phase of the project l to ensure that both internal and external interfaces were l identified. The task teams consioted of representatives ' from UE&C, YNSD, the Independent Review Team and external contract personnel, as required. The Task Team Program reviewed numerous technical issues to ensure adequate interface control among the various design organizations. This program reviewed approximately twenty (20) key technical issues including issues such as Fire Protection, Environmental Qualification, HVAC Design Electrical Separation, Structural Beam Verification, Seismic Qualification Hydraulic Transient and interfaces with the NSSS vendor. All task teams were closed out in May 1986, after ensuring that the technical issues were reviewed and resolved appropriately. NHY has reviewed INPO Finding DC.2-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. l l i
p E d ISSUE: Preparation, verification, updating and issuance of electrical design ; documents. 1 INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (DC.3-1), pages 15, 16. NHY RESPONSE STATUS: United Engineers and Constructors (UE&C) reviewed the program and guidance governing electrical drawing and calculation preparation and found them to be adequate. UE&C re-emphasized the need for thoroughness in the i implementation of these controls specifically, for drawing and cniculation preparation, and checking through additional training of engineering and design personnel. This action was completed by August 1984. By August 1984, UE&C completed the following specific l corrective actions with respect to this issues
- a. Issued formal loading calculations for certain f installed 480V unit substations and 125V DC systems.
- b. Applied the System Engineering Completion Program to h ensure that specifications reflected the delivered i equipment configuration.
1 As part of the System Completion process, a comprehensive j review was performed by each discipline'to ensure adequate '
. verification of design documents. This detailed inter-discipline review utilized a multi-discipline checklist of key. attributes to ensure closecut of engineering activities and included items such as P&ID, Logic Diagrams, Electronic j Schenatics, Line and Valve Lists Setpoint Data Lists, j specificatlons and associated Qualification documentation. l NHY has reviewed INPO Finding DC.3-1 together with the !
corrective action taken. We have determined that no i issues exist which would adversely affect safe plant operation, i l
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.s ISSUE: FSAR Administrative _ Control.
INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (DC.5-1), pages 16, 17. NHY RESPONSE STAYUS: At the time this INPO finding was documented, some of the minor, identified FSAR discrepancies had been addressed in pending FSAR Amendments. To address these inconsistencies and provide, where necessary, technical justification of exceptions taken, UE&C reviewed the applicable administrative procedures and implemented appropriate improvements. A thorough review was performed of FSAR, Section 6.2.4, and several other sections, to determined if any other significant inconsistencies or diecrepancies existed. This review was completed by August 1984. In 1985 a consistency review of the Seabrook Station FSAR was performed by New Hampshire Yankee (NHY), Yankee Nuclear Sr.tvices Division (YNSD), United Engineers and Construct:rs (UE&C), and Westinghouse (W). Included in the consit ency review was an ECA/DCN/NCR review performed by UE&c. The consistency review indicated that the involved organizations were very effective in following ! procedures to update the FSAR for design changes. There j were no instances where a change required a physical plant ' modification or where unreviewed safety issues appeared. NHY has continued to update and issue FSAR amendments i following the issuance of the operating licenses for Seabrook Station. In one of these amendments, NHY replaced the UE&C design drawings for the P& ids and electrical one-line drawings with NHY documents.- An integral step in creating the NHY design drawings was a systems walkdown to assure that the drawings reflected the as-built condition of the facility. When the drawings were incorporated into the FSAR, a review was performed to assure the consistency of the text with the drawings. NHY has initiated its program to prepare and issue the ' initial update of the FSAR in accordance with the requirements of 10CFR50.71(e). This program shall include the necessary administrative controls and direction to assure.that minor discrepancies, such as , those referred to in the finding, are identified and 1 resolved, however unlikely that such a condition may exist at this time. In conclusion, NHY has reviewed INPO Finding DC.5-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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, ISSUE: Indication of equipment safety classification on design drawings.
INPO
REFERENCE:
November 1983/ Construction Prt. ject Evaluation Finding (DC.5-2), page 17. NNY RESPONSE STATUS: The ASME Boiler and Pressure Code Section III boundaries were indicated on piping and instrumentation drawings (P& IDS), and the drawings were certified for Section III, l NCA2131 Code Class boundaries and as such did not require I additional. stamping. This was an accepted and documented -l prhetice, as indicated in Project Procedure QA-3, Section IV.E.3.c. Inconsistencies on the electrical drawings 1 were corrected and other drawings were checked. The ! drawings noted were considered isolated cases and as such did not have generic interdisciplinary implications. UE&C reviewed the applicable procedures for the classifi-cation marking of P&ID drawings to ensure consistency . between procedures and provided appropriate clarification. Action was completed by August 1984. l l NHY has reviewed INPC Finding DC.5-2 together with the i corrective action taken. We have determined that no L! issues exist which would adversely affect safe plant 4 operation. i l l l. l
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y, O L ISSUE: Engineering Change Authorization (ECA) Program. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (CC.1-1), pages 18, 19. NKY RESPONSE STATUS: In response to the overall recommendation to upgrade the ECA Program and the detailed recommendations, both YAEC/PSNH and UE&C conducted comprehensive reviews of Administrative Procedure (AP-15), which defined the r Engineering Change Authorization (ECA) Program. In November 1983, a revision to AP-15 was issued based upon the results of the internal reviews. The complexities of the previous revision were minimized while maintaining technical and administrative controls. PSNH committed to continue to review the ECA Program in an effort to streamline and improve its operation. A review of this program was included in the evaluation performed , by senior management, as described in response to Finding OA.1-1, page 5. In response to specific INPO recommendations, the ECA Program was revised as described belows
- a. Site engineering approval authority for design changes ~1 was expanded beyond specifically defined areas (e.g.
conduit supports, NNS-1 piping). The process of , expanding this authority to cover other areas began _in February 1984. L b. The AP-15 reviews evaluated the effectiveness of the design change program.
, Specific training was provided following-the issuance of the November 1983, revision of AP-15.
- c. AP-15 was revised to permit the site engineering group to initiate ECAs to facilitate rapid correction of miner design problems and ir.terferences. These ECAs were issued by the site engineering group to construction and were concurrently reviewed by the-off-site engineering group. If an ECA wae disapproved by the off-site engineering group; i
construction accomplished to-date was appropriately modified to conform to the requirements established by 1, the off-site engineering group. Less than five percent of ECAs issued by site engineering required l l such modification. l l d. A trending program was initiated for ECAs. I'
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[ i Finding;(CC.1-1).(continued)- p[ > 1 . ; r f.0 e. ..The ECA ~ review cycle was evaluated to attempt: !
' simplification by reducing the number of.: sign-offs. '
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'f.- Unnecessary. steps in problem resolution were removed from AP-15. ;p -. I is- g. Training was conducted covering the latest revision of' AP-15. ;
m NHY has reviewed INPC Finding CC.1-1 together with the E ' corrective action taken. We.have determined that no or . issues exist which would adversely' affect: safe plant. # e A, l operation. .; t t h, a i i ,
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i-I 3- ISSUE: _Some installed equipment is not being maintained in accordance with ( vendor recommendations and project preventive maintenance. INPO
REFERENCE:
November 1983/ Construction Project Evaluation, Finding (CC.3-1), page 19
-NHY RESPONSE STATUS: Procedural changes were made to the environmental ;
surveillance program to provide positive control of the construction environment. In addition, preventive maintenance personnel and Quality Assurance engineers were instructed to report immediately in writing any deviations to maintenance requirements. Organizational changes were also made to improve the construction Preventative Maintenance program control and provide better program support with personnel resources and technical guidance. In addition, the Startup Test Department (STD) took
' sole responsibility for the preventivo maintenance ;
program for turned over equipment. ' NHY has reviewed INPO Finding CC.3-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. 1: h l
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'[s c . i ISSUE: Storage, Identification-and Oc:.crol of Sa" 'y-Related Structural Materials.
L INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (CC.3-2), e pages 20, 21. NHY RESPONSE STATUS: In an effort to upgrade the site process for identity 1r.s. Installing and verifying safety-related fasteners, the following action was completed by August 1984:
- a. Nuts and washers used on high-strength bolt's to assemble hanger components were evaluated to be technically acceptable. The necessary documentation for the verification of quality requirements of p subject fasteners in safety-related systems was evaluated,
- b. All personnel involved in the control, installation, and inspection of safety-related bolting were '
retrained in the requirements and method of control and identification of bolting material,
- c. Fastener control systems were re-evaluated to determine their adequacy and appropriate measures to improve physical identification were implemented.
In addition, as a result of NRC Bulletin 87-02 (Fastener Testing to Determine Conformance with Applicable Material-Specifications) dated November 6, 1987, NHY provided the NRC with results of chemical and mechanical tests conducted on a sample of fasteners from Seabrook Station inventory. The test results determined that none of the sample set had any significant: deviations.from specification. Tius NHY response also described the receipt inspection requirements and the-storage and issuance controls at Seabrook. NHY has reviewed INPO Finding CC.3-2 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant cperation.
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L: ISSUE: Completeness, Legibility and Accuracy of Installation Documents. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (CC.4-1), pagec 21, 22. NUY RESPONSE STATUS: The drawing control program identified engineering, management, and supervisory personnel who were required to review construction drawings to ensure.their completeness and accuracy. The program included training of personnel preparing and checking documents, with emphasis on high quality work standards to minindze document- revisions. Management emphasized these quality requirements to supervisory personnel. A Design Change Trending-Program , was implemented to track the reasons for drawing changes and to determine their root causes. When causes were identified, corrective action plans were implemented.
-A Drawing Enhancement Program was implemented to redraw aging drawings and to ensure good quality reproductions.
To provide improvements in implementing the program, the following' actions were taken:
- a. Supervisors and field engineers maintained a status schedule to ensure that design information was available prior to commencing work. Field engineers were required to review design information, including drawings, to ensure;that they were complete.
Craftsmen'were instructed to ask for guidance if the design information was inadequate or unclear.
- b. Inspectors were rotated between in-process.and final inspections.
- c. Personnel performing as-built verifications worked directly with the Quality Control (QC) inspectors.
NHY has reviewed INPO Finding CC.4-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant-operation. I l-
f ISSUE: Control of-Mechanical Construction Work. INPO
REFERENCE:
November.1983/ Construction Project Evaluation Finding (CC.4-2), pages 22. 23. I NHY RESPONSE STATUS: In order to upgrade the control of hanger installations, a l team approach to in-process inspection was implemented in December 1983. For each pipe support crew foreman, one QC ; inspector and one field engineer were assigned. Application of additional manpower resources was completed in January 1984. Additionally, the safety-related piping systems were re- ~ examined to ensure that the as-built plant configuration reflected the analytical design. (Refer to PAPSCOTT effort in response to Finding DC.1-2. page 10.) In addition, inspectors were rotated between in-process and final inspections, and personnel performing as-built inspections worked directly with the QC inspectors. Non-
-conformance reports (NCRs) were trended to further upgrade the installations prior to the as-built inspections.
A Posted Areas Log showing the rejection rate of in- i process inspections was instituted. The log increased the importance and awareness of doing the work right the first time. NHY has reviewed INPO Finding CC 4-2 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. l
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- ISSUE: Organization and Implementation of the ASME Code Stamping Program.
INPO
REFERENCE:
November.1983/ Construction Project Evaluation Finding (CC.4-4), pages 23, 24. l 1 Following the INPO evaluation, the ASME Code Stamping NHY RESPONSE STATUS: Program was changed to reflect UE&C/QA's responsibility for the leadership in the Stamping Program. UE&C provided l the vendor-supplied Document Index for the N-5 Data ) Reports. The NA certificate holders for piping and I&C l were responsible for developing the supplementing N-5 Data Reports for their scope of work, including the supporting
-*' installation data. The result was one final N-5 Data Report for each class of each piping system.
