ML20043F720
| ML20043F720 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/31/1984 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML20043F709 | List: |
| References | |
| NUDOCS 9006180039 | |
| Download: ML20043F720 (50) | |
Text
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g eavus s V C' DECEMBER 1984 APR1B19g CONSTRUCTION PROJECT EVAL.UATION RESTRICTED DISTRIBUTION SEp3ROOI STADON l
.i SEABROOK STATION PUBLIC SERVICE COMPANY 0F NEW HAMPSHIRE
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INP9 pnm =ny
RESTRICTED DISTRIBUTION EVALUATION of SEABROOK STATION Construction Project Pub!!c Service Company of New Hampshire i
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I Copyright 1984 by lastitute of thseleer Pouer Operatione. All rights reserved. Not for sale.
Reproevetten of this report without the written consent of 1190 le empressly prohibited.
unestherlaed reproduction is a violation of applicable law.
The persons and ergenlastless that are furnished emples of this report should not deliver or transfer this report to any third person ulthout the prior agreement of l>PO and the member of IM l
for whom the report was written.
December 1984 6
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SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted an evaluation of the Pub!!c Service Company of New Hampshire $$NH), New Hampshire Yankee Division (NHY) l Seabrook Station construction project during the weeks of December 3 and December 10 1
j 1984. The project is located in borook, New Hampshire, approximately 30 miles north of Boston, Massachusetts.
The project has two 1,198-Mwe Westinghouse pressurized water reactors.
PURPOSE AND SCOPE INPO conducted an evaluation at the site with follow-up at the principal design office.
United Engineers and Constructors in Philadelphia, Pennsylvania to evaluate the control of design and construction processes and to identify areas needing improvement. Information was assembled from discussions, interviews, observations, and reviews of documentation.
The INPO evaluation team examined the areas of organization and admin!stration, design control, construction control, project support, training, quality, test control, maintenance, technical support, and industry operations experience. The team observed actual work i
performance and test performance.
A portion of the evaluation focused on a detailed vertical path examination through the design, construction and quality of the project, combined with a horizontal examination at several points. The team follow-up at the design office reviewed the design control, and the team at the project site examined, in some detall, the installed equipment.
INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant construction. The recommendations in each area are based on best practices, l
rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily Indicative of unsatisfactory perfor-mance.
MEsTRicTED OlsmIRftlON Copyright 1984 by lastitute of Nuclear Power Operations. All rights resoeved. Not for sole.
Reproduction of this report ulthout the written consent of 1870 ls empressly prohibited, unenthertred reprJeestlee le e vielsflon of appllteble law.
The poreans and orgenlaations that are f urnished copies of this report should not deliver or transfer this report to any third person without the pelar agreement of 1890 and the member of lleo i
for whom the report was written.
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RESTRICTED DISTRIBUTION !
SEABROOK (1954);
4 Page 2 DETERMINATION Withln the scope of this evaluation, the team found, except as indicated by the findings,1 that the systems in place to control the quality of design and construction are being imple-4 mented elfectively.
The following benefic'.al practices and accomplishments were noted:
A strong corporate commitment exists to complete the Seabrook Station project.
Personal involvement and commitment of senior managers are reflected in effective meetings, improved communications, and in holding personnel accountable for project !
goals.
The estab!!shment of a site engineering team is resulting in the definition of remaining ;
engineering work, improved communications, and in holding personnel accountable for project goals.
The control room simulator is being effectively used to check out start.up and opera ;
tions procedures and to, develop human factors improvements.
The early establishment of an experienced plant operations staff has enhanced the -
preparation of operating procedures.
Improvements were recommended in a number of areas. The following are considered to be -
among the most important:
l' In the near term, the project needs to complete a detailed 'ntegrated schedule of all ~
major milestones in sufficient detall to ensure that needed personnel and material j
resources are identifled to support schedule dates.
I Increase emphasis on training craftsmen and inspectors in site requirements. Include
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l provisions to retrain personnel as requirements change.
Ensure increased involvement of first-line supervisors in the day-to-day direction of l
work activities.
1 Strengthen the currective action program to identify problems, analyze generic issues, I
and povide timely resolutions to root causes.
Strengthen start-up and hydrostatic testing activities throu operations involvement and the routine use of procedures,gh improved staffi valve lineups, and good testing practices.
Improve the quality of preparation and review and the timely issuance of engineering change authorizations.
1 Increase emphasis in completion of systems and correction of walkdown deficiencies on a schedule to support testing.
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Page 3 In each of the areas evaluated,INPO has established Performance objectives and supporting criteria.
Findings and recommendations are listed under the Performance Objectives to i
which they pertain. Particularly noteworthy conditions that contribute to meeting Perfor-mance Objectives are identifled as Good Practices. Other findings describe conditions that detract from meeting the Performance Objectives. It would not be productive to lin as Good Practices those things that are commordy done properly in the industry since this would be of no benefit to Public Service Cr,mpany of New Hampshire, New Hampshire Yankee Division, or to INPC's other member utilities. As a result, most of the findings high!!ght conditions that need improvement.
The recommendations following each finding are irtended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and
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recommendations, the utility should, in addition te correcting or improving specific condl-tions, pursue underlying causes and issues.
As part of each construction project evaluation, the evaluation team follows up on response to previous findings, in this case those from the INPO Construction Project Evaluation Report of October 1983. Findings with response actions that are incomplete but progressing on a reasonable schedule have been carried forward in APPENDIX 1 to this report. In areas where additional improvements were needed or where response actions have not been timely, a new finding that stands on its own merit has been written. Thus, this report stands alone, and reference to the previous INPO construction project evaluation report should not be necessary. For this evaluation, there are nine new findings relating to i
previous findings and three findings carried forward in APPENDIX I.
The findings listed herein were presented to Public Service Company of New Hampshire, New Hampshire Yankee Division, management at an exit meeting on January 10, 1985.
Findings, recommendations, and responses were reviewed with Public Service Company of i
New F ampshire, New Hampshire Yankee Division management on March 7. March 14 and March 15,1985. Responses are considered satisfactory.
To follow the timely completion of the improvements included in the responses, INPO I
requests a written status by October 15, 1985.
Additionally, a final update will be requested six weeks prior to the next evaluation of the Seabrook Station construction project.
The evaluation staff appreciates the cooperation received from all levels of the Pubtle Service Company of New Hampshire, New Hampshire Yankee Divlslon.
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Page 4 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE NEW HAMPSHIRE YANKEE DIVISION Response Summary Public Service Company of New Hampshire (PSNH), New Hampshire Yankee Division has reviewed the findings and recommendations resulting from INPO's December 1984 Construction Project Evaluation of the Seabrook Project.
This evaluation identified a number of areas where improvement can be made in i
project procedures and methodology. Each INPO finding has been evaluated along with its associated recommendation. A description of the appropriate corrective action that has already been implemented or is planned for the future is provided in each attached response. A schedule for implementation of outstanding corrective action is provided with each response, i
Our review of INPO's findings has Indicated a need to enhance training on a project-wide, basis. The Project is presently developing a customized training program that wl!!
Include comprehensive supervisory, technical, and procedural training for both manual and non-manual personnel. We will request INPO's assistance in development of the training course outlines to ensure that the final program will adequately address Seabrook's needs.
The management of the Seabrook Station project wishes to express the'e appreciation to the evaluation team for their effort and dedication and to INPO for its assistance in striving for a high level of excellence in the construction of Seabrook Station.
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ORGANIZATION AND ADMINISTRATION THE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS PERFORMANCE OBJECTIVE:
The project fint-line supervisors and middle managers should perform a significant role in ensuring the quality of the project.
Finding (OA.5-1)
Some first-line supervisors need to be more involved in the daily activities of their craftsmen to ensure quality construction. On a number of occasions, quality control inspectors provided work Instructions to craftsmen in !!eu of the foremen. $1nce the foremen were not present, they were unaware of the instructions given.
Specific work activities included piping, hanger, and instrumentation and control insta!!ations.
Recommendation Improve supervisory attention to quality by strengthening the accountability of supervisors for their crew's work perfor-mance. Ensure supervisors take effective corrective action on problems identified. Consider establishing specific quality goals and objectives for supervision.
Response
Since the INPO evaluation, the fo!!owing corrective actions have been imp!*m.cated for the contractor's Instrumentation and ContM (l&C) Construction discipline:
I a.
In Janary
- 1985, all I&C craft pipefitters, supervisors, engineers, and QC inspectors received intensive trainin the Field Instrumentation Procedures, App.g onB of 10 CFR 50, weld sym i
nomenclature, and general Nuclear Quality j
Assurance Manual (NQAM) requirements, b.
In January 1985 a Lead !&C Superintendent was added to the Owners Construction Group to
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strengthen the management of the instrumentation and control effort.
