ML20058E710
| ML20058E710 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/18/1993 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| References | |
| 50-443-92-99, NUDOCS 9312070135 | |
| Download: ML20058E710 (12) | |
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V NOV I 81993 4-i Docket No. 50-443 Mr. Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer i
North Atlantic Energy Service Corporation Post Of6ce Box 300 Seabrook, New Hampshire 03874 F
Dear Mr. Feigenbaum:
SUIDECT:
SEABROOK SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT NO. 50-443/92-99 This letter forwards the Seabrook SALP report (Enclosure 1) for the period March 1,1992 to August 28,1993. This SALP was conducted under the new SALP process that was
'l implemented by the NRC on July 19, 1993. The new SALP process rates licensees in four -
functional areas: Plant Operations, Maintenance, Engineering, and Plant Support. The Plant Support area includes radiological and effluent controls, chemistry, security, emergency preparedness, fire protection, and housekeeping. Overall, you continued to operate the plant safely, with generally strong management oversight and support fer all activities. We noted t
improved performance in engineering and continued strong performance in plant support.
However, performance in Plant Operations and Maintenance declined from that we had previously observed.
Noteworthy strengths in the engineering area included demonstrated good safety assessment and a strong modification program. There was continued effective management involvement and improved communications between engineering and the site organizations. Root cause analyses were thorough and timely following reactor trips and equipment failures.
I in the plant support area emergency preparedness was very strong. This was demonstrated by exercise performance and the response to the blizzard. Security and fire protection performance also continued to be strong. However, the generally well implemented
-l radiological controls program lacked comprehensive and timely corrective actions for some I
identified problems, particularly during the outage. Further, management did not resolve all radiological cor trols issues from the last SALP.
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In the maintenance area, personnel were highly trained and knowledgeable. There was an j
excellent surveillance program which identified problems and corrected them or referred i
them to engineering for further work. However, we noted that improvements in procedural adherence were overdue and clearly needed. In the latter part of the SALP period, a number of instances of inattention to detail in the control of work, particularly by the 1&C I
technicians, caused minor safety system transients and equipment failures. We recognize that
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Service Corporation you are currently evaluating the potential for a common cause for these problems. However, we are concerned that until recently management and staff appeared too ready to accept individual personnel errors as isolated events, beyond reasonable broad based preventive actions.
In the area of plant operations, operators were generally well trained and response to unplanned operational events was good. However, we note that the plant tripped seven times during the current operating cycle, a marked decrease in performance over the previous cycle, and at least three of those trips were precipitated or complicated by personnel errors.
Further, the continued, frequent occurrences of other perwmel errors by operators was in dicative of the ineffectiveness of your STAR program and management response to this issue. While your identification of the falsification of logs by auxiliary operators and a ;gressive, comprehensive and effective corrective actions, were considered to be excellent; the existence of this problem was indicative of a past breaMown in the conduct of auxiliary operator rounds vid oversight by operations management. Finally, management attention is needed to provide increased focus on trip reduction.
In conclusion, although we find you do well in performing root cause analyses for reactor trips and equipment problems, you do not appear to look broadly at personnel-related issues.
This was evident in the functional areas of radiological controls, operations and maintenance.
Further, while there appears to be good identification of problems by your staff, resolution is not always timely. The same aggressiveness that you apply to determining common causes of hardware-related problems and resolving those issues needs to be applied to personnel performance-related problems.
We have scheduled a management meeting with you, open for public observation, at the Science and Natare center on December 8,1993 at 1:00 p.m.
At that meeting, ycu should be prepared to discuss our assessment and any initiatives you plan to take to address weaknesses indicated in our evaluation.