Efforts'were made to reduce the complexity of the process control documents and streamline the documentation 1 process. Changes were made to the UE&C as-built program, the UE&C Site QA Program, and the Piping Contractor's Nuclear-QA Manual. These changes controlled as-built I final inspection and the development of the N-5 Data Reports. Training was conducted and a schedule was developed for code stamping activities. These actions were completed by-August 1984. NHY has reviewed INPO Finding CC.4-4 together_with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant , operation. ' s
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ISSUE: Quality Workmanship. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (CC.5-1), pages 24, 25. l NHY RESPONSE STATUS: Management emphasiaed to INPO that PSNH would not compromise quality in the construction of Seabrook Station, a Major contractors instituted a Posted Areas Log, or equivalent, showing in-process rejection rates, in an effort to increase the awareness of the importance of achieving quality the first time. The objective of this ! Log was to make first-line supervision cognizant of and accountable for work being performed by craft personnel. Area superintendents utilized the Log to decide whether personnel retraining or replacement was necessary. A trending program of NCRs and Posted Areas Log rejection information was initiated. The trending program report was evaluated by senior construction management. These actions were implemented in January 1984. In addition to the above, the adequacy of the in-process and final installations and fabrication activities was confirmed by a multi-level confirmatory quality assurance program consisting of quality control inspection, quality assurance surveillance and quality assurance audits as L defined in Chapter 17.1 of the Seabrook Station FSAR. NHY has reviewed-INPO Finding CC.5-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. L 1
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. ISSUE: Control of Measuring and Test Equipment.
'1 INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (CC.7-1), pages 25, 26. l NHY RESPONSE STATUS: Two technicians were certified.and added to the staff. J The training and certification program was enhanced and included formal documentation of training, including the results of general, specific, and practical examinations. UE&C Corporate QA personnel re-evaluated the results of calibration facility. surveys to ensure that essential attributes of the vendor program regarding measuring and test equipment (M&TE) were addresced adequately. . At the timn of the evaluation, a program was in effect for review of> equipment calibration intervals for each type
.of equipment against the calibration history to ensure that low probabilities of equipment deviations existed.
UE&C evaluated the effectiveness of all contractor M&TE programs and initiated appropriate corrective actions. The Owner's Quality Assurance Group provided overview of contractor M&TE programs and the above corrective actions. This action was completed by August 1984. . NHY has reviewed INPO Finding CC.7 1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant ,- operation. 1
l
!. ,a L e; ISSUE ~ Adherence to industrial safety practices during testing.
E INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (PS.1-1), page 27. NHY RESPONSE STATUS: At the time of this INPO Evaluation, startup activities were beginning but construction activity was not yet j completed. This finding arose primarily because of the l need to improve the interface between Construction and Startup with raspect to industrial safety. Specifically, there was, at the time, a need to ensure that Startup personnel were trained in industrial safety and that Construction and Startup personnel were aware of each other's activities in the same area or. system so that unsafe conditions did not arise. Therefore, in December 1983, all certified test personnel were retrained by the site Safety Department. After December 1983, safety retraining was conducted as part of the test personnel recertification process. This training was conducted by site-qualified training instructors. In order to improve the Startup Test Department's (STD) communication with the Site Safety Group, a representative of the Site Safety Group attended-the STD's Plan-of-the-Day Meeting. At these meetings, the Site Safety Group representative could learn the specifics of planned STD activities. This representative would then ensure that planned Construction and STD activities would not create safety hazards. Where safety concerns arose, the site safety representative would provide service and/or recommendations to alleviate the concern. NHY has reviewed INPO Finding PS.1-1 together with the corrective action taken. We have determined that no I issues exist which would adversely affect safe plant operation, i
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-ISSUE: Improvement is needed in project planning and scheduling.
INPO
REFERENCE:
November 1983/ Construction Project Evaluation, Finding
. (PS.2 1), page 27 NHY RESPONSE-STATUS: A management review of project' planning, scheduling, and the mechanism for measuring construction progress against schedule took place in response to this l finding. The project master schedule was updated as necessary. New, more detailed schedules and a rework -l reporting procedure, allowing timely' incorporation of rework items into the detailed schedule and cost system, were also introduced. . NHY has reviewed INPO Finding PS.2-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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n:r 3 e 0 ISSUE: Identification of the current status of documents in records management systems. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (PS.6 1), pages 29, 30. NNY EESPONSE STATUS: The training program was expanded for design and administrative personnel having responsibilities with the records management program. The expanded training included the procedures for inputting current data and the requirements for naintaining an updated and accurate revision status of the Records Management System. This training was initiated in December 1983, and became an ongoing program. In addition, procedures were restruc-tured to simplify the inputting of data to the Drawing Task System and to reduce the ' turn-around* time. A high level of audit activity was undertaken during the last two quarters of 1983 to identify Records Management System deficiencies. Changes to Project Procedure AP-15 strengthened and emphasized the requirements for overall records management accuracy. Regularly-scheduled audits of the system were undertaken on a continuing basis, the frequency of which was predicated upon audit findings. These actions were completed by August 1984. NHY Engineering performed record and database audits as part of the Engineering Records turnover to NHY, These audits included calculations, specifications, drawings, vendor information and other design documents. Periodic audits continue as part of the Engineering Records Center activities. NHY has reviewed INPO Finding PS.6 1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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ISSUE: Use of the latest available revision of drawings or procedures in work. l 1 1 1 e INPO EMD *ENCE: November 1983/ Construction Project Evaluation Finding (PS.6 2), I page 30. NNY RESPONSE STATUS: Project management evaluated the controls for construction ! [ document distribution and initiated appropriate corrective action by August 1984. The need for fast and effective l [ distribution of approved construction documents was
- emphasised. Project management committed to continually monitor this area'and take appropriate action.
L Since 1983, the PSNH Quality Assurance Program as well as reviews by NRC and INPO periodically evaluated the J control measures being applied to drawings and procedures. : In 1984 a records review group was formed to review all I formal quality assurance records prior to their submittal to the Document Control Center. The completeness and accuracy of the as-installed equipment was verified by system walkdown performed at the time of systems turnover from Construction to Operations. [ NHY has reviewed INPO Finding PS.6 2 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant ,. operation. , f. i t i
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L 1 o j- ISSUE: Management needs to provide increased support of training programs. INPO EEFERENCE: November 1983/ Construction Project Evaluation. Finding l (TN.1-1), page 31 i NNY EESPONSE STATUS The responsibility for the site training program was 'l~ placed under Senior Project Management. A training procedure was developed which included a needs analysis 4 and provisions for ensuring instructional quality and ' training effectiveness. During this period. Senior
- Project Management approved a training program for ,
L managers and supervisors, which included Kepner-Tregoe ; Problem Solving and Decision Making, Managing Management Time. Team Building, and Making Oral Presentations. This was provided to personnel with 7 the title of Department Supervisor or above. , i The site training program discussed briefly above refers to the Construction Site Training Program. Since construction was completed, many additional improvements have been made. We now have all training ; combined under one Training Manager, reporting to the ; Executive Director of Nuclear Production. Operator training programs, including non-licensed operators, have been accredited through INP0 by the National Nuclear Accreditation Board. Mechanical, electrical. *
)
and instrumentation and control training programs are in the accreditation process a visiting team has performed its evaluation and preparation is under way , to submit the programs to the Board later this summer. In August, the final four programs will undergo review by the visiting team. with a presentation to the , Nuclear Accreditation Board in early 1991. . All programs now use the Training System Development Process. Thas begins with needs analysis, including job analysis and task _ analysis, and proceeds with program design, development and implementation. Evaluation occurs at all phases of the process, t including follow-up evaluation after the programs have been presented. All programs use Curriculum Advisory-Committees, consisting of training personnel and - members of the user groups, with plant management . involved heavily in the process. Plant management has developed a Qualification Program to ensure that personnel are qualified to perform the tasks to which they are assigned. This process drives the training program, that is, the need for personnel qualified in specific duty areas determines what training is developed and presented. NHY has reviewed INPO Finding TN.1 1 together with the corrective action taken. We have determined that no issues exist which would adversely affect sare plant operation.
i
- I I
- 1 ISSUE: The latest issues of technical documents are not always used as the '
basis for performing quality surveillances. j i INPO
REFERENCE:
November 1983/ Construction Project Evaluation. Finding (QP.2-1), page 32 l NHY RESPONSE STATUS: By February 1984, changes were nede to the training l program for, and procedures used by, individuale conducting surveillances to ensure that surveillance checklists were written against the latest revision of the applicable technical document. NHY has reviewed INPO Finding QP.2-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. l l l
s' New Hampshire Yankee May 1$, 1990 ; I
-ISSUE: Control of Non-Conforming Equipment.
INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (QP.2 2), i page 32. 1 NNY RESPONSE STATUS: The following actions were taken by August 1987 to improve the timeliness of disposition of Non-Conformance Reports . (NCRs):
- a. The site NCR program was extensively revised to ;
streamline document flow by eliminating unnecessary in-line review and approval participants.
- b. The dispositioning and timely resolution of NCRs ,
consistent with project schedule goals was expedited. ' Project directives were' issued to Engineering and construction organizations to disposition and correct , non-conformances within specified time frames. NHY has reviewed INPO Finding QP.2 2 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant -> operation. : f i u I l \ t b . l :
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ISSUE: Potential damage to or misuse of ASME materials in storage. .le INPO RJU13UDDCE: November 1983/ Construction Project Evaluation. Finding f (QP.5-1), page 33 t f i NNY RESPONSE STATUS: In November 1983, management personnel of all project f organizations were redirected relative to each organization's responsibilities in the areas of , housekeeping, material control, and storage. In ; addition to the controls applied by the contractor's QA/QC programs, starting January 1984, each contractor i assigned a management representative to continuously ' evaluate the effectiveness of the program and through management actions ensure timely closeout of identified i conditions. i The effectiveness.of this program was evaluated and i maintained through the YAEC QC surveillance and audit j program. NHY has reviewed INPO Finding QP.5-1 together with.the , corrective action taken. We have det. ermined that no issues exist which would adversely affect safe plant' i operation.- , i r i 1 b l. L l le
ISSUE: The protection and maintenance of some equipment turned over to the Startup Test Department (STD) from Construction needed more attention. INPO
REFERENCE:
November 1983/ Construction Project Evaluation Finding (TC.1-1), page 35 NHY RESPONSE STAYUS: The STD immediately took measures to complete the ; transition of responsibility from Construction to STD for turned over equipment and STD nanagement increased their walkdowns and inspections of equipment and areas : under STD jurisdiction. NHY has reviewed INPO Finding TC.1-1 together with the
- corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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*- ISSUE: The planning and scheduling of day-to-day test activities needs '
improvement, r i INPO
REFERENCE:
November 1983/ Construction Project Evaluation. Finding j' (70.3-1). page 35 i NRY RESPONSE ST&YUS: The use of commitment dates and priorities was incorporated into the planning and scheduling of STD - activities. In addition,_the Pro,4ect Completion $ystem ! was expanded to include the prioritiaation of post- ; turnover items needed to support STD activities, j t NHY has reviewed INPO Finding T0.3 1 together with the r corrective action taken. We have determined that no issues exist which would adversely affect safe plant l operation. J
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"' ISSUE: Closer attention to accuracy and completeness in making field changes ,
to some procedures and instructions is needed. INP0
REFERENCE:
November 1983/ Construction Project Evaluation Finding (TC.4-3), page 36 NHY RESPONSE STATUS: The deficiencies noted were reviewed with the test engineers invcived and general training of all test engineers was conducted to re-emphasize the requirements. NHY has reviewed INPO Finding TC.4-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. l l
7T , i j' O 4 ISSUE: Increased' effort is needed to ensure adherence to tagging programs on systems turned over to Startup Test Department. INPO
REFERENCE:
November 1983/ Construction Project Evaluation.-Finding (TC.4-3), page 37 NHY RESPONSE STATUS: Project Notices were distributed to all contractors re-
- i. . emphasiaing the requirements of safety tagging. The visibility of the safety and jurisdictional. tagging programs were increased through the use of site displays and at craft 'gangbox' training sessions. The safety tagging instruction was also revised to
-incorporate certain aspects of INPO Good Practices.
NHY has reviewed INPO Finding TC.4-3 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. ,1 i i i t -- l
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1 1 d c, 1 ISSUE: Significant improvement is needed in managing the Systems Turnover Program. l INPO
REFERENCE:
' November 1983/ Construction Project Evaluation Finding l (TC.4-2), page 36 l NHY RESPONSE STAYUS: The Systems Turnover Program received considerable management attention as a result of this finding and was upgraded. This resulted in more timely and accurate identification of items that needed to be closed prior to turnover and a clearer definition of management responsibility and accountability.
NHY has reviewed INPO Finding 70.4-2 together with the corrective action taken. We have determined that no ; issues exist which would adversely affect safe plant operation.