In addition, the contractor appointed a new I&C Superintendent who assumed all i
of the contractor's managerial responsibility for the I&C. Department.
This action released field i
superintendents and supervisors to concentrate their efforts directly with craft activities. These changes orovide for improved supervisory attention to
,nstallation quality and direct craf t supervision, Additional field engineers were added in February c.
j 1985 to relleve the foremen and superintendents of paperwork processing, thus allow!ng the supervisors to spend more time with the journeymen in the installation process.
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In January 1985, installation crews were estab!!shed in groups to specialize in the installation of specific commodities (i.e.,
instrument tube installers proficient in tube clamping and tube connecting).
In January 1983, the polley was reemphasized that e.
all Installations be rigorously checked by field engineers before turnover to QC for final acceptance inspection.
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Additional training was performed.
Qualification and certification of pipefitters in the use of cryofit coupilngs was accomplished in January 1983.
In February 1985, the manufacturer of the stainless steel hoses conducted on-site training to teach installation techniques to craf t supervision.
One of the practices instituted to correct the condition reported is the assignment of craft personnel to QC inspectors at the time of final acceptance inspections. This practice optimites personnel utilization within the bounds of the program. Minor
,nstallation discrepancies can be corrected on the spot without the generation of unnecessary paperwork. Re poor workmanship, specification violations,petitive cases of or procedural breakdowns are properly recorded in the Nonconformance Report (NCR), In-Process inspection Report (!!R), in Process inspection Discrepancy Report (!!DR), and Corrective Action Report (CAR) systems.
Trend reports will be prepared and evaluated to ensure management involvement is attained at all levels.
The A5ME !!! plains contractor has taken the following actions in the areas of p ping and hangers a.
Additional craft supervisors have been added to the piping contractor's staff to increase the level of craf t supervision during in-process work.
j b.
By precedures, the field supervisor is directly
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responsible for the quality of work produced by the craftsmen. The site is presently reviewing training needs for supervisory personnel as well as cratt personnel to clearly establish responsibl!!ty for quality and training programs.
c.
The contractor is now staggering start times of second-shift craft suoervisors to allow cohesive t
turnover of work activLtles between first and second shift. A one-hour overlap permits the supervisors to walk down work being turned over and pass on the appropriate paperwork.
d.
When required, a shif t turnover form is included in work packages being worked on a two-shift basis.
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The form provides for Instructions from first to l
i second shift and second to first shift. It identifles problems encountered and records the foreman and field engineer involved in the work.
The shilt turnover form enhances communications between shifts and direct involvement of supervision in the
- work, First-line supervisors will perform the necessary e.
supervisory functions to ensure quality installations.
The existing progre.m. supplemented by the actions discussed above, will ensure that project first-!!ne supervisors and middle managers will perform the necessary supervisory functions to ensure quality Installations and schedule adherence.
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PageS DESIGN CONTROL DESIGN INPUTS PERFORMANCE OBJECTIVE: Inputs to the design process should be defined and controlled ovide a consistent basis for making design decisions in order to achieve a complete, to quality design.
Finding (DC.1-1)
Thermal overload trip setting criterion for engineered safety motors (class 1E) requires evaluation. The overload setting of class IE continuous duty motors connected to the MCCs is higher than the values normally used by the industry to protect the motors.
The FSAR commitment to match the overload heater characteristic curve with the motor thermallimit curve has not been done.
Recomtrwxiation Evaluate the thermal overload settings selected that are based upon the present criterion. Determine if adequate protection is -
provided for continuous duty motors. If not, review normal
,ndustry practice and implement appropriate changes.
Response
New Hampshire Yankee (NHY) has evaluated the criteria for overload protection for continuous duty motors (less than 100 hp) that are powered from motor control centers. The Seabrook design places special emphasis in the sizing of the overload 4
protection for Class IE motors, such that completion of the safety function is assured. Nulsance trips, transient overloads, and manufacturer's tolerances in heater size were taken into consideration and minimized to the extent practical.
For additional conservatism, motors have been specified to have their rated horsepower at least 5 percent above the maximum brake horsepower required.
In summary, New Hampshire Yankee concludes that the Seabrook design for overload protection of continuous duty motors is acceptable.
New Hampshire Yankee hcs reviewed the FSAR commitment regarding the comparison of the thermal overload protection curves with the manufacturer's motor thermal damage curves.
The review concludes that, for small motors (less than 100 hp),
this comparison is unnecessary, and, therefore, NHY plans to revise the FSAR accordingly.
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Page 9 DESIGN VERIFICATION PERFORMANCE OBJECTIVE: The design should include a verification process to ensure conformance with design requirernents.
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Good Practice (DC.4-1)
The project has implemented an "As Engineered" program to verify that design requirements have been appropriately defined, interpreted correctly by interfacing organizations, and provided for in the design. Calculation review teams verify assumptions and references, reconcile inconsistencies, and identify, potential problem areas requiring design evaluation to minimize impact on project schedules. Review teams such as the Safe Team for pipe-support design are established to perform site walk down reviews. Best alternative solutions are determined for installed i systems requiring additional design consideration. The program has been implemented in all design disciplines.
li i-DESIGN OUTPUT I
PERFORMANCE OBJECTIVE: Project design documents should specify complete, accurate, and clear requirements for a constructible, testable, operable, and maintair.able design.
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l Finding (DC.5-1)
Clas,tence requirements between ma}or components have not,
l been addressed. In some cases, displacement data necessary to ;
evaluate potential interactions are not available in existing i seismic test reports. For example,it could not be demonstrated that the existing.25 inch clearance between the Remote Safe i l
Shutdown Panel and Motor Control Centers would not result in,
I unacceptable interaction during seismic events.
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Recommendation Establish minimum clearance criterla between major compo-i nents to preclude seismic interactions. Identify Installed equip- !
ment that violate the criteria and resolve these violations either through additional analysis, test, or a combination thereof.
Response
Component separation criterla are addressed in Technical i Procedure TP-8 entitled " Technical Procedure for Separation j Criteria."
This procedure is presently being modified to-establish minimum clearance criterla among major components (such as I&C panels, moto. control centers, etc.) in Seismic 4 Category I buildings to preclude selsmic interaction. TP-1 will be reissued to include this acceptance criteria by May 1935.
Subsequently, deviations from this criteria will be identified and evaluated for acceptability.
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Page 10 Finding (DC.5-2)
Improvement is needed in the control of instrumentation call-bration information provided in the Standard Instrument Sche-dule (SIS). In some cases, the calibration range specified in the SIS does not agree with the value used in the approved setpoint calculation. As a result, correct instrumentation calibrations cannot be assured.
Recommendation Update the calibration range information provided in the 515 to match the source calculations. Establish necessary controls to ensure the information is updated when source calculations are revised.
Response
A program 1: being imslemented to verify those safety-related fleids of the Standarc Instrument Schedule (SIS) required to ensure startup testing and pre-operational readiness. The SIS verification will be completed by July 1985. This information will then be issued as a safety-related document in accordance with pre-established procedures.
This wi!! ensure that the l
calibration range information in the 515 matches that of the source calculations. Verified setpoint data will be provided by l
system turnover. Any changes to the SIS resulting from the i
verification or changes to the source calculations will be implemented via standard Project design change procedures.
l DESIGN CHANGES PERPORMANCE OBJECT!YE: Chanites to approved project designs should be controlled to ensure the design criteria are not vio ated.
Finding (DC.6-1)
Improvement is needed in the preparation, review, and distribu-tion of Engineering Change Authorizations (ECA). A significant percentage of ECAs reviewed contained errors such as the followings a.
Incomplete interdisciplinary review 1
b.
failure to list affected documents l
c.
failure to provide marked-up affected documents with the ECA Recommendation Conduct a technical review of a representative sample of ECAs from each discis!!ne to determine the extent of problems similar to those notec above.
Determine whether generic program changes or discipline-specific changes are required and take appropriate corrective actions. Periodically re-sample ECAs to assess the effectiveness of the corrective act!ons.
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SEABROOK (198h) l j.-
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Response
A representative sample of ECAs from each discipline w!!!'be ;
rev!ewed to determine the extent of problems similar to those discussed in this finding and to identify any appropriate corrective actions. These reviews will be completed by July 1985. Ongoing monitoring of these types of problems will be included as a :>ortion of an ECA trending program to be 4
implemented by May 1985.
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Page 12 CONSTRUCTION CONTROL MATERIAL CONTROL PERFORMANCE OBJECTIVE: Material ar.d equipment should be inspected, controlled, and maintained to eruure the final as-built condition meets design and operational requirements.
Finding (CC.3-1)
The present maintenance program does not include equipment qualification (EQ) requirements and shelf life considerations for safety-related equipment and components. Worst-case quallfled life conditions have not been extrapolated to actual plant environmental parameters, such as radiation and temperature, and equipment locations. Some spare parts with !!mited shelf life have been procured without identifying shelf life require-ments.
l Recommendation Evaluate the plant maintenance program for safety-related equipment to ensure that environmental qualification require-ments are appropriately ldentified and implemented.