Sincerely, C '.d 0;wl By:
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Thomas T. Martin Regional Administrator i
Enclosure:
SALP Report OFFICIAL RECORD COPY
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l Service Corporation cc w/encis:
- 11. L. Drawbride,e, Executive Director of Nuclear Production W. DiProfio, Station Manager l
R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts i
S. Woodhouse, Legislative Assistant T. Rapone, Massachusetts Executive Off:ce of Public Safety l
D. Tcfft, Administrator, Bureau of Radiological Health, State of New Hampshire j
Public Document Room (PDR)
Local Public Document Room (LPDR) l' Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (29) SALP Reports NRC Resident Inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Seabrook Service List The Chairman l
Commissioner Rogers Commissioner Remick Commissioner de Planque institute for Nuclear Power Operations i
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Service Corporation bec w/ encl (VIA E-MAIL):
J. Taylor, EDO J. Lieberman. OE W. Dean, OEDO W. Scott, NRR/RPEB A. DeAgazio, PD I-4, NRR J. Stolz, PD I-4, NRR W. Russell, f4RR bec via E-Ms':
Region I Staff (Refer to SALP Drive) bcc w/ encl:
Region I Docket Room (with concurrences)
J. Callan, NRR SALP Program Manager, DRIL, NRR (2) p
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///II/93 OFFICIAL RECORD COPY G:\\SALP-SEA.93
i SEABROOK SERVICE LISI j
Thomas Dignan, Esquire Diane Curran, Esquire i
John A. Ritscher, Esquire Harmon and Weiss l
Ropes and Gray 2001 S Street, N.W.
j One International Place Suite 430 Boston, Massachusetts 021104t 24 Washington, D.C.
20009 Mr. J. F. Opeka Regional Administrator, Region 1 Northeast Utilities U.S. Nuclear Regulatory Commission P. O. Box 270 475 Allendale Road Hartford, Connecticut 06141-0270 King of Prussia, Pennsylvania 19406 Mr. A. David Rodham, Director John P. Arnold, Attorney General Massachusetts Emergency Management Agency G. Dana Bisbee, Associate Attorney j
400 Worchester Road, Box 1496 General Framingham, Massachusetts 01701-0134 Attorney General's Office NITN: Mr. James B. Muckerheide 25 Capitol Street State Nuclear Engineer Concord, New Hampshire 03301 Robert Bachs, Esquire Mr. R. M. Kacich.
i Backus, Meyer and Solomon Northeast Utilities Service Company 116 Lowell Street P. O. Box 270 Manchester, New Hampshire 03106 Hartford, Connecticut 06141-0270 Mr. T. L. Harpster Office of the Attorney General North Atlantic Energy Service Corporation One Ashburton Place-Post Office Box 300 20th Floor i
Seabrook, New Hampshire 03874 Boston, Massachusetts 02108 Scaccast Anti-Pollution league Town of Exeter l
5 Market Street 10 Front Street Portsmouth, New Hampshire 03801 Exeter, New Hampshire 03823 Mr. David W. Graham Stephen G. Burns, Director Fuel Supply Planning Manager Office of Commission Appellate Massachusetts Municipal Wholesale Adjudication Electric Company U.S. Nuclear Regulatory Commission j
Washi gton, D.C.
20555 l
P. O. Box 426 z
Ludlow, Massachusetts 01056 i
Gerald GarGeld, Esquire Board of Selectmen Day., Berry and Howard Town of Amesbury l
City Place Town Hall Hartford, Connecticut 06103-3499 Amesbury, Massachusetts 01913
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Resident inspector Mr. Peter Brann
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U.S. Nuclear Regulatory Commission Assistant Attorney General Seabrook Nuclear Power Station State House, Station #6 Post Office Box 1149 Augusta, Maine 04333 Scabrook, New Hampshire 03874 3
Jane Spector Adjudicatory File (2) l Federal Energy Regulatory Commission Atomic Safety and Licensing Board Panel S25 North Capital Street, N.E.
Docket f
Room 8105 U.S. Nuclear Regulatory Commission -
l Washington, D.C.
20426 Washington, D.C.
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Mr. George L. Iverson, Director Mr. Jack Dolan i
New Hampshire Office of Emergency Federal Emergency Management Agency j
Management Region I State Office Park South J.W. McCormack Post Office and 9
107 Pleasant Street Courthouse Building, Room 442 j
Concord, New Hampshire 03301 Boston, Massachusetts 02109 4
Atomic Safety and Licensing Board 1
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Washington, D.C.
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SALP REPORT - SEABROOK I.
BACKGROUND The SALP Board convened on September 9,1993, to assess the nuclear safety performance of Seabrook for the period March 1,1992 to August 28,1993. The Board was conducted pursuant to NRC Management Directive (MD) 8.6 (see NRC Administrative Notice 93-02).