L T ! L i ISSUE: Improvements are needed in the lifted lead and jumper program. INPO
REFERENCE:
November 1983/ Construction Project Evaluation. Finding (TC.4-4), page 38 i NEY RESPONSE STAYUS: A program to review the completeness of inactive lifted lead and jumper forms was implemented by the Startup Test Department Technical Support Group in December I 1983. General training of all test engineers was conducted to emphasize the requirements of the lifted lead and jumper program and the pertinent procedure was revised to incorporate INPO Good Practice OP-202 and other beneficial changes. , NHY has reviewed INPO Finding T0.4-4 together with the corrective action taken. We have determined that no l issues exist which would adversely affect safe plant i operation. l l e<
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I-~ 1. 9 ISSUE: First-Line Supervision Involvement in Construction i INPO
REFERENCE:
INPO Evaluation of Seabrook, dated December 1984. Finding (OA.3 1), pages 5 through 7 ) e NRY RESPONSE STATUS: All appropriate personnel received intensive training in l January and February 1985, to ensure technical and ; administrative policy procedures were to be followed. Additional technical training was provided in such areas as installation techniques to improve existing expertise of field personnel. Administrative changes were made to a) increase supervisory personnel availability for inprocess work and b) improve communications between personnel to improve existing work interfaces. NHY has reviewed INPO Finding OA.3-1 together with the status of NHY's commitments to INPO, We have determined that no issues exist which would adversely affect safe plant operation. I I 1 i i 1 l l I b
8 i F .h j e ISSUE: Thermal Overload Trip Setting Criteria l INPO EEFERENCE: INPO Evaluation of Senbrook Station, dated December 1984 j
> Finding (DC.1-1), page 8 1 NEY RESPONSE STATUS: The criteria for overload protection for continuous duty motors (less than 100 hp) that are powered from motor control centers were evaluated. The Seabrook design ;
places special emphasis in the slaing of the overload I' protection for Class 1E motors, such that completion of the safety function is assured. Nuisance trips. ! transient overloade, and manufacturer's tolerances in heater size were taken into consideration and minimized to the extent practical. For additional conservatism, motors were specified to have their rated horsepower at least $ percent above the maximum brake horsepower required. In summary. New Hampshire Yankee concluded that the Seabrook design for overload protection of continuous duty motors was acceptable. ! New Hampshire Yankee has reviewed the FSAR commitment regarding the comparison of the thermal overload protection curves with the manufacturer's motor thermal damage curves. The review concluded that, for small ; motors (less than 100 hp), this comparison is unnecessary. The FSAR was revised via Amendment $4 to , reflect this conclusion. NHY has reviewed INPO Finding DC.1 1 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation. , L'
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,s: "1 4-ISSUE: Clearance Requirements Between Major Components INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (DC.5-1), page 9 NNY RESPONSE STATUS: Component separation criteria was addressed in Technical Procedure TP-8 entitled ' Technical Procedure for separation Criteria.' This procedure was modified to establish minimum clearance criteria among major components (such as IEC panels, motor control centers, etc.) in Seismic Category I buildings to preclude seismic interaction. TP-8 was reissued May 1985, to
-include this acceptance criteria. Any deviations from TP-8 criteria were evaluated on a case-by-case basis to verify acceptable component separation.
Additionally, during the later stages of construction NHY Engineering employed the services of Mark Technologies. Mark Technologies performed proximity evaluations for major componente required for safe shutdown. Additionally, this program required. physical plant walkdowns of systems and components to verify the proximity criteria. All issues were adequately identified and resolved. Mark Technologies' evaluations.. calculations and program requirements were subsequently included with NHY project documentation. NHY has reviewed INPO Finding OP.2 1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. t
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I ISSUE: ' Control of Instrumentation Calibration Information INPO
REFERENCE:
INPO Evaluation of Seabrook Station dated December 1984, ! Finding (DC.5-2), page 10 i
'NEY 1RSPONSE STATUS: A program was implemented to verify safety-related fields of the Standard Instrument Schedule (SIS) J required to ensure startup testing and pre-operational readiness. The SIS verification was completed in July 1985. This information was issued as a safety-related document in accordance with pre-established procedures. i This ensured that the calibration range information in the SIS matched that of the source calculations.- ,
i Verified setpoint data was provided by system turnover. ; Changes to the SIS resulting from the verification or changes to the source calculations was implemented via i standard Project design change procedures. NHY has reviewed INP0 Finding DC.$.2 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation.
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i' 6 ISSUE: Engineering Change Authoriaation (ECA) Program n INPO REFREENCE: INPO Evaluation of Seabrook Station, dated December 1984 Finding (DC.6 1), pages 10 through 11 NEY RESPONSE STATUS: A 'sepresentative sample of ECAs from each discipline was reviewed to determine the extent of problems similar to those discussed in this finding and to identify any
, appropriate corrective actions. These reviews were completed in June 1985, and covered approximately ten percent of the more than 4000 ECAs issued in the first four months of 1985. Results indicated only two isolated errors which were corrected. No programmatic changes were required. An ECA trending program initiated in 1985, included attributes to cover the INPO concerns raised in this Finding.-
NHY has reviewed INPO Finding DC.6 1 together with the corrective actions taken. We have determined that no-issues exist which would adversely affect _ safe plant operation. f I I_ \ l' l l l
j (- I l' ISSUE: Inclusion of Equipment Qualification (EQ) and Shelf Life Requirements in Maintenance Program INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (CC.3-1), pages 12 through 13 NNY RESPONSE STAYUS: All equipment qualification and shelf life program requirements are now included in the following manuals F and procedures a
. Corporate Policy.
NHY Procedure (NYMA) 17230. Equipment Envirotunental Quality Program . created to ensure that the equipment
. qualification of safety related and certain non-safety equipment is maintained durin6 design changes, modifications, paintenance, and testing. This program also includes shelf life considerations for safety-related equipment and components.
-Implementation Controls.
NHY Production Equipment Qualification Manual (NPEQ) - production controls used to implement equipment qualification requirements of NYHA 17230. NHY Procurement Manual (NYPH): PMS.7, Shelf Life Program
- production controls use to implement shelf life requirements of NYHA 17230.
These programs as well.as the departmental implementing procedures are maintained current and are treated as
'Living Documents' for the purpose of maintaining the Environmental Qualification Program in accordance with 10CFR50.49.
NHY has reviewed INPO Finding CC.3-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. i l
s i t i ISSUE: Storage and Control of ASME III Material by Contractor f i- INP0
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 ! L Finding (CC.3-2), pages 13 through 14 l I
-h NNY RESPONSE STAYUS: Construction supervision resolved ASME III material l storage problems identified in several 1985 contractor i inspection reports issued by the ASME III piping l C contractor as part of the contractor's surveillance and monitoring program. ,
I I. Subsequent to the INPO. evaluation, the NHY Quality i Assurance (QA) Department increased the frequency of surveillances of areas in which the. piping contractor
'[c was storing ASME materials. A significant improvement in storage conditions in these areas was noted, as demonstrated by a NHY QA surveillance conducted during ,
the last week January 1985 in which no deficiencies l , were found. In addition to the above activities, actions were taken I to help alleviate the cosmetic rusting problem for , storage of materials outdoors. Cosmetic rust was cleaned to meet specification requirements prior to , finish painting. ,
, t Surveillance by both ASME III piping contractor QA and YAEC QA continued on a regularly scheduled basis to.
ensure adequate material control in storage areas. NHY has reviewed INPO Finding CC.3-2 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe
! plant operation. -
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-' ISSUE: Care and Protection of Electrical Cable During Installation INPO REFEEENCE INPO Evaluation of Seabrook Station, dated December 1984 Finding (CC.4-1), pages 14 through 15 L
NNY ERSPONSE STATUS: The Field Electrical Procedure (FEP-504) training sessions conducted by NHY and Construction Management personnel placed a great deal of emphasis on the care , required during cable installations. Special consideration was given to minimum bending and sidewall t pressure limitations. All cable pulling foremen were i- trained and tested to FEP-504 with a minimum acceptable score of 80 percent. A survey of cable rework during the months of November and December 1984, revealed that only 1 percent of rework was due to damaged cable. ! Because some rework was still occurring, all foreman received additional instruction on the aforementioned subjects in March 1985. o NHY has reviewed INPO Finding CC.4-1 together with the status of NHY's commitments to INPO. We have determined that no issued exist'which would adversely affect safe plant operation. h i
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180UE: Honit: ring cnd Contr:1 cf Hang;r cnd Pip) Instal 10ticn INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (CC.4-2), pages 15 through 16 4 , NHY RESPONSE STATUS: The following corrective actions were implemented for the ASME III piping construction disciplines
- a. Additional craft supervisors were added to the piping contractor's staff to increase the level of craft supervision during in-process work.
- b. By procedures, the field supervisor was directly responsible for the quality of work produced by the craftsmen. Training needs for supervisory personnel as well as craft personnel were reviewed to clearly establish responsibility for quality and training programs.
- c. The contractor staggered start times of second-shift craft supervisors to allow cohesive turnover of work activities between first and second shift.
A one-hour overlap permitted the supervisors to walk down work being turned over and pass on the appropriate paperwork,
- d. When required, a shift turnover form was included l in work packages being worked on a two-shift basis.
The f,rm provides for instructions from first to seco.d shift and second to first shift. It identified problems encountered and records the foreman and fleid engineer involved in the work. The shift turnover form enhances communications , between shifts and direct involvement of I supervision in the work,
- e. Related procedures to this finding were revised.
The Pipe and Pipe Support Close Out Task Team ' (PAPSCOTT) completed in May 1986, verified actual installed ASME piping system configurations and supports reflected analytical design packages. Additional details on this program are provided in the response status to the November-1983 Construction Project Evaluation. Finding DC.1-2, page 10. l NHY has reviewed INPO Finding CC.4 2 together with the corrective action taken. We have determined that no : issues exist which would adversely affect safe plant operation.
l ISSUE: Implementation of Site Industrial Safety Program i U s 4 INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (PS.1-1), page 17 NNY RESPONSE STATUS: A Seabrook Project Safety Committee was established in January 1985. the committee's goals and objectives were i as follows:
- a. Ensure that present-safety programs were ,
implemented to their fullest.
- b. Look for areas to improve present safety program. [
-c. Increase safety awareness for every employee at the ,
Seabrook site through safety meetings, accident reports, and updates in the project newspaper.
- d. Review present project disciplinary actions for-safety violations: the need for stronger disciplinary actions was evaluated.
NHY has reviewed INPO Finding PS.1-1 together with the-corrective actions taken. We have determined that no issues exist which would adversely affect safe plant operation. . J t b
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r 4 e k ISSUE: Development and Implementation of Overall Project Schedule INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (PS.2-1), page 18 NEY RESPONSE STATUS: Detailed schedule levels currently existed defining work activities for the work force levels anticipated through May 1985. The detailed scheduled development process was accelerated to increase the lead time. It was intended that detailed schedules would be developed three to six months ahead of the anticipated construction manpower assignment. While the construction detailed activities were developed on a priority basis in support of the critical path, it should be noted that all startup and engineering logic were established in detail. The consolidation of the engineering logic into the common Project 2 network processing was completed in May 1985. This allowed fully integrated (i.e., engineering, construction, and startup) critical path. analysis (CPM) type schedule analyses and reporting. l The detailed schedule system was utillaed to manage the completion of all remaining construction work scope. Schedules were developed to specifically identify not only system completion, but commodity-type activities such as insulation, cable tray bracing, penetration sealants, building completions, etc. NHY has reviewed INPO Finding PS.2-1 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation. ll L
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l -- . . ISSUE: . Control of Documents used by Start-up Personnel INPO REFEEENCE: INPO Evaluation of Seabrook Station, dated December 1984, Finding (PS.6-1), page 19 f-NHY RESPONSE STATUS: Startup Administration Instructions, ' Control of Ji Drawings,' was revised April 1985 to improve controls for the notification and issue of drawing revisions to Startup Test. Engineers (STE). STEs were notified of 4 - drawing revisions and were required to acknowledge that drawings previously issued to them were revised. NHY has reviewed INPO Finding PS.6 1 together with the status of NHY's commitments to INPO. We have determined' that no issues exist which would adversely affect safe plant operation. c. t !
f I e ISSUE: Training cf CrOf tsman cnd Qu211ty C;ntrcl (QC) Insp;ctors
.- INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984, Finding (TN.3-1), page 20 through 21 NHY RESPONSE STATUS: Safety, Installation Procedures and acceptance criteria training was provided in April through August 1985, to all craftsmen and Quality Control Inspectors to a revised Employee Orientation Program. The existing training procedure (ASP-8) was revised in April 1985, to include a) administrative control to ensure personnel receive safety training on a timely i basis, and b) a monitoring and feedback mechanism to ensure that desired results were attained and supervisory accountability was established. NHY has reviewed INPO Finding TN.3-1 together with the corrective action taken. We have determined that no i issues exist which would adversely affect safe plant operation.