Response
Environmental Qualification (EO) Program Considerations An integrated EQ task force (NHY, YAEC, and entractors) is actively working on the completion of an overal! EQ program.
Task force efforts include the following:
a' a.
the review and acceptance of the qualification documentation for all class IE equipment located in a harsh environment b.
the compliation of EQ documentation files on a j
purchase order basis c.
the identification of the worst-case quallfled life for IE equipment based on calculated environmental parameters for specific equipment locations in the station d.
the preparation of an overall EQ program manual.
the incorporation of EQ program requirements into e.
the ma ntenance program via implementing statements inserted into existing station-administrative control' programs / procedures (Design i
Control, Work Control, Procurement and Issue Control, etc.)
I EQ associated mechanical equipment tasks paralleling a., b., and i
- c. above have already been completed for the station.
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Page 13 The overall schedule of the above activities is designed to be more than 83 percent complete prior to the NRC EQ audit, which is anticipated in late 1983. The total EQ program Is scheduled for completion prior to plant commercial operation.
Preventive Maintenance Program Considerations i,
At the prtsent time, a station maintenance program has been established that is based upon the equipment manufacturer's recommendations and requirements as identified in applicable -
Instructions, maintenance
- manuals, and engineering specifications.
The Station Maintenance Program Manual includes provisions for EQ component replacement, as well as storage and shelf life t
considerations.
The safety-related technical manuals and applicable vendor requirements for both harsh and mild EQ components are reviewed and Incorporated into the appropriate storage or operating component preventative maintenance programs.
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.The project-responsible engineer / organization reviews those components that are located in a " harsh" environment to ensure compliance with the requirements stipulated in 10 CFR 30.49. -l The a>propriate parameters (temperature, pressure, radlation, humid ty, chemical spray, submergence) are asp!!ed to each component in order to determine its cuallfled ;lfe. The core load date is the initiation of the qua ified life for electrical equipment, since the safety-related components are not subjected to the barsh parameters prior to fuel loading.
However, as stipulated above, vendor documentation is also i
reviewed to determine the component preventive maintenance replacement schedule to ensure equipment operability.
In summary, shelf life !!mitations l>rovided by the vendor are I
considered along with harsh anysonment quallfled life in determining the replacement schedule for 10 CFR 30.49 related equipment.
Finding (CC.3-2)
The storage and control of ASME material by the piping con-tractor need to be improved. Some ASME pipe hanger, piping, and bolting material in outdoor storage areas exhibit large_
amounts of rust and corrosion. Some non safety material and material with obvious damage are not segregated from acceptable ASME material and do not have required hold tags.
attached.
Recommendation improve the degree of protection provided to material stored in outdoor storage areas to minimize corrosion. Initiate tighter l
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Page 14 controls on storage arear to ensure that acceptable ASME material remains segregated from non-safety and non-conforming material.
.ncrease surveillance activities of mate-rial storage conditions to identify improper storage conditions and to ensure continued effectiveness of the storage program controls.
Response
The ASME !!! piping contractor has a surveillance / monitoring j program in effect for all AWE-designated storage areas. The January 1985 ASME piping contractor inspection reports (14 i, total)
Identifled 37 unacceptable conditions, including 1
n segregation of ASME and non-ASME ltems, that are being !
resolved by appropriate construction supervision.
Since the time of the INPO evaluation, the NHY Quality Assurance (QA) Department has increased the frequency of its surveillances of areas in which the piping contractor is storirg 3
ASME materials.
A significant improvem~ent in storage I conditicns in these areas has been noted, as demonstrated by a NHY QA surveillance conducted during the last week of January 1985 in which no deficiencies were found.
In addition to the above activities, covered farm w gons are being used for storage of materials outdoors to help a!!eviate the cosmetic rusting problem. Cosmetic rust will be cleaned to 3
meet specification requirements prior to finish painting.
Surveillance by both the ASME !!! piping contractor QA and YAEC QA will continue on a regularly scheduled basis to ensure adequate materlat control in storage areas is maintained.
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f CONTROL OF CONSTRUCTION PROCESSES PERFORMANCE OBJECT!YE: The construction organization should monitor and control all construction processes to ensure that the project is completed to design requirements and that a high level of quality is achieved.
Finding (CC.4-1)
The care and protection of electrical cables need to b upgraded to ensure that cables ars not damaged. Some cables were being mishandled during installation, and others were not properly !
protected af ter installation.
t Rwommendation Initiate action to ensure that procedural requirements are understood, implemented, and enforced.
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Response
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 i
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bending and sidewall pressure !!mitations.
All cable pulling i foremen were trained and tested to FEP-504 with a minimum i acceptable score of 80 percent. A survey of cable rework during !
the months of November and December 1984 revealed that only i i percent 6f rework was due to damaged cable. Because some i rework was still occurring, all foremen received additional l instruction on the aforementioned subjects in March 1985.
1 T inding (CC.4-2)
The monitoring and control of some construction activities need T improvement. Specific problems were noted in the following 1
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areas a.
hanger erection I
b.
pipe installation c.
welding process Recommendation -
Implement in-process inspections by craft supervision to ensure.
that construction is performed in accordance with procedures and quality requirements. Hold fleid supervision responsible for ;
the quality of work produced by the craftsmen.
Monitor !
construction activities to ensure that quality and project i objectives are met.
Response
Since the INPO evaluation, the following corrective actions have :
been implemented for the ASME 111 piping construction ;
disciplines i
a.
Additional craft supervisors have been added to the piping contractor's staff to increase that level of craf t supervision during in-process work, b.
By procedures, the fletd supervisor is directly responsible for the quality of work produced by the ;
craftsmen. The site is presently reviewing training needs for supervisory personnel as well as craf t.
personnel to clearly establish. responsibility: fori quality and training programs.
c.
The contractor is now staggering start ' times of second-shift craft supervisors to allow cohesive :
turnover of work activities between first and second shift. A one-hour overlap permits the supervisors to walk down work being turned over and pass on the appropriate paperwork.
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Page 16 d.
When required, a shift turnover form is included in work packages being _ worked on a two-shift basis.
The form provides for instructions from first to second shif t and second to first shift. it. ldentitles.
problems encountered and records the foreman and field engineer involved in the work. - The shif t turnover form enhances communications between.
shifts and direct involvement of supervision in the i
work.
e.
Some procedures related to this finding have been or are in the process of being revised. Speelfic changes include the following:
1.
Mandatory root inspection by QC has -been eliminated and now can be performed by the welding supervisor and welder.
2.
The piping installation specification has been revised to provide more realistic construction-dimensional tolerances.
3.
The engineering specification addressing-requirements for cold pulling of pipe has been revised to allow more precise interpretation i
and implementation.
The existing program supplemented by the actions enumerated above will ensure that the first-line supervisor will perform the-necessary supervisory functions to ensure quality installation in accordance with the estabilshed project procedures.
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PROJECT SUPPORT I
INDUSTRIAL SAFETY l
PERFORMANCE OBJECTIVE: The construction site industrial safety program should -
achieve a high degree of personnel safety.
Finding (PS.1-1)
More aggressive management actions are needed to ensure that-the site industrial safety program is fully implemented. Some-areas are not receiving proper safety and fire protection cover-age.
Recommendation increase management emphasis on implementation of the indus--
trial safety program.
Initiate appropriate actions to' ensure safety personnel provide adequate site coverage.
Response
A Seabrook Project Safety Committee was established in January 1985. The committee's goals and objectives will be as fo!!ows:
a.
Ensure that present safety programs are being 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. discip!! nary actions for safety violations; the need for stronger disciplinary actions will be evaluated.
The program will complement an already stringent campaign toward protection rules, hard-hat utilization, safety belt use, grinder shield usage, elimination of tripping hazards, and danger tagging programs, thereby asserting the project's dedication to a
" safety first' approach to industrial safety practices.
I The first Project Safety Committee meeting was held January L
30, 1985.
Subsequent meetings will be neld on a regular l
scheduled basis. One of the actions taken by the committee was to establish regularly scheduled safety meetings with craft o
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. foremen. The first foremen meeting was held February 6,1985, L
during which the project safety rules were reviewed.
Subsequent meetings will identify other project safety problems and implementation of corrective measures. The emphasis will.
be on accident prevention.
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PROJECT PLANNING -
PERFORMANCE OBJECTIVE: Project plans should ensure completion of the project to the highest industry standards by identifying, interrelating, sequencing, and implementing the l tasks of the project organizations.
Finding (PS.2-1)
Development and implementation of the overall project schedule l remains to be completed. Some detailed level !!! schedules need '
to be completed and integrated to properly access the following a.