Board members were M. Wayne Hodges (Board Chairman), Director, Division ef Reactor Safety, NRC Region I (RI); Richard W. Cooper, Director, Division of Reactor Projects, NRC RI; Susan F. Shankman, Deputy Director, Division of Radiation Safety and Safeguards, NRC RI; and John F. Stolz, Director, Project Directorate I-4, NRC Ofnce of Nuclear Reactor Regulation. The Board developed this assessment for approval of the Region I Administrator.
The performance category ratings and the assessment functional areas used below are defined and described in NRC MD 8.6.
4 II.
PERFORMANCE ANALYSIS - PLANT OPERATIONS Plant Operations was rated as a Category 2 in the previous SALP. Management involvement and effective independent assessment resulted in very good, safe plant operation by highly trained, professional operators. The performance of operational tasks outside of the control board area of the Control Room was in need ofimprovement.
Over this SALP period, Operations management continued to provide strong support to plant operations and an appropriate focus on safety. The licensee performed thorough post-trip reviews before restarting the unit; in one case, searching four days for the root c*use of a reactor trip due to an electrical fault. Shift turnovers by operators were highly effective. In addition, the attendance of Operations Department managers at daily Shift Superintendent meetings continued to ensure the efficient integration of plant activities. This activity minimized the potential for adverse impact on plant operation. To reduce the burden of paperwork and other distractions on the operators, operations management continued to enhance the on-shift capability of operators beyond the minimum staffing required by Technical Specifications.
Early in this SALP period, the licensee identified several instances in which some auxiliary operators logged completion of plant rounds that they had not actually performed. The licensee was aggressive in taking prompt and comprehensive corrective actions to resolve the problem, including disciplinary actions, license revocations, and programmatic revisions.
The modified requalification training program was well designed and effective in bringing formerly licensed operators, whose licenses had been revoked, current with regard to plant systems, procedures, and management expectations.
Operators responded in an excellent manner to planned and unplanned operational activities, in several instances averting plant trips. The outstanding questioning attitude of licensed and non-licensed operators led to early identification of equipment problems and procedural inadequacies. Examples included an auxiliary operator who identified a pinhole leak in
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service water piping, and a licensed operator who stopped a surveillance test on refueling water storage tank level transmitters because the procedure lacked a proper plant impact
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statement.
During this SALP period, some ineffectiveness of the Operations Department manifested itself in several areas. First, licensee initiatives to reduce the frequency of personnel errors were ineffective, in that personnel errors continued throughout the S_ ALP period. Inattention to detail by operators resulted in challenges to plant equipment, missed surveillance tests, and Technical Speci6 cation violations. One of several examples that occurred in the latter part of the SALP period was an Emergency Feedwater System actuation. That actuation resulted from low steam generator level caused by a licensed operator inadvertently leaving feedwater l
isolation valves shut when executing post-trip Emergency Operating Procedures. Weak l
control of licensed operator overtime and several instances of minor weaknesses in log-keeping and con 6guration control records was further evidence of a lack of attention to detail.
by operators and management.
L Second, although Operations management did a thorough investigation of individual reactor trips to determine root cause and corrective action to prevent recurrence, seven reactor trips j
occurred in the latter half of this SALP period before the licensee decided to pursue a broad review to determine possible common causes or programmatic contributors. This review was.
ongoing at the end of the SALP period.
i Lastly, weaknesses in command and control of some evolutions implemented by operators outside of the Con 91 Room resulted in plant trips. Two notable examples inclu'ded improper restoraaon of feedwater heaters that resulted in a loss of feedwater, and inadequate coordination of primary and secondary plant manipulation at low reactor power.
In summary, Operations management continued to provide good support of plant operations and an appropriate focus on safety. The licensee was aggressive in taking prompt and comprehensive corrective actions to resolve the problem with licensed and non-licensed operator rounds. Operators responded in an excellent manner to planned and unplanned operational activities. The outstanding questioning attitude of licensed and non-licensed operators led to early identification of equipment problems. Ineffectiveness of the Operations i
Department manifested itself in areas such as personnel errors resulting from inattention to i
detail and recognition of the need to focus on reactor trip reduction.