I r t ISSUE: Identification of Dimensional Deficiencies in Pipe Support Installation INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984, i Finding (QP.2-1), page 22 NHY RESPONSE STAYUS: The najority of pipe support dimensional deficiencies identified during the as-built walk-downs related to gap dimensions between the pipe and support members. These result from shrinkage / warpage of support components and the piping system during the welding process and would not be identified during in-process dimensional checks. Correct gap dimensions were achieved by shimming as permitted by project specifications. A project rework study was performed in order to identify the root cause of rework. The study concluded that the major portion of rework was related to small bore pipe installation tolerances. In an effort to minimiae rework, the installation tolerances for small bore pipe was substantially modified. Additionally, Technical Procedure 26, 'As-Constructed Requirements for Pipe Systems," was revised April 1986, to provide a more concise mechanism of taking piping and pipe support as-built information. The ASME III contractor as-built the piping and pipe supports immediately following installation. Prompt identification of dimensional deficiencies minimized the impact on the project schedule. The engineering stress reconciliation effort and piping walkdowns required by IE Bullotin 79-14 was performed by PAPSCOTT (refer to
., the response summary for the November 1983 Construction Project Evaluation. Finding DC.1-2. Page 10 for a description of the PAPSCOTT Program) beginning in April 1985. This approach ensured that installation deviations were identified early and reconciled accordingly thereby minimiaing the impact on the project milestones.
NHY has reviewed INPO Finding QP.2-1 together with the status of NHY's commitments to INPO, We have determined that no issues exist which would adversely affect safe plant operation. 1 i
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ISSUE: Quality Control Inspection Hold-Points INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding (QP.3-1), page 23 NHY RESPONSE STATUS: The symbol "H" indicateds a QC hold point on the weld process control sheets and is well understood by craftsmen.. supervisors, and inspectors. The symbol "H" with a slash, initial, and date indicated a hold point was deleted. Deleted hold points were shown on the ASME III pipe contractor's process sheets several weeks prior , to the INPO evaluation and may not have been fully j understood by craftsmen. As a result, productivity was impacted because craftsmen stopped work to get a resolution from QC inspectors. QC inspectors were informed of the deleted hold point symbol following the INPO evaluation. As of January 1985, there was no question as to the meaning of a hcid point by QC or craft personnel, and the existing procedures were clear in this regard. ; Disciplinary action was administered against any i individual bypassing designated hold points. j In the event a hold point was inadvertently bypassed, I a Nonconformance Report (NCR) and a Corrective Action Report (CAR) were generated. Trend analyses was performed monthly to confirm that hold points was adhered to by the ASME III piping craftsmen and l inspectors. Similar misunderstanding of hold point symbols existed in the area of the electrical contractors. To clarify : any misunderstanding on electrical field procedures, a ! training seminar for quality control and construction ! personnel was completed in April 1985. The training highlighted attributes to be inspected at hold points ; and symbols used to identify hold points. ! NHY has reviewed INPO Finding QP.3-1 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation. i i i I a
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-ISSUE: Quality Control Inspector not Adhering to Quality Control Procedures
-1NPO REFERENCE '
INPO Evaluation of Seabrook Station, dated December 1984, Finding (QP.3 2), pages 23 through 24
'NHY RESPONSE STATUS: Memorandums were issued to remind QC inspectors of the importance of certain procedural requirements.
Training was provided in January 1985, to all appropriate personnel to ensure field procedures were to . be followed. ! Procedures were revised in February 1985, to clarify inspection methodology. NHY has reviewed INPO Finding QP.3-2 together with the
, status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation.
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T h s' . ISSUE: Review-of Quality Records for Accuracy and Completeness l INPO
REFERENCE:
INP0 Evaluation of Seabrook Station, dated December 1984 Finding (QP.3-3), page 25 NEY RESPONSE STATUS: Level I QA review of turnover packages included a. verification that applicable documentation required to substantiate field implementation of NCR disposition and NCR' closure was included in the package. The project issued an interim procedure change in February 1985, to incorporate this requirement into QCP-17-1, ' Records , Review." Appropriate personnel were trained accordingly. NHY Level II QA review included a
> verification that applicable NCR closure documentation L was reviewed and included in the documentation package.
In the area of hardware to software reconciliation, the problem relates specifically to ASME code items installed by the previous I&C contractor. A task force was established to address and resolve any hardware / software problems. The effort was conducted to support the system turnover schedule during hot functional testing. By nature of the differences between the previous and new contractor programs pertaining to responsibility for recording / verifying information on weld process sheets, the possibility of any similar problems with the new contractor's IEC documentation was considered to be extremely remote. In respect to reviews of contractor RT film, the problem was precluded from recurring by a NHY QA policy that was instituted in early 1984, which requires the contractor to present all RT film' transmittals and
'r corresponding film packages for NHY QA review mediately prior to their transmittal to the Records Jt. This review wa's performed to ensure that NHY QA he.o previously reviewed all film packages included in
required corrective action. A formal Corrective Action Report (CAR) system was implemented in May 1985, to replace the Startup Notification Report (SNR) system. In order to ensure all programs were implemented, an additional corrective action follow-up system was created whereby department heads were issued bi-weekly report listing status of open corrective action documents for which they were responsible. NHY has reviewed INPO Finding QP.5-2 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation.
.i
h ISSUE: Day-To-Day Scheduling of Startup Testing Activities INPO' REFERENCE ' INP0' Evaluation of Seabrook Station, dated December 1984, Finding (TC.3-1), page 29 - NHY RESPONSE STATUS: -The Startup Test Department (STD) increased its attention to detailed short-term planning. STD convened a startup schedule weekly review meeting. This meeting was attended by the STD manager, group managers, discipline supervisors, and test engineers responsible for accomplishment of scheduled activities. Testing and. support activities relating to established milestones were addressed and a dynamic "TO GO' schedule to include the most recent information. To support the increase in construction and startup activities, the plan-of-the-day (POD) meetings resumed on a daily basis. In addition, the STD nuclear steam supply system (NSSS) and balance-of-plant (BOP) groups held daily meetings to lay out specific activities for that day. All of the above meetings were attended'by representatives of the affected STD disciplines, as well as members of the Station Staff Technical Services, Maintenance and Operations groups, and Safety Department. representatives. Organizational interface and support manpower requirements were addressed at these meetings and planned as far in advance as practical. Parallel to the above-mentioned efforts, the Startup Planning and' Scheduling group developed three-week
'look-ahead
- schedules in June 1985, for the entire Startup logic. These schedules were used by the discipline supervisors to better integrate their activities with the overall startup program.
NHY has reviewed INPO Finding TC.3-1 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe pl ant operation, o
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, ISSUE: Startup Testing Program Controls INPO
REFERENCE:
INPO Evaluation of.Seabrook Station, dated December 1984, , Finding (TC.4-1), page 30 NEY RESPONSE STATUS: Startup testing activities were controlled through generic or specific procedures as'the specific nature of the test dictates. In addition, equipment operations and maintenance were supported by the use of venoor manuals, instructions, drawings, and plant operating , procedures as appropriate to the task being performed. ' These evolutions were directed through a single System Test Engineer (STE) who maintained a high degree of knowledge and control regarding system status and technical operating requirements. A policy guideline was issued April 1985, to clarify the philosophy regarding the proper use of procedures and to more clearly define when detailed procedures were required. The guidelines addressed complex tasks as well as the use of procedures as a communications device for multiple shift operations and/or when large numbers of personnel were involved. NHY has-reviewed INPO Finding TC.4-1 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation. l l l i; t
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-1 ISSUE __ Integrity Test Package Program and Hydrostatic Test Performance INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 _! Finding (TC.4-2), pages 30 through 31 NHY RESPONSE STATUS: The program for performing hydrostatic testing was in process of being realigned during the INPO evaluation. The program realignments provided ASME III piping
" contractor personnel dedicated to cleaning up outstanding items restraining issuance of the packages in each of their operating groups (Field Engineer, QC,'
QA, and Production). i Scheduling of the tests were coordinated with the Startup Test Department, and priorities were established with regard to project milestones. The scheduling of this work was coordinated with startup flushing and hydrostatic (hydro) test activities. Sufficient personnel including supervisors were assigned to the ASME III piping contractor hydro test group to handle the workload presently scheduled. As the scheduled hydro test activities increase, additional staff _was assigned to the group. The personnel assigned to the ASME III pipe contractor hydro test group had prior field experience in hydro test activities and were considered fully qualified to perform the assigned responsibilities. Actual testing was performed in conjur.ction with Startup Test l Department personnel, fully certified Quality Control inspection personnel, and the Authorized Nuclear Inspector, when applicable. I NHY has reviewed INPO Finding TC.4-2 together with the status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation.
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ISSUE - Site Safety Tagging Requirements Not.Followed 4 INPO REFERENCE - INPO Evaluation of Seabrook' Station, dated December 1984 Finding (70.4-3), page 31 through 32 i l NHY EESPONSE STATUS: Two tagging programs were currently in effect for all j site safety tagging of equipment.- One was for equipment under'the Operation's Department jurisdiction and the other covers equipment was under the jurisdiction of the Startup Test Department. To eliminate confusion the dual tagging system was , eliminated in favor of one system under the jurisdiction j
.of the Operation's Department. All appropriate personnel were trained to the new Tagging system. j NHY has reviewed INPO Finding TC.4-3 together with the j status of NHY's commitments to INPO. We have determined i that no issues exist which would adversely affect safe-plant operation.
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ISSUE: Involvement of Operational Department with Ste,rtup Testing Activities INPO.
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1924 Finding (OP.2-1), page 33 l i NHY RESPONSE STATUS: Steps were taken to improve the interface and communication between the Startup Test Department (STD) and Operations Department personnel. These included the following: {
- a. Startup initiated daily nuclear steam supply system h (NSSS) and balance-of-plant (BOP) discipline ;
meetings to discuss activities planned for the day. -
- b. Shift test directors were instructed to brief the i appropriate Operations personnel at the start of j each shift. ;
-i
- c. When performing individual preoperational or acceptance tests.-the test director briefed Operations personnel involved in the test prior to i the start of the shift and/or prior to the start of !
the test. I 1 In addition, ongoing STD activities were evaluated to
. verify the extent of Operations Department personnel involvement.
NHY has reviewed INPO Finding OP.2-1 together with j status of NHY's commitments to INPO. We have' determined i that no issues exist which would adversely affect safe plant operation.