Impact u >on major milestones in the level I and level I
il schedu,es I
b.
time phased manloading of the remaining project work projected needs for the various support requirements c.
Recommendations Continue to develop the detailed project schedules on an urgent ;
basis. Ensure that all major work activities are integrated into the schedule such as engineering, major rework, walk-downs, hanger verification (NRC IE Bulletin 79-14) inspections, verifications / review of paperwork, testing and building / room close out.
Response
Detailed schedule levels currently exist defining work activities for the workforce levels anticipated through May 1985. The detalled schedule development process has been recently accelerated to increase the lead t.me. It is the intention that i
detailed schedules will be developed three to six months ahead -
of the anticipated construction manpower assignment.
I While the construction detailed activities are developed on a priority basis in support of the critical path, it should be noted.
that all startup and engineering logic has been established-in detall.
Efforts currently-are nearing completion that consolidate the engineering logic into the common Project 2 network processing. This transition will allow fully integrated I
(i.e.,
engineering, construction, and startup) critical path.
i analysis (CPM) type schedule analyses and reporting.
4 The detailed 8.hedule system will be utilized to manage the b
completion os all remaining construction work scope. Schedules will be developed to specifically identify-not only system completion, but commodity-type activities such 'as insulation, cable tray bracing, penetration sealants, building completions, etc.
In addition, it is noted that execution of the detailed schedule work activities is assisted through the Project Completion System program (Level 4) management and will be assisted in the future by a new production planning function (Level 5) (i.e.,
three-week production schedule) currently being established.
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I' DOCUMENTATION MANAGEMENT.
L PERFORMANCE OBJECTIVE: The management of project documentation should support the effective control and coordination of project activities and provide a strong foundation l
for the documentation /information requirements of the plant's operational phase.
Finding (PS.6-1)
The control of ~ documents used by start-up personnel needs improvement. Some drawings and documents used by start-up wrsonnel for performing tests are not controlled and are not the t
- atest revision.
i Recommendation implement improved controls to ensure that drawings and i
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documents used by start-up personnel during the conduct of testing activities are the current revision. Perform follow-up reviews in this area to ensure effective corrective action.
Response
Startup Administration Instructions, " Control of Drawings," will be revised to improve controls for the notification and issue of drawing revisions to Startup Test Engineers (STE). STEs will be notified of drawing revisions and will be required to acknowledge that a drawing previously issued to him has been revised. "he latest revision will then be issued if requested.
These drawing control changes should be fully implemented by 1
May 1985.
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TRAINING l\\
GENERAL TRAINING AND QUALIFICATION l
PERFORMANCE OBJECTIVE: The training program should ensure that all employees receive indoctrination and training required to perform effectively and that employees are quallfled as appropriate to their assigned responsibilities.
Finding (TN.3-1)
Improvement is needed in the training of craf tsmen and quality control (QC) inspectors. Some craf tsmen and QC inspectors are not 2ffectively trained in installation procedures and acceptance criteria.
Craftsmen are allowed to work on site prior to receiving safety training.
Recommendation Develop and implement training methods to ensure that crafts-men and QC inspectors are knowledgeable concerning proce-dures and acceptance criteria.
Implement a monitoring and feedback mechanism to assure management that requirements are being met. Hold first-!!ne supervision accountable for the knowledge level and quality level of work of their subordinates, implement administrative controls to ensure that craf tsmen are not assigned work prior to receiving site-specific safety j
training.
Response
The need for procedural and acceptance criteria training for craftsmen will be addressed in the revised Orientation Program for new employeest The procedural end acceptance criteria training will be predetermined per craft function via a training needs matrix. The training-format will be prescribed by the Construction Site Training group. This program is first priority in the development of craft training. Initial implementation is planned for April 1985. Retrofitting a!! present craftsmen to this program should be complete by June 1985.
Procedural and acceptance criterla training for QC personnel will be predetermined by }ob function via a training needs matrix and will be implemented during April 1985. The training format will be prescribed by the Construction-Site Training i
group. Required refresher training will be completed by June 1985.
The existing training procedure (ASP-8) will be revised by April 1985, and will Include a monitoring and feedback mechanism to ensure that desired results are attained and supervisory accountability is established.
First-line supervisor accountability for the knowledge level and quality level of subordinates' work will be strongly emphasized in a general foreman / foreman training program, which is expected to be developed and implemented by April 1985.
Administrative controls to ensure that the craf tsmen receive safety training on a timely basis will be included in the revision o
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h of the training procedure (ASP-8). Safety trainin integral part of the Employee Orientation Program. g *,ill be a The Site Training Administrator has developed the scope and implementation plans for a completely revised construction site t
training program.
The revised training program will be implemented by June 1985.
NHY, with out:Ide consulting assistance, will design, develop, and monitor the programs to address the above mentioned actions, as well as the necessary training to meet the project.
schedule milestones.
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Page 22 QUALITY PROGRAM IMPLEMENTATION PERFORMANCE OBJECTIVE: Quality assurance and quality control functions should be performed in a manner to support and control the quality of the project activities.
t Finding (QP.2-1)
Identification of dimensional deficiencies in the construction of -
pipe supports needs to be more timely. The current practices of QC and field engineering do not identify dimensional deficien-cles until af ter pipe supports have been completed. As a result, numerous dimensional problems are not identified until the.as-built walkdowns.
Recommendation Revise pl:m support inspection procedures to include dimensional and conf..guration checks during fit-up and final weld inspec-tions.
Response
The majority of pipe support dimensional deficiencies being i
identified during the as-built walk-downs relate to gap dimensions between the pipe and support members. These result
~from shrinkage / warpage of support components and the piping p
system during the welding process and would not be identified during in-process dimensional checks. Correct gap dimensions are achieved by shimming as permitted by project specifications.
A project rework study was performed in order to identify the 1
root cause of rework.
The study concluded that the major portion of rework was related to small bore pipe installation.
tolerance. In an effort to minimize rework, the installation tolerances for small bore pipe has been substantially modified.-
I Additionally,. Technical Procedure 26, "As-Constructed Requirements for Pipe Systems," has been revised to provide a more concise mechanism of taking piping and pipe support as--
built information.
Presently, the ASME !!! contractor as-builds the piping and pipe supports immediately following installation.
Prompt -
identification of dimensional, deficiencies minimizes the impact on the project schedule. The engineering stress reconcillation effort and piping walkdowns required by IE Bulletin 79-14 have been accelerated and are expected to start in April 1985. This approach will ensure that installation deviations are identified early and reconelled accordingly, thereby minimizing the impact on the project milestones.
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Page 23 QUAL.ITY INSPECTIONS PERFORMANCE OBJECTIVE: Quality inspections should be performed in a manner that ensures optimum monitoring of project activities.
Finding (QP.3-1)
Quality control inspection hold-points are not adhered to by all craftsmen and Inspectors.
The hold-point programs are not always understood by all craftsmen and quality control inspec-tors.
Recommendation Provide a more consistent methodology for annotating hold points in weld process sheets.. Provide clear and consistent.
procedural guldance as to the meaning and requirements of hold points, and provide training to both QC inspectors and craf tsmen to ensure their understanding of the hold point program requirements.
Response
The symbol H Indicates a QC hold point on the weld process control sheets and is well understood by craftsmen, supervisors, and inspectors. The symbol H (H with a slash) with initial and date indicates a hold point has been deleted.
Deleted-hold points were shown on the ASME !!!' pipe contractor's process sheets several weeks prior to the INPO evaluation and may not have been fully understood by craftsmen. - QC inspectors were informed of the deleted hold point symbol.
As of January 1985, there is no question as to the meaning of a.
hold point by QC or craf t personnel, and the existing procedures are clear-in this regard. Disciplinary action is administered against any Individual bypassing designated hold points.
i In the event a hold point is inadvertently bypassed,.a non-conformance report (NCR) and a Corrective Action Report are generated. Trend analyses are performed monthly.to confirm that hold points are being adhered to by the ASME !!! piping craf tsmen and 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 is-scheduled for April 1985. The training will highlight attributes to be inspected at hold points and symbols used to identify hold points.
Finding (QP.3-2)
Some QC inspectors are not adhering to requirements of the QC
- )rocedures. Deficiencies were noted in the inspection of
,nstrumentation and controls (l&C), pipe supports, and 0 --
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RESTRICTED DISTRIBUTION SEABROOK (1984)
Page 24-Recommendation Ensure that QC inspectors understand the importance lowing all procedural requirements.
Conduct training of QCj personnel on changes to procedural requirements that affe mspection attributes.
Response
of the importance of certain procedura The content of the memorandums are highlighted below.
1 a
ASME Pipe Supports, "Matertal IdentificationLan a.
Fit-up Inspection for Support" dated December 20, i j.
1984.
j' This memorandum. provided the following !
directiom i
1.
to ensure that both pieces of materla! bel
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. Joined at fit-up inspection are identified by.1 proper markings 4
2.