The plant operations area is rated as a Category 2.
III.
PERFOIO1ANCE ANALYSIS - ENGINEERING I
i Engineering was rated as a category 2, improving, in the previous SALP. Feedback from independent self-assessments was used effectively. Root cause analyses were improved.
Good management involvement and controls were evident in the engineering organization.
i Timely corrective actions were taken when problems were encountered. Plant modifications
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were effectively prepared, controlled and implemented. There was excellent support for plant operations. However, engineering reviews in support of license amendment requests were not comprehensive and warranted added management attention.
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i During this SALP period, the modification program continued to be strong. Modification packages were well organized and design inputs were correctly incorporated. Safety l
evaluations were thorough, technically sound, and contained all of the information supporting the proposed modification. Installed modifications were thoroughly closed out and appropriate changes to station documents were made prior to declaring modifications j
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The capability and competence of the engineering staff represented a strength. There were
.j appropriate training and participation in industry groups. Strong engineering initiatives were noted in the development of design basis documents and the use of probabilistic risk l
assessments to minimize shutdown risk.
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l The licensee continued to demonstrate an emphasis on self-assessment, self-identification and i
root cause determinations. Examples include: 1) identification of testing and surveillance i
procedure problems; 2) inconsistencies between design documents and surveillance i
procedures; and 3) General Electric HFA relay problems. Root cause analyses were timely and thorough following reactor trips and equipment problems. Assessments were generally I
reactive rather than proactive.
There was continued evidence of effective management involvement and improved j
communications. The level of coordination between engineering and all site organizations was improved. There were no programmatic engineering weaknesses identified. Isolated examples of engineering-related deficiencies in performance included: 1) Instances where equipment problems were not aggressively pursued and resolved (dic>el generator fuel injection springs and emergency feedwater recirculation flow gage are examples) and 2) engineering failed to recognize a regulatory requirement for operating the cooling tower fans in automatic.
In summary, the capability and competence of the engineering organization were demonstrated strengths. Engineering initiatives in shutdown risk and self-assessment were noteworthy. Coordination between engineering and all site organizations was improved.
There were no programmatic weaknesses identified in engineering.
The engineering area is rated as Category 1.
IV.
PERFORMANCE ANALYSIS - MAINTENANCE Maintenance was rated as Category 2, improving, in the previous SALP. The maintenance department programs had evolved and matured as management supported improvements in the program and endorsed recommendations made by self-assessment studies. Activities were well controlled and implemented. Improvements were noted in planning, coordination and supervisory oversight. Maintenance personnel were knowledgeable and well trained.
The experience and knowledge of the maintenance staff continued to be strengths in this SALP period. Operators, maintenance technicians and technical support engineers demonstrated excellent understanding of surveillance requirements. Self-identified problems
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encountered during the performance of surveillances were corrected or appropriately turned e
over to engineering for resolution. Surveillance tests identified equipment problems and the problems were resolved with excellent interdepartmental cooperation (e.g., the "B" vital i
battery and the status indication for SB-V9). Technical support engineers were directly involved in maintenance and surveillance activities.
i Generally, there was strong control of most maintenance activities; however, errors
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continued to occur. Of concern to the NRC was the untimely and inadequate response by management and staff to the trend in personnel errors. For instance, the mechanical i
maintenance group failed to correctly label and separate and check the contents of a 55 gallon barrel, resulting in the contamination of a diesel generator jacket cooling water system with dirty fuel oil. Further, lack of administrative controls caused a missed air lock seal surveillance test after entering mode 4.
The instrumentation and control maintenance group was involved in several of the more recent examples of inattention to detail in the control of work. Examples include: 1)
Instrument and Control (I&C) maintenance personnel installed an electrical jumper without notation in the work request and without the necessary review. Subsequently, incorrect t
removal of the jumper resulted in inadvertent closure of the "A" steam generator blowdown isolation valve; 2) Insufficient details in a work package for the heater drain tank level control circuit resulted in a minor feedwater transient; 3) Improper placement of electrical jumpers caused a blown fuse; 4) Improper signoff of a work package resulted in incorrect installation of a main steam isolation valve limit switch lever pipe plug; and 5) Failure to document replacement parts differences resulted in the installation of an incorrect positioner for a steam generator atmospheric steam dump valve.