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ISSUE: ' Auxiliary Operator Adherence To Procedures ta 7 INPO REFERENCEi INPO Evaluation of Seabrook Station, dated December 1984 Finding,(OP.2-2), page 34 L;i , '
!GDf RESPONSE STATUS: Auxiliary operators were verbally reminded, in weekly meetings with the Assistant Operations Manager,'of the need for using procedures and for adherence to procedure ,
requirements. Operations Department supervisors were- , instructed, by department memorandum, to periodically monitor the auxiliary operator's use of procedures and 4 to validate procedures during equipment and system testing in conjunction with the Startup Test Department. The Station Manager and'the Operations Manager monitored actions taken and found no followup actions were required. NHY has reviewed INPO Finding OP.2-2 together with the
' status of NHY's commitment to INPO. We have determined that no issues exist which would adversely affect safe plant operations. -
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'd ISSUE: Auxiliary Operator Knowledge of Plant Systems t
- INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984, s ;. Finding (OP.4-1), pages 34 through 35 NHY RESPONSE STATUS.- A task force of Training Center staff and Operations Department staff reviewed the INPO generic job task analysis for applicability to Seabrook Station. The i task force revised the trair.ing program. June 1985,.for' auxiliary operators accordingly. The revised program included formal qualification requirements addressing ; both initial training and recycle training to reduce known weaknesses. On-shift' operators were recycled into the training program in 1986. The Operations Department also developed administrative controls to matrix and track tasks that an au.:111ary operator needs to accomplish. The matrix was used by the shift supervisers to document demonstrated proficiency in specific tasks and to schedule on-the-job training for 4 areas of noted weakness. The-continuing Auxiliary Operator (AO) training program has been modified to provide more specific AP-oriented-plant update information. This training program was accredited by the National Nuclear Accrediting Board in July 1989. Additional details related to A0 training are provide in the NHY response status to INPO recommendation TQ.5-1, page 19, of the November 1987 i INPO evaluation of Seabrook Station. NHY has reviewed INPO Finding OP.4-1 together with the corrective actions taken. We have determined that no issues exist which would adversely affect safe plant - operations. i l l' I.
l G^ ISSUE: -Uncontrolled Drawings and Sketches used as Operator Aids a. INPO
REFERENCE:
INPO Evaluation-of Seabrook Station, dated December 1984, i Finding (OP.5-1), page 35 NHY RESPONSE STATUS:' Operations Department personnel were notified that only controlled operator aids were to be used and that , uncontrolled information would not be allowed in the performance of duties at the station. Many uncontrolled operator aids were removed and others were reviewed to determine the need for their continued use. The Operations Management Manual.(OPMM). vas revised August 1985, to include the controlled use of operator aids. The procedure incorporated the beneficial aspects of f INPO Good Practice OP-207, " Control of Operator Aids." NHY has reviewed INPO Finding OP.5-1 together with the status of NHY's commitments to INFO. We have determined that no issues exist which would adversely affect safe plant operation. l i e w ._ _ _ _ _ _ _ _ _
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ISSUE: Preservation of Station Equipment L INPO
REFERENCE:
' INPO Evaluation of Seabrook Station, dated December 1984 Finding (MA.5-1), page 37
' NHY RESPONSE STAYUS: Based on a review'of'the preventive maintenance program, additional personnel were added to perform required preventive maintenance functions in a timely manner and supervisory personnel began to monitor their progress through increased plant inspections. .
Construction quality assurance audited the balance-of-plant preventive maintenance activities in April 1985, with no major program deficiencies identified. NHY has reviewed INPO Finding MA.5-1 together with the > status of NHY's commitments to INPO. We have determined that no issues exist which would adversely affect safe plant operation. s l-l l l k 4 _ _ . _ . _ _ _ . . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
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Facilities in Support'of Maintenance Functions
'ISSUEt -
l, i i INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding'(MA.8 1), pages 38 through 39 i
.NHY RESPONSE STATUS: Additional shop and storage space was provided to j Station Maintenance in support of their activities. i 1
A ' Hot Side' I&C Shop is addressed in the design of a new Decontamination Facility scheduled for completion prior to the first refueling outage. Provisions for i using a temporary structure for such a facility is being. , discussed as an interim solution prior to completion of j
, this structure. l The long term maintenance facility needs are presently ,
addressed in a Five Year Facility Plan. .; NHY has reviewed INPO Finding MA.8-1 together with the. i status of NHY's commitments to INPO. We have determined 'l that'no issues exist which would adversely affect safe i plant operation. 1 4 l 1 t l i l
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-ISSUE:' Impicment3 tion of Constructlon and Op3 rating Exp3risnca Progrcms b I l':%~ INPO
REFERENCE:
INPO Evaluation of Seabrook Station, dated December 1984 Finding-(CE.1), pages 40 through 43 NHY RESPONSE STATUS: a) A program was developed in 1985 to distribute and . review incoming information, and distribute l outgoing information via Nuclear Network. This program provided a mechanism.for all groups to evaluate the.oignificance and generic i applicability of significant in-house events and ,
,e ensure distribution of this information via NUCLEAR l NETWORK.
b) An Operating Experience Review Program was r developed in 1986 to provide a method for 'I i ovaluating industry operating experiences. As part of this program, all SERs are evaluated for applicability to Seabrook Station and recommen-ations are made as appropriate. Operating < Experience Review Program actions are tracked on j e' NHY Integrated Commitment Tracking System (ICTS) and Executive Management is provided with periodic status reports, e c) An Event Evaluation and Reduction Program was developed in the Spring of 1989 to handle Event l Evaluation, Root Cause Determination and Event 1 Reduction Evaluation in addition to evaluation activities required by other manuals and procedures. NHY has reviewed INPO Finding CE-l'together with ! corrective actions taken. We have determined that no issues exist which would adversely affect safe l plant operation.
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New Hampshire Yankee May 18, 1990
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-i Enclosure 3 to NYN 90lli .)
Status Update of NHY Responses to INPO Recommendations *
^
1987 Pre-Operational Assistance Visit for Seabrook Station
,*(The enclosed' response summaries refer to " Findings."
The 1987 INPO Report does not provide formal Findings but dces offer recommendations. NHY has treated these recommendations as Findings for purposes of developing responses and prioritizing activities on
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-these recommendations.) '
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e Jc ; i 4 4 E- > ISSUE: Formal. Management Objectives INPO
REFERENCE:
IMPO Evaluation of Seabrook Station, November 1987. Finding l (OA.2-1), page 4 NHY RESPONSE STATUS: The New Hampshire Yankee'(NHY) ' Mission Statement and 'i corporate objectives' for long-term station goals are , provided in the NHY Manual under Procedure 10000. 'The New Hampshire Yankee. organization", along with the . associated responsibilities and authorities. The NHY
' Mission Statement and Corporate Objectives' clearly
- define NHY's commitmentEto providing electricity at'the lowest possible cost while maintaining protection of the health and safety of the public.and. employees.- j L The NHY Manual also contains Procedure 11140, 1:, " Operation Goals Program', that delineates the !
requirements and responsibilities of each' corporate ' subdivision for implementing the ' strategic goals' on an annual basis. Additional guidance is also provided 7 in the annual budget guidelines provided by corporate .' management. l [ 'NHY has issued annual corporate goals, beginning in H January.1987. These goals have been periodically .
+
reviewed by NHY to assure that they remain current with' the latest industry standards. In addition, NHY has submitted Seabrook Station Performance Indicators in 1988 and 1989 to INPO for their.information. NHY has reviewed INPO Finding OA.2-1 together with the corrective action taken. We.have determined that no issues exist which would adversely affect safe. plant operation.
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' ISSUE: Management Development Program
-INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding ! (OA.4 1), pages 4 and 5 NBY RESPONSE STATUS: As a result of this recommendation by INPO, NHY hired a manager of Employment and Development for the Employee Relations Department under which many of these issues would be addressed. In conjunction with the NHY Training Department, a formal management training program was developed. It is entitled "NHY Hanagement.and Supervisory Training Program" contained within the Management Training Manual. In addition to this program, executive l management elected to expand its general corporate reimbursement program for those employees that were taking additional formal education classes related to their positions. This new program includes provisions to select a person that has exhibited promising management potential and provide complete sponsorship for further formal studies. This additional program.is entitled "The Executive MBA Program". NHY is placing , one person per year in this program. Additionally, NHY is developing a specific training module that will be made available for first time supervisors that will enhance their proficiency and acclimation to their new roles. NHY has also implemented a program to review and update. position descriptions and has developed and is implementing a management development program which identifies potential successors for key positions based on required skills and experience. It'also identifies other potential candidates for future consideration. NHY has reviewed INPO Finding OA.4-1 together with the , corrective action taken. We have determined that no issues exist which would adversely impact safe plant operation.
ISSUE: Human Resource Management Plan INPO
REFERENCE:
INPO Evaluation of Seabrook Station November 1987. Finding (OA.4-2), page 5 NHY RESPONSE STATUS: Station management has developed and implemented a resource plan to umintain the proper number of operators to safely maintain plant operations. This resource plan reflects the training and experience i requirements for an entry. level Auxiliary Operator to progress to a skill level equivalent to a Senior Reacter Operator. On an annual basis the Station Manager, Operations Manager, and Training Manager assess training requirements for all positions within the Operations Group to ensure a full complement of licensed operators. Since the 1987 INPO report, NHY has maintained more than the udnimum required licenses to staff all Operations Department positions. Operations uses eighteen (18) annual training positions for Auxiliary Operator and licensed training. Eleven-(11) positions are used for existing Auxiliary Operators to qualify for Reactor Operator licenses and for Control Room Operators, that currently retain an RO license, to qualify as Senior Reactor Operators. The remaining seven (7) positions are used to train and
, qualify entry level Auxiliaryf0perators. This training cycle has ensured a full complement of qualified and licensed operators and accounts for promotions, transfers and resignations.
NHY has reviewed INPO Fihding OA.4-2 together with the corrective action taken. We have determined that no 1 issues exist which would adversely affect safe plant operation.
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ISSUE: Station Industrial Safety Program INPO
REFERENCE:
~ INPO Evaluation of Seabrook Station, November
;, 1987 Finding (OA.5-1), pages 5 and 6
-NHY RESPONSE STATUS: The following immediate action was taken to reduce the number of safety program violations:
- 1. The Station Manager discussed these safety concerns with managers and department supervisors at a monthly managers meeting. Group managers and department supervisors were ,
directed'to enforce compliance with j the station policy on safety I issues.
- 2. A memorandum was issued by the ,
Maintenance Manager to Maintenance ; Group personnel outlining the discipline policy on violating the hard hat and safety glasses station policy. In addition-to the immediate corrective actions taken, the following actions were also undertaken:
' 1. The Safety Supervisor developed a j list of safety films available to i all NHY departments. Safety .{
Committee meetings are used by 1 management to address safety , violations as they are identified. j
- 2. The Health and Safety Manual.
l Chapter 3. Section 6 contains the l- requirements to-wear protective , l clothing when working with battery I acid. i l 1 ,
- 3. Section 3.3 (scaffolds) of the {
. Health and Safety Manual provides -i l controls for scaffold erection and j safety requirements. Prior to use , all scaffold and supports must be inspected by a qualified individual. The Safety Department performs periodic plant inspections of scaffolds and tags unsafe j assemblies. h j
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- Station Industria; Safety Program (continued)
Page 2 y gli Procedure MA 4.5 in the Station l Maintenance Manual (SSMA) contains the requirements for.a Working Foreman
.signoff and the use of a permit tag on scaffolding. SSMA Procedure MA 4.10 provides instructions and requirements
. regarding scaffolding erection. which'in :
-f i
turn references SSMA Procedure MA 4.8. Chapter 3. Section 3 of-the Health and Safety Manual requires, scaffold-- construction in accordance with SSMA
, Procedure MA 4.10.
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' Lost time accident rates for NHY- ;- i personnel and major site contractors !
were-down in 1989 from 1988 indicating j progress has been made. ' Increased ' emphasis in this area should naintain these trends. NHY has reviewed INPO Finding OA.5-1 ! together.with-the corrective action { taken. We have determined that no
' issues exist which would adversely affect safe plant operation.
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REFERENCE:
INPO Evaluation of Seabrook Station, November 1987.. Finding j (OA.7-1), pages 6 and 7 ; NHY RESPONSE STATUS: As a result of these initial recommendations, twenty-two (22) interface meetings between the Nuclear Quality , Group and Production were held to determine what , improvements would be made to the Operational Quality I
- c. Assurance Program and associated manual to enhance its effectiveness for both organizations. As a result of those meetings, guidelines and enhancements have been developed and program / procedure changes have been l implemented, where necessary. The principle areas of !
enhancement were the definitions for prioritization of i I findings, categorization of findings and clear definition of the use of ' HOLD
- points. I Additionally, the NHY President and CEO reaffirmed .
executive management's commitment to a performance based Quality Program in a detailed mission statement to all NHY employees. The NHY Independent Review Team conducted an extensive l
'l evaluation of the_ Operational Quality Assurance Program and its implementation in the Spring of 1989. This ';
evaluation resulted in a set of recommendations to enhance program and implementation practices. The substance of these recommendations have been successfully implemented. A key practice of performance based. inspections has significantly ; improved the substantive efforts of the Nuclear Quality l Group, improved their contribution for line l organizations and has gained them greater acceptance and appreciation by line management. j In July 1989, NHY internal reorganizations resulted in establishing a Quality Programs (QP) subdivision within NHY. The QP subdivision reports directly to the Senior Vice President and Chief Operating Officer on par with the Production and Engineering subdivisions. The QP ; subdivision includes the Nuclear Quality Group,
- , Independent Safety Engineering Group, Employee l Allegation Resolution Program, and Independent Review -
Team. This organizational arrangement has proven f effective since its implementation. 1 NHY has reviewed INPO Finding OA.7-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant l~ ^ operation, q i
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. t ISSUE:' Fitness For Duty Program INPO
REFERENCE:
INPO Evaluation of Seabrook Station November 1987. Finding + (OA.8-1), pages 7 and 8 . NHY RESPONSE STATUS: Fitness For Duty training has been upgraded to provide improved awareness of program requirements applicable to both supervisory and non-supervisory personnel, i Specific response to observed problems are noted belows
- a. The program was revised in 1987 and personnel were retrained. This training (in the revised course) of eligible personnel was completed in 1988. !