4-actions to be taken if marking is not on one o i i
both pieces in order to resolve the problem b.
!&C, "Llquid Penetrant Testing" dated January 15, t
'1985.
This memorandum directed that thel, '
,1 temperature of surfaces to be examined by liquid ;
penetrant testing must be determined prior to 1
performing the test, utilizing a calibrated surface temperature indicator.
Electrical, "Use of a Sultable Weld Measuring Tool" c.
dated February 11,1985. This memorandum directed-i that a suitable weld measuring tool' (e.g., fillet gauge, six-inch scale, etc.) must be - utilized to ' '
determirA 5 cceptability of fillet welds.
In addition, all !&C, QC, and construction personnel received 1
comprehensive ' documented training in January 1985.. An electrical field procedure training seminar will be conducted in April 1985 to highli acceptance criteria.ght all QC notification po'1ts and inspection L
All QC and construction personnel involved i
i in electrical construction were required to attend this seminar.. j L
UE&C Procedure QCP-10-8, "AWS Dl.1 Safety-relsted/ Seismic i
Weld Inspection," was revised in February 1985 to clarify that L
the weld size will be measured utilizing a suitable weld measuring tool (e.g., fillet gauge, six-inch scale, etc.). -
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Changes to inspection procedures are reviewed by responsible a
4 supervisors for inspector training needs.
If the supervisor determines that training is necessary, inspectors affected by the.
change either receive formal classroom training or are required 1
[
to complete reading assignments. The supervisor determines the type of training based upon the complexity of the change. The training in either case will be documented.
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Finding (QP.3-3)
Improvements are needed in the review of quality records for -
i..
accuracy and completeness.
Areas for improvement include. l hardware to software reconcillation, non-conformance report (NCR) review, and the evaluation of non-destructive examina-tion (NDE) results.-
Recornmendation increase the statistical overview inspection of NCRs, NDE results, and hardware to software reconcillation to identify existing deficiencies.
Implement corrective actions to correct root causes of deficiencies. Enforce rev!ew of all documents i
pertaining to quality by. nf contractor documentation review groups.
Response
Level I QA review of. turnover packages now includes a l
verification that app!! cable documentation required - to substantiate field implementation of NCR disposition and NCR closure is included in the package. The project issued an Interim i
procedure change in February 1985 to incorporate this.
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requirement into QCP-17-1, " Records Review."
Appropriate personnel were trained accordingly. NHY Level Il QA review now includes a verification that applicable NCR closure t
documentation has been reviewed and is included in i
the documentation package.
4 In the area of hardware to software reconcillation, the problem relates specifically to ASME code items installed by the -
previous !&C contractor. A task force has been established to -
address and resolve any hardware / software problems.
The-effort will be conducted to support the system turnover schedule and is anticipated to be complete by 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 1&C documentation is considered to be extremely remote.
In respect to reviews of contractor RT film, the problem is -
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 corresponding film -
packages for NHY QA review immediately prior to their trans-mittal to the Records Vault. This review is performed to ensure that NHY QA has previously reviewed all film packages included -
in the transmittal. In addition, NHY began an ongoing effort in January 1985 to re-inventory all RT flim in the Records Vault by system and alpha-numeric isometric / drawing sequence. This re-inventory effort will identify any RT flim that bypassed the 3
NHY QA review prior to instituting the film transmittal review policy discussed above.
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CORRECTIVE ACTIONS 1
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PERFORMANCE OBJECTIVE: Conditions re resolved in an effective and timely manner. quiring corrections or Improvements s i
t Finding (QP.5-1) improvement is-needed in root cause analysis for changes affecting design and construction.
Reasons for engineering change authorizations (ECA) are not trended and evaluated to >
Improve design and construction processes.
I Recommendation
- i Implement a program that identifies, evaluates, and corrects the i root causes of problems that result in recurring design changes. - 1
Response
A new a
Engineering Change Authorization (ECA) trending i program is now being developed. The emphasis of the program will be identification of root causes of problems resulting in recurring design changes, as well as ECA problems. The goal of !
the new trending
- avoidable ECAs, program will be reduced rework, reduction in and. identification of engineering problems 7
Impacting construction.
This program is scheduled to be 1 implemented in May 1985.
Finding (QP.5-2)
Conditions-adverse to quality are not consistently documented '
and corrected in an effective and timely manner. Trend analysis j
' has not been performed by the constructor for seven months.
Frequently documents identifying problems do not receive - {
timely review to identify action and to correct the problems and i
root causes.
j Recommendation Continue ongoing efforts to estab!!sh a site trend analysis pro-i gram, implement a documented program to review the prime contractor's NCRs' for the identification of root causes. and' i actions to prevent recurrence. Review the various programs for documenting conditions adverse to aggressive program for the following: quality, and impleme Obtain corrective action responses from organiza-a.
tions responsible to correct conditions adverse to quality.
b.
Follow-up on responses to ensure that timely and effective action is taken to correct and prevent identified conditions.
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Response
The prime contractor's QC organization had failed to perform i
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the NCR trend analysis in accordance with their procedure. It' was recognized by the prime contractor, and a Corrective
~,
Action Request was issued. Cause was identified and corrective action was implemented. A status system has been estabilshed-that will preclude recurrence. -
i implementation of an overall site trending program commenced In November 1984 under the direction of the NHY Projec Construction Quality Assurance Manager.
All deficiencies identitled by NCRs, inspection Reports, Audit Reports,
- Surveillance Reports and other deficiency documents are-recorded on a computer input sheet daily.
Printouts are distributed monthly to the applicable QA/QC managers who analyze the data for. trends adverse to quality that require-i o
corrective action. The QA/QC managers are responsible for the followings i
a.
reporting identified trends to appropriate management within their organizations b.
obtaining action responses that address the ~ root causes and prevent recurrence of the condition verification of corrective action completion c.
The QA/QC managers submit monthly trend analysis repo-ts and -
action item follow-up reports to the NHY Trending Su 41sor,
i for QA. The construction QA Manager will evaluate tic, arts.
4 for significant trends that may impact the project as a whole.-
Due to the newness of the program, adequate time has not elapsed to evehiete its effectiveness.
It is recognized that there have been occasions when corrective action responses and/or implementation have not been-accomplished In an effective or timely: manner.
A _ recent restructuring of the Project QA Organization immediately under -
.the Project Construction QA Manager will focus attention.in this area. A formal Corrective Action Report (CAR) system.is -
now being implemented to replace the Startup. Notification Report (SNR).
Project Management issued a memorandum on R bruary 12,1985 directing all project participants to comply wnh Project QA Program requirements regarding prompt idencification and L
i correction of conditions adverse to quality. In order to ensure that this ' direction is properly implemented, the oroject QA t
organization has developed an additional correct.ve action follow-up system whereby department heads will be issued a bi-l-
weekly report of the status of open corrective action documents for which they are responsible.
Any repetitive failures to comply with co rective action requirements will be presented by the Construction QA Manager at Project Management staff meetings for resolution. It is anticipated that this additional
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TEST CONTROL l
TEST PLANNING PERFORMANCE OBJECTIVE: Testing activities should be controlled effectiv the use of detalled plans and schedules.
r Finding (TC.3-1)
The scheduling of day-to<iay testing activities ner.ds increased attention.
Detailed short-term scheduling is net used to fore-cast and monitor test progress.
Operator support needs are sometimes not known until just prior to the beginning of the test activity.
Recommendation Estab!!sh the use of a detailed schedule that shows all testing and testing-related activities on a daily basis.
This schedule t
should include support manpower requirements and be distri-buted to involved wrsonnel including test engineers.- Hold personnel accountab e for preparation for and implementation of activities shown on this schedule.
)
- Response The Startup Test Department (STD) has'intreased its attention to detailed short-term planning.
STD cerently convenes e startup schedule review meeting at least weekly. This meeti.g i
is attended by the STD manager group mangers, discir of scheduled activities.gineers res,ponsible for accc supervisors, and test en ent Testing and support activities relating to established milestones are addressed and a dynamic "TO GO" schedule is generated that incorporates the most recent knowledge and reflects current problems.
To support the increase in construction and startup activities, the p,an-of-the-day (POD). meetings have been resumed on a daily basis.
In addition, the STD nuclear steam supply system (NSSS) and balance-of-plant (BOP) groups hold daily meetings to i
lay out specific activities for that day.
All of the above meetings are attended by representatives of the affected STD t'
disciplines, as well as members of the Station Staff Technical
- Services, Maintenance and' operations groups, and Safety p
Department representatives.
Organizational Interface and t
support manpower requirements will be addressed at these j
meetings and planned as far in advance as practical.
Parallel to the above-mentioned efforts, the Startup Planning and Scheduling group is developing three-week "look-ahea2" schedules for the entire Startup logic. - These schedules will be used by the discipline supervisors to better integrate their activities with the overall startup program.