In summary, an experienced and knowledgeable maintenance staff continued to be a strer.gth and there was excellent interdepartmental cooperation. Strong control of most maintenance activities was occasionally marred by continuing personnel errors and lack of aggressive management response for these errors. Program requirements for maintenance work packages were not always followed, particularly in the I&C maintenance group during the latter portion of the evaluation period.
The maintenance area is rated as Category 2.
V. PERFOIGIANCE ANALYSIS - PLANT SUPPORT This functional area is new, representing a significant change from previous SALPs. The i
support functions, including Plant Support functional area covers all activities related to v radiological controls, emergency preparedness, security,
. y, fire protection, and housekeeping controls.
i In the previous SALP, emergency preparedness and security were rated Category 1. These ratings were based on excellent performance of and support for both programs from I
corporate and station management. Radiological controls was rated Category 2 in the last SALP period. This rating was based on generally good performance with key weaknesses
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5 identified as excessive outage overtime, weak access control to high radiation areas, weak contamination control during the outage, and weak training of radiation protection technicians.
In this SALP period, most plant support activities were conducted in an excellent manner, contributing to safe operation of the Seabrook station. All plant support functional areas benefitted from well-trained and qualified staff, facilities upgrades, and management support.
However, some long-term corrective actions that were instituted in the radiological controls program were not implemented in a timely manner.
Security and emergency preparedness responses to the blizzard of 1993 were outstanding.
l The staging of personnel and the transfer of the service water function to the cooling tower i
were conservative steps that enhanced plant safety and readiness. Security and emergency preparedness also had many other examples of superior teamwork and management support.
For example, the emerge: icy preparedness group successfully completed the turnover of responsibility for part of the emergency plan implementation from the Seabrook Off-site Response Organization to the Commonwealth of Massachusetts. Exercise performance continued to be excellent and validated the effectiveness of the turnover. In security, management oversight and support were evident in program upgrades and enhancements, such as the installation of an improved intrusion detection system and enhanced locidng mechanisms on vital area doors, both of which improved reliability and reduced spurious alarms. Furthermore, security of6cers performed alarm station functions, roving patrol duties, and compensatory measures in a meticulous manner.
Fire protecM and housekeeping received appropriate management attention and were also considered eAcellent. Two examples of excellent activities in the area of fire protection were the continued retention of dedicated fire fighters on each operating shift and installation of a new fire protection system computer, both of which provided an enhanced response capability should a fire occur.
The licensee's program to keep radiation exposure of workers as low as is reasonable achievable (ALARA) successfully met the goals set by the licensee during this SALP period.
Chemistry department personnel performed in an excellent manner and the licensee maintained excellent radioactive liquid and gaseous effluent control programs. The radiological control program benefitted from a very well qualified and professional staff, most of whom have professional certification in health physics. Furthermore, training and selection of radiation protection technicians, an area noted as weak during the last SALP, improved. Also, the problems noted in the last SALP with excessive use of overtime during l
an outage did not recur.
NRC review of radiological occurrence reports (RORs) generated from September,1992 through April,1993, found in some cases that outage related problems identified in the RORs were not addressed quickly enough to benefit outage performance, nor were they completely addressed after the outage. Several RORs detailed worker contamination due to inadequate instructions to workers or poor communications. Other inadequacies in radiological control
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practices were noted during the outage such as inadequate worker adherence to high radiation area (HRA) controls. Due to the low source term, most of the weaknesses noted during this
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i SALP period had little safety significance. However, management attention is indicated to assure that adequate corrective measures are taken as problems are identified while the plant l
is early in its operating history before the source term increases and such weaknesses may be more significant.
i In summary, the licensee's effort resulted in good radiological control performance and other wise superior plant support. Security and emergency preparedness demonstrated outstanding performance and had many examples of superior team work and management support. Fire protection and housekeeping received appropriate management attention. However, area for improvement were noted in the radiological controls program.
,j The plant support area is rated as Category I.
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