Additionally, NHY began reviewing the. proposed NRC l regulation on ' Fitness For Duty" in mid-1989 and l started developing a revised ' Fitness For Duty Program' to meet the NRC regulation.in the fall of 1989. NHY 1mplemented this new program in i December, 1989. l i
- b. A pamphlet, " Drugs and You' and the Fitness For i Duty procedures are provided to employees as they l process through General Employee Training (GET). ,
I
- c. GET does cover the site rules which include.
prohibitions against the use, possession or sale of , alcohol / drugs on site and fitness for duty. !
- d. Fitness for duty is included as part of the Employee Assistance Program (EAP) Introductory Training and the Behavior Observation Program Training. A site orientation course has been ,
developed to be given to personnel who do not ! receive GET. Chemical screening is-being conducted ] L in conjunction with.GET,' site orientation, and on a ( l random basis. i 1 Fitness for duty training is covered in the Sehavioral Observation Training Program. This ; training was given in 1988 and 1989 and continues .l to be given. Various pamphlets have been made available to employees and their families by the l EAP Program. The important aspects of the Fitness For Duty Policy are referred to in the GET Program, but are i not taught at the same level of detail as is with ] supervisory personnel in the Behavioral Observation Training module.
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'( s i ISSUE: Operations Department Administrative Controls INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding (OP.1-1), pages 9 and 10~ NHY_ RESPONSE STATUS: The Op.;ations Department administrative controls now include specific controls as follows:
- 1. Control Room instrument deficiency tags and
. extension control tags are-identified and controlled by Station Maintenance Manual (SSMA)
Procedures MA 3.1 and MA 4.2.
- 2. Contingency action required when equipment parameters are masked by deficient remote alarms or ,
instruments are adequately addressed in Section 3.0 of the Operation Management Manual. It provides programmatic guidance to the Shift Superintendent and the Unit Shift Supervisor should these conditions occur.
- 3. Section 3.0 of the Operation Management Manual addresses the requirement to use minimum and maximum parameter values on auxiliary operator logs, where applicable.
4.. A complete physical plant walkdown has been completed to remove unauthorized tags. Many of the removed tags were from the early construction days and were used to control const ruction related , activities. Additionally, the following elements have also been added to the programs
- a. The Station management personnel have been directed to make periodic plant tours by the Station Manager and report any unauthorized activities or conditions detrimental to effective and safe operation on the Station. i
- b. Quarterly tag audits are now required by Operations Administrative Instruction (OAI)-14.
This audit reviews the various tag logs to assure that the identified tags are still valid. Corrective measures are taken when
-invalid tags are identified,
- c. The Operations Management Manual also requires the Shift Superintendents to conduct periodic plant tours with their auxiliary operators while on the back shifts.
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Administrative ControlsL(Cont'd) i t
" *, ni t 4 q
r l' Ld. Independent. verification of components with? it remote Control Room indication is~to be proceduralized in 1990.. NHY's past. position on l
,' .this issue was.that there are always:at-least .
n two Operations personnel in the Control Room.at l all times to perform this-function. Therefore, i it was not necessary to'have it p'roceduralized,
~
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, NHY has reviewed'INPO. Finding-OP.1-1 together'with the- '
j corrective action taken.. We'have determined that no --
-issues exist which.would adversely affectDsafe plant, 100 ,
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ISSUE: . Caution Tags I INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November.1987. Finding ! (OP.3-1), page 10 NHY RESPONSE STATUS: During the transition phase from construction to Operatione, quite often systems were not configured in the manner they were designed in order to support flushing, hydrostatic testing and off-normal operations. The result was that operating procedures , were not always capable of being used correctly since procedure changes would have been massive and, for the short-term, systems were operated from a combination of startup procedures and normal operating procedures. In this mode the use of caution tags was considered necessary and in fact prudent. Operations, since approximately mid-1987, has been consciously reducing the reliance on-caution tags and writes procedure changes to accommodate necessary cautions. All Operations personnel were briefed during the first six weeks of 1988 regarding limiting the use of caution tags when procedure changes are more appropriate. A review was completed of all caution tags and all tags that were deemed necessary were kept as tags. A determination was made of the need to incorporate other tags into procedures as required. Additionally, l Operations Administrative Instruction (OAI)-14 requires a quarterly' audit be performed of all issued
' caution' tags to assure their validity or re-evaluate the necessity to issue an appropriate procedure change.
NHY has reviewed INPO Finding OP.3-1 together with the corrective action taken. We have determined that.no issues exist that would adversely affect safe plant operations. i
ISSUE: Emergency Operating Procedures' l INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding ! (OP.5-1), page 11 NKY RESPONSE STATUS: New Hampshire Yankee'(NHY)' completed a review of the Emergency Operations Procedures (EOP) as suggested by the INPO recommendations. This review was conducted between July, 1987 and May, 1988 using the criteria and guidelines issued by Westinghouse in their Rev. lA,
" Emergency Response Guides (ERG)" . This review was not completed at the time of this INPO station evaluation. 1 The E0Ps were subsequently reviewed by the NHY Station Operations Review Committee (SORC) and issued in May, 1988. This was the second revision to the E0Ps and they have been continuously maintained current.
Licensed Operators maintain their knowledge of E0Ps through the re-qualification training that occurs on a six (6) week rotating ochedule for each shift. The training consists of classroom review and Simulator scenarios which test the capabilities of the shift crew and individual operators under simulated emergency conditions. During the summer of 1989 NHY recognized the NRC's pursuit of active maintenance programs.for E0Ps at L nuclear power facilities. NHY established an l additional review and maintenance program for the L E0Ps. This review, conducted in the fall of 1989,. generated a number of enhancements to the E0Ps, all of which were reviewed and determined not to contain any safety significance. These enhancements are currently in the process of being fully incorporated into.the ' l EOPs. The maintenance program was also formalized by L the issuing of Operations Management Manual (OPMH) Procedure OP-9.9, " Emergency Operating Procedure L Maintenance" and by creating a-data base to facilitate the E0P maintenance effart. Additionally, NHY has verified and validated ell changes required and'has completed a walkdown of local actions to evaluate the human factors concerns related to these actions. To ensure continued enhancements and active maintenance, NHY created an Emergency Operating Procedure (EOP) Task Team that consists of members from Operations. Training, Engineering, Nuclear Quality, and Licensing. The E0P Task Team's charter is to review the E0Ps utilizing the guidance provided by the NRC in TI-2515/92 and in NUREG-1358, " Lessons Learned From The Special Inspection Program For Emergency Operating Procedures". This review will continue to further refine and enhance the E0Ps and goes beyond the specific issues that were addressed by INPO.
li' f Emergency Oper0 ting Procid:rse (Contin :d) P ge 2 !
., f
'Upon completion of each enhancement process, the E0Ps !'
will go through a verification and validation process. They.will be verified for technical adequacy and l validated by simulator trial, tabletop review or plant - walkdown. The verified and validated E0Ps will then be , presented to SORC for approval and subsequent issuance : for implementation. ! i This overall program has been developed and is being -) implemented to assure that the quality of the E0Ps continue to remain within the highest standards ; expected of NHY procedures. This will also assure that ; the plant remains in a safe operating environment to nwet the requirement of adequately controlling a plant 3 emergency, should the need arise. NNY has reviewed INPO Finding OP.5-1 together with-the corrective action taken. We have determined that no l issues exist which would adversely affect safe plant ! operations. k I i I ' ! l l H j
{ 3 .. i ISSUE: Balance of Plant Condition INPO
REFERENCE:
INPO Evaluation of Seabrook Station November 1987. Finding (MA.2 1), page 13 NNY RESPONSE STATUS: In early 1989 NHY established a five year BOP painting plan and Radiological Control Area (RCA) program. These programs are intended to utilize the designated six man cleanup and five man painting crew within the Maintenance Department to work towards the completion of these plans, when they are not required to provide their services to completing current maintenance or modification work. The primary focus of these plans is to prepare and protect those areas and equipment that , are subjected to harsh environments or possibly subjected to contamination. To date, the face of the main condenser, water boxes, # circulating watar inlet and outlet piping have been sandblasted, where appropriate, and protected with a rust inhibitor paint. The service water pump house has had all its piping componente and structural steel painted. The circulating pump house is currently scheduled for a late fall 1990 to early winter 1991 completion of the applicable coatings. l The emergency feedwater (EFW) welds in the EFW pump house have not been painted yet due to its normal ' operating environment. The room remains warm under normal operating conditions, therefore having minimal effect on material deterioration. l The RCA program is focusing on three major objective preserve, protect and maintain the RCA: criteria rework and complete in accordance with design for ALARA l considerations: and touch-up areas and equipment as required. Significant painting efforte in the RCA will continue l: while the plant is in operation. This program, which is being implemented with an initial schedule for RCA rework, will assure that areas requiring additional attention as the plant continues in power escalation l are addressed as quickly as possible to minimize de-contamination problems. NHY has reviewed INPO Finding HA.2-1 and the alleger's statement regarding this finding together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
ISSUE: Vork Planning j INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding ! (MA.3 2), pages 13 and 14 NNY RESPONSE STATUS: NHY has enhanced the details contained in Station Maintenance Manual (SSHH) Procedure MA.3-1, entitled
' Work Request', which controls the development of work packages and associated responsibilities.
Work Requests (WR) are generated for work performed within the Station. Anyone can generate a WR and then process it through the Unit Shift Supervisor (USS) if the work affects plant equipment operability. The US$ then forwards the WR to the Shift Superintendent (SS) who reviews the WR to assure the work is adequately described as well as justified. Work that is appropriate is prioritiaed by the SS and forwarded to the Section Leader, Work Control for further processing. The Section Leader, Work Control assigns the tracking number to the WR and forwards it to the System Engineer for further review and work scope details. The System Engineer will also assure that there ir no duplication of WR's and determine the appropriate technical j requirements of the work to be perforrt.ed, such as safety-related, fire protection, seismic, security, equipment qualification, in service testand, ASdE Section XI. IE associated B31.1 upgrade, etc. The System Engineer will also determine the corroct scope of post maintenance testing to validate that the reworked component still meets its design basis i requirements. NHY Production Planning and Scheduling Manual, Chapter 3, defines the responsibilities of the planner in preparing the work package for implementation. This , procedure requires the planner to perform a work i station walkdown to assure all aspects of the planned. i work are incorporated into the work package. This also i includes any necessary permits and prestaging of any D required material, as necessary. Additional staffing has made the planning process more effective in that work methods performed on similar components, are reused as much as possible, minimizing delays in producing the new work packages. _The tagging process l: has been significantly enhanced by job preplanning and l the full daytime staffing of the Work Control L Supervisor position in the Control Room, Job l preplanning requires the identification uf work scope l boundaries to facilitate subsequent tagging. The Work l i i
v 4 ! Work Planing (Continued) Page 2 , Control Supervisor position, normally staffed by the relief week Unit Shift Supervisor, streamlines the operations review and approval for removing equipment , from service. The NHY configuration management system uses a hierarchical categoriaation matching the extent and - priority of change document incorporation in documents. This system requires Category 1 Control Room drawings to be updated before
- operability' is declared on a system, while Category 2 drawings are required to be updated within 24 hours. This simplifies the Planner's tasks as well as assuring that the Control Room has the most current drawing available for reference. Category ,
3 documents are typically baseline design references and are not frequently revised to reflect as-built plant configuration. NHY uses a Change Document ; Tracking system which does, however, cross reference each change document (e.g., DCR) with the affected , document. The Change Document Tracking system retains all change documents issued for the life of the project through current NHY efforts. NHY has established a long-term program to systematically revise frequently ,
" used Category 3 documents. !