It is anticipated that these schedules will be implemented by June 1985.
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TESTING PERFORMANCE AND DOCUMENTATION PERFORMANCE OBJECTIVE: Performance and documentation of the test program should i ensure that test objectives are achieved and that test results are reviewed and documented Properly.
Finding (TC.4-1)
Some start-up testing la performed without proper controls.
Test activities such as major equipment operation, water transfers, and valve manl >ulation are performed without -
procedures. As a result of tils practice, the. systems and com-ponents under test, as well as other equipment, could-be i adversely affected.
Recommee.dation Implement guidelines to define the complexity level of Phase 'I y,
testing that regulres the use of detailed procedures and valve lineups to supplement generic test procedures.
k
Response
Startup testing activities are controlled through generic or specific proceduras as the specific nature of the test dictates.-
In addition, equipment operations and maintenance are supported by the use of vendor manuals, instiuctions, drawings, and plant operating procedures as is a>propriate to the-task being performed.- These evolutions are d.rected through a single System Test Engineer (STE) who maintains a high degree of --
knowledge and control regarding system status and technical operating requirements. A policy guideline-will be issued to earify the philosophy regarding the proper use of procedures --
and to more clearly define when detailed procedures are required. The guldelines will not only address complex tasks, but will address the use of procedures as a communications device for multiple shift operations and/or when large numbers of personnel are involved. -
This guideline will be issued by April 1985.
Finding (TC.4-2)
The program to complete integrity test (IT) packages and per-form hydrostatic tests needs strengthening.
The contractor hydro group is understaffed, inexperienced, and not effectively planning and scheduling the conduct of tests. In addition, in-sufficient priority is given to the completion of IT packages.
Recommendation Strengthen the contractor hydro group and provide sufficle'nt priority to complete IT packages as required to support the Cold Hydro Schedule. Ensure that required systems are identif. led and completed in time to support the hydrostatic testing schedule.
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Response
The program for performing hydrostatic testing was in the process of being realigned during the INPO evaluation. The ASME 111 piping contractor now has personnel dedicated to cleaning up outstanding items restraining issuance of the test packages in each of their operating groups (Fleid Engineering, <
Scheduling-of the tests is now. being coordinated with the !
Startup Department, and priorities are being established with- {
regard to project milestones. The scheduling'of this work is.
being coordinated with startup flushing and hydrostatic (hydro)-
test activltles.
Sufficient personnel including supervisors have been assigned to,
the ASME 111 piping contractor hydro test group to handle the. !
workload presently scheduled.
As.the scheduled hydro test i activities increase, additional staff will be assigned to the group.
The personnel assigned to the ASME !!! pipe contractor hydro '
test group have prior field experience in hydro test activities and are considered fully quallfled. to perform the assigned-responsibilities.
Actual testing is being performed in '
conjunction with Startup Test Department personnel, fully certifled Quality Control -Inspection-personnel, and the Authorized Nuclear Inspector, when applicable.
Finding (TC.4-3)
Site safety tagging requirements are not always followed.
Maintenance and construction personnel were observed wo on improperly isolated equipment that had been turned over to Start-up or Operations.=
i.
Recommendation Emphasize the need for all site personnel to adhere to the site safety tagging requirements. Increased management attention.
should be given to the strict enforcement = of site tagout requirements.
i
Response
Two tagging programs are currently in effect for a!! site safety tagging of equipment.
One is for equipment' under the Operation's Department jurisdiction.
The other covers '
equipment under the jur(sdiction of the Startup Test Department.
Both Construction and station personnel have been trained and reminded of the importance of adherence to and the consequences of non-adherence to the safety tagging programs.
These groups will continue to receive management emphasis in this regard. The following additional actions have been taken to 3_.o
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preclude repetition of the Station Maintenance Department personnel-related observations and safety tagging proolemst i
a.
Station Maintenance Department personnel have been directed to use their own tags for work'on equipment _ under the. jurisdiction of the Startup Safety Tagging Program.
This action will ensure
.that Station Maintenance personnel are cognizant of
. proper tags.
Any exceptions to this directive
{
requires a Station Maintenance supervisor's approval.
b.
. Additional Station Maintenance Department i
personnel are being quallfled for the Startup Tagging Program.
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c.
been instructed to periodicall
. for violations or deficiencies. y check tagging orders.
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.i Good Practice (TC.4-4) The use of the. Seabrook simulator to check some ' pre.
operational test procedures and to brief operators is effective in upgrading the test procedures, checking simulator performance, i
and training test engineers. At present,18 test personnel have validated 32 test procedures. As a result, some simulator and procedure problems were corrected, some procedures were changed to suit control room arrangement, and inconsistencies.
between FSAR commitments and plant design w'ere discovered.-
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OPERATIONS i
CONDUCT OF OPERATIONS PERFORMANCE OBJECTIVE: Operational activities should be conducted in a manner that
- achieves safe and reliable plant operation.
E Finding (OP.2-1)
The Operations Department needs to be more involved in start-up testing activities. Communication between Start-up and the Operations Department does not ensure shift operating person-nel are aware of scheduled tests or of the personnel needed to support these tests.
Recommendation Increase the involvement of the Operations De coordination of start-up testing activities. partment in the Control room personnel should be informed in advance of all planned start-up testing and manpower requirements. Consideration should be-given to conducting pre-shift briefings to ensure operating personnel are cognizant of scheduled tests.
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Response
A number of positive actions have been taken to improve the o
1 interface and communication between the Startup : Test Department (STD) and Operations Department personnel. These g~
i include the followings Startup(NSSS) and balance-of-plant (BOP a.
system meetings to discuss activities planned for the day.
An Operations' supervisor participates in these:
meetings.
b.
Shift test directors have been instructed to brief the appropriate Operations personnel at the start of each shift.
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When performing individual preoperational or acceptance tests, the test director will brief Operations personnel involved in the test prior to the start of the shift and/or prior' to the start of the test.
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In addition, ongoing STD activities have been evaluated to verify the extent of Operations Department personnel involvement.-
Operations personnel have been heavtly committed to the operator cold license training program and to construction
~,
support. All parties agree that once these commitments are i
l met, Operations ' personnel will participate in STD testing L
activities to the maximum extent feasible.
Participation is anticipated to commence in April 1985.
Also,'it has been emphasized to the Operations personnel that the purpose of their involvement in STD activities is twofold; first, to support test activities, and second, to learn the plant systems.
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Finding (OP.2-2)
Auxiliary operator (AO) adherence to procedures needs improvement. Instances were noted where operating procedures-were not followed or were not used to guide operating activities.
Recommendation Emphasize to Aos the need to use operating procedures and to =
adhere to procedure requirements.
In addition, Operations Deartment supervisors should. periodically monitor AO acti-vit,es with emphasis on procedure usage and adherence.
Response
Auxillary operators have been verba!!y reminded, in weekly meetings with the Assistant Operctions Manager, of the need for using procedures and for adherence to procedure requirements.
Operations Department supervisors have been instructed, by department memorandum, to periodically monitor the auxillary operator's use of procedures and to validate procedures during-equipment and system testing in conjunction with the Startup Test Department.
The Plant Manager and the Operations Manager will monitor the actions taken and evaluate the,
offactiveness by May 1985.
1 OPERATOR KNOWLEDGE AND PERFORMANCE PERFORMANCE OBJECTIVE: Operator knowledge and performance should support safe and reliable plant operation.
-1 Finding (OP.4-1)
Auxillary operator (AO) knowledge of some plant systems needs to be improved. Several Aos were not fami!!ar with some plant equipment they operate. Formal AO qualification requirements a for individual systems and equipment have not been developed.
)
Recommendation Evaluate the current level of AO knowledge and provide appro-priate remedial training. Develop formal qualification require-ments for individual systems and equipment that Aos operate.
Ensure qualification requirements are met prior to assigning Aos operational responsibilities.
Response
in accordance with the plans being developed prior to the INPO evaluation, the auxillary operator training program has been transferred to the Licensed Training Department. A task force of Training Center staff and Operations Department staff has reviewed the INPO generic job task analysis for applicability to Seabrook ' Station.
The task force is revising the training
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Page 35 program for auxillary operators accordingly.
The revised program will include formal qualification requirements. These qualification requirements will take into' consideration' both initial training and recycle training to reduce known weaknesses. Plans are being made to recycle on-shif t operators to training as soon as possible. The Operations Department is-also developing a procedure to matrix and track tasks that an auxillary operator needs to accomplish. The matrix will be used by the shift supervisors to document demonstrated profielency.
In specific tasks and to schedule on-the-job training for areas of-noted weakness. These program revisions are scheduled to be in full effect by June 1985.-
OPERATIONS PROCEDURES AND DOCUMENTATION PERFORMANCE OBJECTIVE:
Operational procedures and - documents should provide appropriate direction and should be effectively used to support safe operation of the plant.
Finding (OP.5-1)
Uncontrolled drawings and sketches used as operator aids are located at various places throughout the plant. Administrative controls have not been established for approving, updating, or'-
verifying these documents.-
Recommendation Review all posted operator aids for continued applicability, and remove those no longer required. - Update and authorize those that need to remain posted.. Document the posting of all opera -
tor alds so an effective review for continued applicability cc.n be conducted. Posted operator aids of a procedural nature should be minimized. INPO Good Practice OP-207,'" Control of Opera-tor Aids,"could be of assistance in this effort.-
Response
Operations Department personnel have been notified that only controlled operator' aids are to be used and that uncontrolled -
information will not be allowed in the performance of duties at the station. Many uncontrolled operator aids have been removed and others are being reviewed to determine the need for their continued use.- Those aids found useful will become controlled and the others will be removed by June 1985. The importance of '
using controlled documents will be stressed to all individuals in weekly Operations Department meetings. A procedure for the-use and control of operator aids is presently under development-and will be issued for use by June 1985. The procedure will incorporate the beneficial aspects of INPO Good Practice OP-207, " Control of Operator Aids."
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OPERATIONS FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment should effectively support plant pation.
i Good Practice (OP.6-1)-
Control room Instrument faceplates are color coded to facilitate 1
operator identification of a parameter within an instrumentation l
cluster. Specific colored faceplates are used to identify level, pressure, temperature, or flow instruments.
This practice i
allows the monitored parameter to be readily identified from a distance.
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MAINTENANCE PREVENTIVE MAINTENANCE PERFORMANCE OBJECTIVE:
Preventive maintenance should contribute to optimum performance and reliability of plant equipment.
Finding (MA.5-1)
The preservation of station equipment needs improvement.-
Safety-related and important balance-of-plant equipment is not protected from degradation from ongoing construction work.
Recommendation Upgrade the existing construction and start-up preservation programs to provide increased protection for plant equipment.
Improve the directions given to construction and start-up-personnel for protection of equipment. Ensure that installed equipment remains protected during testing activities. Provide a mechanism that will allow for prompt action to correct defi-ciencies.
Construction' and start-up management and=
supervision should periodically monitor protection measures..
Response
The existing protective and preventive maintenance program has been reviewed in order to ensure the operability and reliabl!!ty.
of plant equipment.
As a result, the project is providing additional personnel to
)erform required preventive maintenance functions in a t.mely manner.
The Preventive Maintenance >rogram has sufficient direction and corrective action procecures in place.. Equipment under Startup Test Department (STD) jurisdiction will be adequately protected with the increased manpower assigned to the program.
Startup management and the STD preventive maintenance program supervisory personnel, which already includes senior plant staff personnel, will monitor this area through increased plant inspections.
The Construction Preventive Maintenance Supervisor is~
periodically reviewing preventive maintenance actions for compliance with vendor recommendations and-makes changes and improves directions, where necessary. Construction quality assurance will audit balance-of-plant preventive maintenance activities by April 1985. Any identified program-deficiencies will be expeditiously corrected.
RESTRICTED DISTRIBUTION SEABROOK (1984)
Page 38 MAINTENANCE FACILITIES AND EQUIPMENT j
PERFORMANCE OBJECTIVE:
Facilities and equipment should effectively support the performance of maintenance activities.
Finding (MA.8-1)
Facilities in support of various maintenance functions for an operating plant need to be improved. The present facilities do not allow for the following:
a.-
a machine shop dedicated to repair and maintenance i of radlologically clean components b.
sufficient work areas for maintenance and refur-blishment of components, as well as storage of tools i and tool boxes c.
an !&C shop of sufficient size that is outfitted whh
!&C equipment and provisions for radiological con-trols, including proper ventilation A
Recommendation Res iew existing facilities and develop.a plan to upgrade them as i
construction funds become available.
Response
a.
The Operations Maintenance Department 'has recently acquired a building that had been used as s -
construction machine shop. This building is located outside the site fence at the south end of the training annex. The building has 6,000 square feet of shop space. with an overhead door and a 3 ton 4
overhead crane. Included with the building was a small lathe, milling machite, surface grinder, and a a small drill press.
. Operations plans' to install additional fixed machinery in the near future and to use this shop to. work on radiologically clean components.
b.
The recently acquired shop discussed above has relleved the problem of adequate work area to l
maintain and refurbish components.
To provide additional space for use by the Maintenance Department and future contractors, Operations plans 4
to modify a second building that will provide another 6,000 square feet of space. The building will have overhead doors plus a 5 ton overhead crane. This o
additional building provides sufficient. space for storage and component laydown.
In addition, as buildings are turned over from construction to the operating staff, more space for storage and laydown will become available.
c.
Operations recognizes that the existing provisions for an !&C " hot side" work facility require enhancement to support the - I&C Department in performing work in the radiologically controlled
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6 RESTRICTED DISTRIBUTION
. SEABROOK (1984)
Page 39 Management is currently addressing this areas.
problem with the intent that improved facilities will be made available prior to the first refueling outage.
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Page 40 CONSTRUCTION EXPERIENCE OPERATING AND CONSTRUCTION EXPERIENCE PERFORMANCE OBJECTIVES: Industrywide and in-house design and construction ~ exper-lence, as well as operating experience, should be evaluated for applicability, and appro.-
priate actions implemented in a timely manner.
Information on in-house design -and construction exper ience should be shared with the industry.
Finding (CE.1)
The construction and operating experience programs have not been fully implemented. The following examples apply:
a.
Significant Event Reports (SERs) are not yet being analyzed except for those associated with Significant
=
Operating Experience Reports (SOERs).
i b.
A formal program for operating events has not yet been estab!!shed.
L c.
Construction experience with generic applicability is not being distributed to the industry on NUCLEAR l
NETWORK.
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Recommendation Complete implementation of the construction and operating j
experience programs. These programs should include provisions.
for the followings a.
evaluation of INPO Significant Event Reports b.
formal investigation and evaluation of plant incl-dents c.
Industry notification of significant in-house events with generic imp!! cations L
Response
CE.la l'
A program to evaluate SERs at Seabrook Station was begun, as i.
l.
scheduled, in January 1985. The program will evaluate and issue recommendations for all SERs from January 1,1983 onward. In addition, all 1982 and older SERs will be sorted to extract all items concerning Westinghouse. NSSS, review-them for.
applicability to'Seabrook, and do a complete evaluation of those.
that are nuclear safety-related. This program has an estimated completion date of September 30,1985.
l CE.lb NUREG-0737, item IC.5 requires that " Procedures for Feedback of Operating Experience to the Plant Staff" be completed and placed into effect prior to issuance of an operating license.
NHY has an FSAR commitment to meet the requirements of item IC.5 and will have approved procedures for investigation
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Page 41; o
and evaluation of plant incidents in effect prior to fuel load However, the following program for review of operating events is presently in of fect at Seabrook Stations The Operations Document Control Center (DCC) a.
Supervisor, on a daily basis, accesses NUCLEAR NETWORK and distributes new entries to the-Seabrook Station Compliance Manager for review.
b.
At the end of each week, all new entries taken from NUCLEAR NETWORK are compiled into a report i
and issued in accordance with DCC distribution lists to Seabrook Station department supervisors and managers to review for applicability to their particular area.
The Operational Engineering Supervisor and the Startup Test Department Manager also receive copies of this weekly report for review.
CE.lc It is acknowledged that the Seabrook Project has experienced-1 events that could have been of generic hterest to the Industry and should have been distributed via NUCLEAR NETWORK.= As noted in CE.lb above, Nuclear Production (Station Statf and 1
1 Starcup) has developed a program for the distribution and review i
of incoming information from NUCLEAR NETWORK. They also have developed a program for the distribution of outgoing information to the industry, via NUCLEAR NETWORK.
The project will expand the Nuclear Production program to include the QA, Engineering, Licensing, and Construction disciplines and will have the expanded program In place by May 1983.
This program will provide a mechanism for these groups to evaluate the significance and generic applicability of significant in-house events and ensure distribution of this information via NUCLEAR NETWORK.
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Page 42 OPERATING AND CONSTRUCTION EXPERIENCE REVIEW PROGRAM PERFORMANCE OBJECTIVE:
Industrywide and in-house design and construction experience, as well as operating experience, should be evaluated for applicability, and appropriate actions implemented in a timely manner. Information on in-house design and construction experience should be shared with the industry.