Maintenance feedback is accomplished by noting any . problems encountered during the performance of the job on the work request. The Planner and System Engineer uso this information for performance monitoring, trending, and to plan future work activitiec. A detailed breakdown of open Work Requests, i prioritization. related plant operational mode entry requirements, and backlog goals were previously provided via NNY letter NYN-90021, dated 1/25/90. Open Work Requests have been reduced to the normal, expected level and are' tracked and monitored on a daily basis. ; NHY has reviewed INPO-Finding MA.3-2 together'with the corrective action taken. We have determined that no . issues exist which would adversely affect safe plant operation. i l' ; i
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_1 i F 4 i [ ISSUE: Maintenance Shop Facilities , V INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding : ( (MA.8 2), page 15 l NNY ERSPONSE STATUS: NHY's '40 Year Facility Planning Committee' has i developed a five year plan to upgrade and improve all , maintenance and decontamination facilities. This plan. ,
~ J- has been approved for implementation by NHY's executive +
management. The implementation of this plan will .;
- c. address INPO's concerns on efficient work spaces for i the involved craft and technician personnel.
NHY has reviewed INPO Finding MA.8-2 together with the .i
,, corrective action taken. We have determined that no ;
L issues exist which would adversely affect safe plant ! operation. s h Ai e 4 I e-l . L [: L} l E M i i %'
F r b ISSUE: System Engineers INPO EEFEEENCE: INPO Evaluation of Seabrook Station, November 1987. Finding (TS.I.1), page 16 NHY RESPONSE STATUS: Guidance and direction for the system engineers are
! continually provided, as explicitly defined in procedures and programs the engineers implement.
Active management involvement in daily. activities, in addition to departmental _ training, working sessions, memos and management review of work provides guidance and management expectations. The remarks received from
- interviews with the engineers, which indicated a ' wide L variance in understanding of system engineer functions and responsibilities', were not of a nature which violated programs and procedures or questioned the general concept. Additional departmental training has been provided, as well as providing clearer definition in MA-3.1 ' Work Requests *, as to the role the System Engineer performs in specifying post work retests.
The Technical Staff Training Program has been developed, implemented and titled ' Plant Operations Course for Technical Staff'. This course was developed by the Curriculum Advisory Committee and the Training Group, It basically addresses three (3) levels of courses to accommodate the various levels of expertise of the System Engineers.- Level 1 is a basic one week introduction to pressurized water reactor power plants for the entry level System Engineer. Level 2 training
" is a more comprehensive six week (half day sessions) of Seabrook Station specific system design and performance for more experienced System Engineers. Level 3 training is a more comprehensiva training course that teaches control functions, operating characteristics and integrated system functions. This course is given to the more senior System Engineers.
l-l NHY has reviewed INPO Finding TS.1-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant L operation. 1' o
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c 4 ISSUE: Temporary Hodifications INPO REFEEENCE: INPO Evaluation of Seabrook Station, November 1987. Finding (TS.3 1), pages 16 and 17 NEY RESPONSE STATUS: Temporary modifications are controlled by the Station Maintenance Manual through Procedure MA 4.3,
' Temporary Hodification'. This procedure provides the .
instructions and guidance to station personnel on how to interface with the Control Room to assure that the on-shift Operations personnel are clearly aware of plant configuration that results from the installation of a modification of this nature. Temporary modifications are installed and removed with a work request which also requires the knowledge and authorization of the Control Room personnel. After temporary modifications are installed in the plant, the applicable Control Room drawing is annotated with the controlling modification number. When Operations must use a drawing that has been annotated in this fashion, these control numbers lead them to the description of the modification that is maintained in the Temporary Modification loc by the UES. All temporary modifications are not necessarfly sketched on to the referenced. drawing since the log provides information witn eufficient detail to determine the impact on what the Operations personnel are working on. This methodology has proven to work adequately in support of the daily operations of the plant. NHY's position is to keep the use of this type of modification to a minimum. Administrative controls require a quarterly review of temporary modifications to ensure that they are held to an absolute rdnimum. On a periodic basis the Nuclear Quality Group also audits the Temporary Hodification Program to verify compliance. NHY has reviewed INPO Finding TS.3-1 together with the l corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. l i l l l 2
l- g
. I ISSUE: Performance Monitoring Program i
INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding I (TS.5-1), page 17 , NHY RESPONSE STATUS: The Technical Support Performance Monitoring Program includes the following types of activities:
- Inservice Testing / Surveillance Testing Systems and Components .
+ System / component Parameter Monitoring l
- Predictive Maintenance Corrective / Preventative Maintenance Testing
+
The program was initiated in 1987 and was first developed around equipment that was in operation during the shutdown period prior to Power Ascension Testing. During the 1987 INPO evaluation and during subsequent evaluations / assist visits by INPO the Station's performance monitoring program was evaluated using standards that were developed for fully operational plants. The majerity of the performance monitoring tasks that wili be implemented by the Technical Support Group require the plant to be operating at elevated power levels. Major components such as the Main Feed l Pumps. Heater Drain Pumps, and Feedwater Heaters have ; never been operated at or near their normal operating l temperatures and flows. The INFO standards for performance monitoring are 1 primarily intended for improving the reliability and '! performance of fully opsrational nuclear power plants rather than plar.ts in prolonged cutages/ shutdowns where p' equipment is either not running or has not been [ operated in its normal operating condition. However, l it should be noted that Technical Support personnel 1 have implemented numerous performance monitoring i activities above and beyond those required by the Facility Operating License, FSAR, or even standard maintenance practices. For example, the Diesel Generator trending effort has accumulated more than two years worth of trendable data from the key performance indicators for these standby components. p Performance data has been and continues to be collec,-d i and trended in a similar manner for numerous other l components, such as the RHR, SW, PCCW, CVCS, Reactor i Coolant Pumps. Heat exchanger thermal performance monitoring and vibration monitoring efforts have been initiated on a number of components where base line l data at or near normal operating conditions could be obtained. Seabrook's innovative motor operated valve
~
S' P;rf rmanco Monit: ring Pag 3 2
-- Pr: gram (Cont'd) test program has beeh favorably noted by INPO and has been used to evaluate. valve performance on valves which are not on a commitment list. Seabrook uses, and has been developing, a number of advanced performance monitoring techniques or tools. For example, Thermography has been used to monitor Motor Control Center Temperatures. Also, state-of-the-art PC based computer technology (which is accessible to plant engineers), is used to analyze and file data as well as predict future performance.
A relatively large amount of temporary test instrumentation (above and beyond that required to complete normal startup testing), has been installed in the plant with the intent of supplementing permanent instrumentation and more closely monitoring equipment performance during initial operation. As Seabrook is a newer. plant, the Station computer has significantly more process inputs. This information is a major source of input to the Performance Files. In addition, operator log sheets are also used to obtain data where appropriate. l One example of a system for whirh a trend program had l not been started (at the time of earlier INPO visits), ! was the hydrogen gas to generator system. This was because the system had not yet been in operation since- i it is only required during power generation. When the. ' system was initially charged, hydrogen consumption was trended using data frem operator logsheets. In the first several weeks of operation, it was evident that the consumption was fairJy high, however, there was some uncertainty over how much leakage was present ; based on the different ways in which the system could 1 be operated. A more rigorous record keeping program . was established by Technical Support Engineers to I better quantify the leakage. This information was.to help in two ways: first to prioritize work to search out and repair leaks, and second to make decisions about a bulk storage facility. The enhanced monitoring program could not have reasonably been developed until the system was initially charged and operating i experience gained. In fact, the system has not yet been operated in its. normal mode. This is because the ; system temrJratures will be greater once power is generated and seal performance will be significantly. better at that time. This case is an example of how , the efforts to develop a performance program should l parallel.the-initial plant startup rather than precede it, and should be improved or modified as conditions
- change over time.
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, NHY has reviewed INPO Finding 78.5-1 together with the- 1 corrective action taken. We have determined that no-L
, issues exist which would adversely affect safe plant >
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e 5 e ISSUE: Training and Qualification INPO REFEEENCE: INPO Evaluation of Seabrook Station, November 1987, Finding (TQ.1-1), page 18 NKY RESPONSE STATUS: Following the Training System Development (TSD) process, the Training Group completed job analyses for the positions cited in the INPO recommendation. Instructors and subject matter experts from the appropriate departments participate in round-table discussions to generate a plant-specific task list for each of the positions. That process includes identification of tasks that should be covered in continuing training, as specified in items (d) and (e) of the recommendation. The Training Group works with each department to ensure that operating experience, plant modifications, and procedure changes are reviewed for training impact in a timely me.nner. Each of these items is assessed to determine whether it only requires notification of a change, or whether it requires e more formal followup, including training. In addition to specific training activities, NHY routinely identifies (veekly) and summarizes revisions l te program nanuals. - The Training Group's formal Training Development Recommendation procedure ensures that new training needs are identified quickly and training content and materials are kept up to date. This procedure establishes specific requirements for a systematic review of information that may have an impact on training programs, including those for the technical positions mentioned in the recommendation. l NHY is currently involved in the INPO accreditation process for maintenance and technical training. These j training programs include periodic _ refresher training to maintain individual qualifications. NHY has reviewed INPO finding TQ.1-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation, j i y
W! . b 9 ISSUE: Training and Qualification INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding
, (TQ.4-1), pages 18 and 19 NHY RESPONSE STATUS: Evaluation of radiation worker training and retraining at Seabrook resulted in changes designed to improve the instructor-to-student ratio, particularly during training on practical factors, such as donning and removing protective clothing.
- 1. The training schedule was redesigned to provide more classes with fewer students in each one.
- 2. Lesson plans have been revised for the practical portion of radiation worker training to include a practical factors checklist.
In addition to generic radiation worker training, NHY recognizes the value of demonstrating practical abilities in radiolegical protection and is currently sharing mockups of key plant components, such as the RCP seal, with H111 stone Unit 3. NHY plans to procure site specific mockups after commercial operation. NHY has reviewed INPO Finding TQ.4-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. I
(.' # a. h. I. ISSUE: Training and Qualification
; INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding 6-(TQ.5 1), page 19 i.
' NHY RESPONSE STATUS: The continuing Auxiliary Operator (AO) Program has been i
modified so as to provide a more specific A0 oriented F plant update. This program has since been accredited
,L through the National Nuclear Accrediting Board, L
i The continuing A0 Program includes the following I methods to provide A0s with timely updates on operating events, procedure changes and plant modifications.
- 1. Update training is a forme.1 part of each phase of A0 continuing training as it was in INPO's 1987 ,
evaluation. A0 continuing training h&D been y revised from the two one-week phases in 198/ to
, untch the shift requalification training that occurs on a six week rotating schedule. On an annual basis AO's receive one week of fire fighter requalification training included as part of the six week training cycle.
- 2. A0s continue to attend update training sessions conducted for licensed operators when the sessions cover information that is specifically applicable to the A0 position.
The Seabrook Training Group's procedure on Training Development Recommendations (TDRs) specifies a system for tracking and reviewing industry and plant operating events, plant modifications, changes to procedures, and j l othar developments that may have an impact on : training. This ensures that new training needs are identified quickly, and training content and materials are kept up to date. NHY has reviewed INPO Finding TQ.5-1 and the alleger's statement regarding this finding together with.the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. L l: ( i J;
p=- i . . , 4 ISSUE: Training and Qualification INPO
REFERENCE:
INPO Evaluation of Seabrook Station. November 1987. Finding (TQ.8 1), page 20 t NNY RESPONSE STATUS: Self critique conducted by trainees and facilitated by training instructors have been enhanced through enhancements to procedures, instructor training and actual conduct of critiques. Specific instructor training periodically reviews procedures which delineate the criteria for conducting critiques. Each e instructor subsequently has the opportunity and responsibility for facilitating self critique.sensions conducted by operations Group trainees. The operations Training Supervisor monitored one full cycle of requalification training to ensure that 6t the completion of each demonstrativa exam, a self critique was properly administered. The successful implementation of self critiques was s demonstrated during_the 1990 IEPO Evaluation and Assist visit in which the requalification program was cited by INFO for the high quality of self critiques. A key element of each critique session addresses the - clarity and adequacy of communications between Control j Room personnel. NHY has reviewed INPO Finding TQ.8-1 together with the corrective action status. We have determined that no issues exist which would adversely affect safe plant operation. f i i l t 4
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.w ISSUE: Training and Qualification
- INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding (TQ.8 2), page 20 NBY RESPONSE STATUS: An upgrade of t'.te Seabrook simulator computer memory,- capacity and '. peed was completed in 1988. The upgrade resolved.TQ.'s-2a and TQ.8-2b as well as providing the capability ;o simulate multiple plant component and system fai*.ures. A plant radio. system and Gaitronics have been installed since the end of 1988 and is also installed in tha instructor booth.- This resolves TQ.8 2c. o The Power Ascension and Low Power Test Program resulta have been compared with simulator algorithms and have shown a high degree of correlation. Control board fidelity is continually updated and verified annually by photo documentation which consists of direct comparison of the actual plant Main Control Board with the Simulator Control Board. All deviations are reviewed and approved by the Simulator Review Committee comprised of Operations and Training representatives.