SOER STATUS The status of Significant Operating Experience Report (SOER) recommendations is as follows:
Number of Recommendations Action Taken 98 Satisfactory 37 Not Appilcable 58 (10 red tab)
Pending - awaiting Jecision 92 (17 red tab)
Pending - awaiting, implementation 1(0 red tab)
Needs further review St Previously evr.iuated as satistactory or not apptbele The following recommendations are pending - awaiting decision:
SOER Number Recommendation Number 81-1 1, 2 81-2 1,2,3,4,5,6 81-3 1, 2, 3 81-5 1, 2, 3, 4 81-6 2
81-17 2
82-9 7
8 2 -11 1, 2, 3, 4, 5 8 2-12 2
8 2-15 1,'2,3,4,5,6 83-2 12 83-3 1, 2, 3, 4, 5, 6, 7, 8, 9, 1 0, 11 83-5 2, 3 83-6 1, 2, 3, 4 83-8 1
83-9 7, 1 0, 11 3 4
84-4 3, 4, 5 84-5 2
84-6 3
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Page 43 3,
The following recommendations are pending awaiting implementation:
SOER Number Recommendation Numbe; 80-1 2
1 80-2 1, 2 l
81-6 la 81-9 1,2b,2c 81-10 1
81-14 2
81-13 2c, 3 81-16 2
82-1 2a, 2b, 2c, :ld 82-4 1, 2, 3 82-3 1, 4, 6 82-6 3, 3 82-7 4a,4b,4f,3 82-8 3
82-9 1, 3, 4 82-10 1,2,3,4,3,6,7 82-12 1, 3, 4, 3 8 2-13 1, 4, 3, 6, 7, 8, 11, 1 2 8 2-16 2
8F1 1, 3, 4, 6, 7, 8, 9, 14 83-2
!!,13 8)-3 7
83 7 7, 8 83-0, 4, 3, 6, 9, 10, 12 83-9 1, 2, 8, 9 84-1 2, 4 84-2 1, 2, 7, 8 84-3 1, 2, 3 84-4 1
84-3 1, 3, 4, 3 84-6 1, 3, 6 The following recommendation needs further review:
50ER Number Recommendation Number 83-9 4
An update on the status of each recommendation listed in the "pending - awaiting E
decision," "pending - awaiting implementation," or "needs further review" categories shown above is requested in the six-month follow-on response to this report. In addition, the status of each red tah SOER recommendation received subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that above, is requested.
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SEABROOK APPENDIX I g
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APPENDIX I Summary of Outstandina Response Action from Previous Evaluation (1983) 4 DESIGN INPUTS i
Finding (DC.1-1)
A more effective system is needed to ensure all dyn documents. Piping analysis work request (PAWR) packages were reviewed for soine of the safety-related fluid systems. The i
documents reviewed did not show that fluid transients were considered in the pipe stress analysis. Also, the documents did not reflect consideration for building settlement loads and J
stress-range reduction factors. The offects o! seismic accelera-tion on pipe supports have not been addressed and documented.
Corrective Action The following actions were taken:
)
a.
Those transients that are expected to happen with a reasonable frequency and have potential for signifi-cant effects were considered and are being evaluated.
4 To improve the program that ensures dynamic fluid transients are considered in the final piping design, a
)
generic list of events for fluid transient considera-tions has been formalized. Program improvements were incorporated into Project Procedure AP-31,
" Development of Pressure / Temperature Data Sheets,"in February 1984.
Further the architect-engineer (A-E) analysis will include documented verification for each system to establish which postulated transient is applicable, not ap>l1 cable, or covered by a more severe bounding condit on. Transients for which pipa stress analyses are not performed will be discussed to define system l
features that preclude the occurrences.
The associated piping analysis will be rechecked for the applicable transient offect to ensure that the im?act is within the margin of design. These actions wl 1 be completed by April 1983.
b.
Procedure DF.DP-2607,
" Computerized Piping Analysis," was revised to clarify the requirements for documenting the considerations for building settlements. The code in effect (1971 Code, Winter Addenda of '72) does not contain a specific require-ment on building settlement loads. Building settle-ments are insignificant at Seabrook because the plant foundations rest on bedrock.
Therefore, no l
changes in the Seabrook piping specification to address this condition were required.
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6 APPENDIX !
Page 2 i
Systems in PWRs generally experience less than i.
c.
7,000 cycles. Therefore, a stress-range reduction i
factor of 1.0 is used. The A-E has reviewed the systems with a potential for a high number of equivalent full temperature cycles over the expected years of service and verify the adequacy of the assumption made for the "f" value. In addition, AP.
31, " Development of Pressure / Temperature Data i
Sheets," was revised to emphasize this requirement.
d.
A sampling of 25 supports was chosen and analyzed, using criteria based on a worst-case selection of ?lpe
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size, geometry, type, location, and support
- oad condition.
The results of the analyses indicate that the effect of seismic accelerations on supports need not be considered. This is primarily due to the stiffness and frequency criteria, which provide sufficient design margin to allow for the stresses produced by these l
effects.
Therefore, the A-E does not plan any calculation retrofitting. However, the Pipe Support Design Guldelines was revised in February 1984 to specifically address these effects in future designs.
Status Fifteen of 24 safety class systems have been evaluated.
Hydraulle analyses have been complemd for five of 16 systems expected to experience hydraulle transients. Completion of the hydraulle transient analysis for remaining systems is scheduled for May 1985.
Completion of piping analysis is forecasted for i
August 1985.
Finding (DC.1-2)
The requirements for single-fallure criterion need to be con-sidered when estab!1shing the bounding design conditions for the A5ME 5ection ID pipe stress analysia.
Some minimum and maximum fluid temperature excursions resulting from single component failures exceed the values utilized in the pipe stress analysis.
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l Corrective Action The maximum temperature condition is given more emphas!s
)
l regarding single failure since this condition typleally results in 1
worst case thermal stress condition. It appears that the identi-fled inconsistencies are confined to the identification of the l
minimum rather than the maximum temperature condition.
A comprehensive review of all the systems that have the poten-J tial to be exposed to temperatures lower than the normal piping erection temperature will be performed. As part of this review, the A-E will confirm that the maximum !!uld temperature (alarm setpoint) is equal' to or less than the maximum l
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SEABROOK APPENDIX !
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l temperature utilized in the pipe stress analyses. The associated i
plw stress analyses will then be reviewed to ensure their acequacy and revised for completeness. The foregoing actions will be complete by July 1983.
AP-31, " Development of Pressure / Temperature Data Sheets,"
was revised in February 1984 to emphasize the single-failure criterion requirement.
Status This concern is !!mited to minimum temperature conditions.
]
Design changes have been proposed to reduce the range of Primary Component Cooling Water (PCCW) temperature swings to which other systems are exposed. These changes are cur-rently under management review.
Other systems will be
'/eviewed subsequent to completion of PCCW changes.
9 Finding (DC.1-3)
Some additional thermal operating modes need to be considered in the ASME !!! Pipe Stress Analysis. Use of fluid minimum temperatures in some operating modes is neither defined nor included as the bounding condition for equipment nozzle thermal displacement. Cold water injection results in pipe contraction and affects the pipe stress analyses for severa!' safety-related systems.
Corrective Action As stated in the re ponse to Finding DC.1-2, a comprehensive l
review of all the systems that have the potential to be exposed to temperatures lower than the normal piping erection tempera-ture will be performed. The associated pipe stress analyses wl!!
then be reviewed to ensure their adequacy and revised for i
completeness. These actions will be completed by July 1985.
Status Improvements in PCCW temperature control are being imposed to reduo the range of temprature swings to which systems are exposed. Other syste.ms w !! be reviewed subsequent to accep-tance of PCCW improvements. See status for DC.1-2 for addi-tional detall.
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l&I institute of RESTRICTED DISTRIBUTION El V Nuclear Power i
Operations i
1100 Cac!t 75 Pamway
$. ale 1600 1-I Allent &. 00#0r 30330 l'
T**pnene 963 M a
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Suite 1600 1100 Circle 75 Parkway h(C.
Atlanta. Georgia 30339 9-A Telephone 404 333 3300 7, g [ p,J December 18.1987
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Mr. Robert J. Harrison President and CEO Public Service Company of New Hampshire P. O. Box 330 Manches NH 03103 Dear M rrison:
This letter forwards the recommendations and good practices identified during INPO's preoperational review and assistance visit to Seabrook during the weeks of November 2, and 9,1987. The attached document is a refined version of the material presented and discussed at the exit meeting on November 24,1987.
We ask that you review this report and provide responses to the recommendations by January 30,1988. Separate responses are requested for each recommendation noted in the report. Concise statements describing your actions are desired. A general response to each of the important areas noted in the Summary section of the report is also requested.
In accordance with INPO policy, this letter and the attached report are provided only to you, if you should decide to provide copies to the NRC, or to otherwise release the report outside your organization, we request that you notify INPO in advance.
We appreciate the excellent cooperation and positive response from all levels of your organization.
Sincerely, N
ck T. Pate President ITP/ sap Attachment cci E. A. Brown G. S. Thomas D. E. Moody RECEIVED DEC 2 3 GF PRODUCr *.
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