-NHY has reviewed INPO Finding TQ.8-2 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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+
n k ISSUE: Radiological Protection INPO
REFERENCE:
INPO Evaluation of See'srook Station, November 1987. Finding (RP.1-1), page 22 NNY RESPONSE STATUS: NHY continually seeks improvements and enhancements to programs, pract.ces, equipment and facilities to deal with radiation a.sd contamination. The following t provide responses which indicate the completion or status of actions addressing each of the specific INPO recommendations. The two entrances into the high level waste storage i area have been addressed by DCR 86-351 and work is i complete. All damaged locks have been repaired. DCR q 88-75 was issued to add guard plates to the Waste Processing Building cage doors. This DCR was implemented in the second quarter of 1989. High sensitivity equipment for monitoring protectivo clothing has been budgeted and will be procured and made operational prior to the first refueling. In the interim, manual surveys will be conducted to monitor protective clothing. The implementation of the sensitive equipment is an enhancement to the current monitoring process. HEPA vacuum cleaners have installed locks to prevent unauthorized entry. An area has been established to control the issue and use of vacuum cleaners. HEPA ventilation units (i.e., AP-2000) have installed locks to prevent entry into the units. Tools and equipment which are designated for 'RCA Use Only' are painted with a color code (e.g., purple) indicating their intended use. NHY is tracking the procurement of a steam generator mockup on the Integrated Commitment Tracking System. This equipment is used for training personnel and is needed prior to the first refueling outage. As stated previously in Finding TQ.4-1. NHY is sharing mockups with Millstone 3. NHY has reviewed INPO Finding RP.1-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation.
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-g ISSUE: Radiological Protection INPO
REFERENCE:
INPO Evaluation of Seabrook Station November 1987. Finding (RP.2 1), page 23 . NRY RESPONSE STATUS: Since Seabrook is currently operational, RP technicians are maintaining their skills on the job and there is no , netd to send them to other facilities. The current in. place qualification program ensures technicians are qualified and maintain the necessary skills to perform. their required tasks. Health Physics Department personnel regularly attend conferences, offsite training and meet with. ; .; counterparts in the nuclear industry to incorporate the experience and good practices from other plants into Seabrook Station programs, pr3cedures and pre.ctices. I NHY has reviewed INPO Finding RP.2 1 together with the corrective action taken. We have determined that no - issues exist which would adversely affect safe plant operation. , D k k r .-. .- ,s, _ -., . _ . - ,
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l IS$UE: Radiological Protection l INPO EEFERENCE: INPO Evaluation of Seabrook Station, November 1987. Finding (RP.2-2), page 23 , NEY RESPONSE STATUS: Continuing Health Physics (HP) Technician training was implemented during the third quarter of 1989. The Curriculum Advisory Committee (CAC) for the HP technician continuing training is ensuring that annual ,
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training includes an emphasis on industry events, their !
, causes and meant.of prevention. The Health Physics .,
g Department also has a procedure _ that establishes a prioritized rest and sign program to ensure technicians b ' are familiar with procedures and their subs 6 tent . revisions. NHY has reviewsd INPO Finding RP.2-2ftogether with the i corrective accion taken. We have determined that no , issues exist which would adversely affect safe plant ' operation. , s o I l-i
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ISSUE: Solid Radioactive Waste INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding (RP.7 1), page 24 NBY RESPONSE STATUS: New Hampshire. Yankee has installed a domineralizer system to process liquid wastes. The installed evaporator system has never been used and is completely isolated. NHY has not generated spent resins that require processing. The Spent Resin Transfer System has, however, been installed and tested. When required, spent resins are transferred to a shielded storage area in the Waste Process Building where they are dewatered. NHY has a range of installed systems that can be used for packaging resins for offsite shipment and subsequent burial. These options provide Seabrook with the flexibility to respond to current and future offsite requirements. The current levels of radiation in the plant combined with using Maislin cloth have not required the use of rage or mop heads. NHY has an existing contract with a laundry service vendor to process and clean rags and mop heads. i NHY has reviewed INPO Finding RP.7-1 together with the corrective action taken. .We have determined that no issues exist which would adversely affect safe plant operation. l 1 i ll +
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l ef , ISSUE: Chemistry p>
-INPO EEFERENCE: INPO Evaluation of Seabrook Station, November 1987. Finding (CY.2 1), page 25 g NNY ERSPONSE STATUS: Training was completed for all technicians on October 14, 1988. This training was part of the annual technician requalification program and involved the use of actual radioactive spectrum from the Unit 3 Millstone initial startup and subsequent power escalation.
s- Chemistry obtained Reactor coolant System (RCS) liquid
- , 'and crud filter samples in 1988 and assigned these to h the chemistry technicians for gamma analyeis.
Chemistry technicians are currently involved in the analysis of RCS samples. The NHY Offsite Dose Calculation Manual (ODCH) requires an annual determination of instrument sensitivity. Minimum detectable activity determinations are intentionally performed with blank samples (no radiation) in order to determine the lowers level of detection which would be a function of existing background and sample. This annual process ensures that instruments retain sufficient sensitivity to meet the requirements of the OSCH.
-NHY has reviewed INPO Finding CY.2 1 together with the corrective action taken. We have determined that no issues exist which could adversely affect safe plant operation, n
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, i ISSUE:' Chemistry i
( a INPO REFEEENCE: INPO Evaluation of Seabrook Station, November 1987. Finding
+ (CY.3-2), pages 26 and 27
- NNY RESPONSE STAYUS: The ammonia table or. the computer data base has been i changed to the same units as the laboratory log sheets to eliminate errors when transferring data to the '
computer data base. The hydrazine table on the computer data base has been - changed to the same units as the laboratory log sheets to eliminate errors when transferring data to the l_ computer data base. First line supervisors worked with technicians to increase awareness of the pH/ ammonia / conductivity ! correlation. Ammonia is not a required Westinghouse , analysis in vet-layep which is the condition that the steam generators had remained, except for hot functional testing, at the time of the INPO evaluation. Subsequent operation of the plant,above MODE 5 has ; increased the department's skills in this area. Also a continuing training module has been developed and presented to working foremen, as well as chemistry technicians, to improve their skills in recognizing pH/ ammonia / conductivity correlations. The data base limits for hydrazine were revised to i reflect the correct limits. NHY has reviewed INPO Finding CY.3-2 together with the ' correr+1ve action taken. We have determined that no issues exist which could adversely affect safe plant operation. i i a
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- ISSUE: Chemistry - Layup Chemistry Control I I INPO EEFEEENCE: 'INPO Evaluation of Seabrook Station. November 1987. Finding j
-(CY.7-1). page 27
, I NEY RESPONSE STATUS: The long-term layup plan for the condenser and the condensate system is documented in the layup procedures jointly written'by the Chemistry Department and the Technical Support Group system engineers. This ,
plan was put in place following five percent testing in 1988. The developed layup plans were drawn up using l the EPRI and Westinghouse guidance. [ The maintenance electrical group and Technical Support engineers are responsible for monitoring the condenser cathodic protection system. This is performed on a weekly basis. R NHY has reviewed INPO Finding CY.7-1 together with the corrective action taken. We have determined that no issues exist which could adversely affect safe plant
- operation.
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O ISSUE: In House Operating Experience Review l
- INPO
REFERENCE:
INP0 Evaluation of Seabrook Station November 1987. Finding
,. (OE.2 1) page 28 i
l.- NHY ERSPONSE STATUS:. New Hampshire Yankee Procedure 12910 defines the
! Operating Experience Review Program (OERP). The OERP provides a method for evaluating regulatory correspondence, industry operating experience and Seabrook Station operating experiences and for , disseminating pertinent information to Station staff and other NHY personnel. The Lead Engineer - Operating.
Experience coordinates the review of both in house and industry operating experience infornation and NRC correspondences disseminates information for additional review or action and assigns due dates monitors progress in resolving items and implementing recommendations and provides periodic status. reports to management. In addition the Lead Enginear Operating Experience is responsible for reviewing Seabrook Station in-house events for their generic applicability to the industry. Appropriate information is subsequently entered on Nuclear Network. NHY has reviewed INPO Finding 02.2 1 together with the corrective action taken. We have determined that no issues exist which could adversely affect safe plant operation. i l L i ! i l h i l l l 4-0
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O d O ISSUE: In-House Operating Experience Review INPO
REFERENCE:
INPO Evaluation of Seabrook Station, November 1987. Finding (OE.2-2) pages 28 and 29 NNY RESPONSE STATUS: New Hampshire Yankee has developed and implemented an Event Evaluation and Reduction Program. This program keys off of the existing Station Information Reports process which is used to identify and track the resolution of key issues affecting plant operation. The Event Evaluation and Reduction Program consists of three separate processes: Event Evaluation, Root Cause Determination, and Event Reduction Evaluation. The SIR and each of the three processes in the Event Evaluation and Reduction Program retain provf.sions for identifying and correcting personnel errors through the Human Performance Evaluation Program that directly parallels the INPO recommended methods. As cited in the response to Finding OE.2-1, NHY provides periedic reports to management which categoriae the nature and causes of in-house and industry events. NHY has reviewed INPO Finding OE.2-2 together with the corrective action taken. We have determined that r.o , I issues exist which could adversely affect safe plant operation. l a i l i l l
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[A i . ISSUE: Industry Operating Experience Review
; INPO
REFERENCE:
INPO Evaluation of Seabrook Station. November 1987 Recommendation (OE.3 1) pages 31 and 32 NHY RESPONSE STATUS: NHY reviewed each Significant Operating Experience Report (SOER), prior to receiving the 52 low power license, for their impact on safe plant operation. NHY also conducted similar reviews for SOER impact on the !
; Power Ascension Test Program and prior to certifying readiness to receive a full power operating license. 1 Significant progress has been made since the 1987 INPO evaluation and an effective program is now in place to review and disposition SOERs. NHY has completed action on about ninety percent of the more than five hundred )
action items established in response to the SOER ! recommendations issued since the inception of this INPO program. Remaining actions represent enhancements and long-term improvements. None of these open action-items affect the safe completion of power ascension testing or subsequent plant operations. NHY has reviewed INPO Finding OE.3-1 together with the corrective action taken. We have determined that no issues exist which would adversely affect safe plant operation. t l. 1 i g
eb ISSUE: Industry Operating Experience Review INPO
REFERENCE:
INPO Evaluation of Seabrook Station November 1987 Recommendation (OE.3 2) pages 32 and 33 NHY RESPONSE STATUS: NHY Procedure 32910 identifies that the Lead Engineer ; Operating Experience is responsible for the initial
- review of INPO lluelear Network entries including Significant By (thers (80). The SO notification review .
effort started 11 February-1989. SO reviews prior to this were perforned informally by the Independent Safety Engineering Group. The SO category is typically an event that is determined to be significant. Items classified as SO tre reviewed formally by the OERP (NHY i 12910) to determine applicability and the need for conducting an evaluation. NHY evaluates each';10 item, assigns and tracks the action items as appropriate, on the Integrated Commitment Tracking System to ensure completion. t NHY has reviewed INPO Finding OE.3-2 together with the corrective action taktn. We have determined that no ' issues exist which would adversely affect safe plant operation. I P \: 7
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, May 18, 1990 a
l.[ , t i, , Enclosure 4 To NYN-90111 b. ij, 1. INPO Report on the October 1983 Construction t' Project Evaluation for Seabrook Station p . .
- 2. INPO Report on the December 1984 Construction
.: Project Evaluation for Seabrook station-
- 3. INPO Report on the November 1987 Per-operational Review and Assistance Visit to Seabrook Station i
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