IR 05000443/1986099
| ML20236E375 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/26/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236E244 | List: |
| References | |
| 50-443-86-99-01, 50-443-86-99-1, NUDOCS 8710290195 | |
| Download: ML20236E375 (55) | |
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U.S,; NUCLEAR REGULATORY COMMISSION.
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SYSTEMATIC ASSESSMENT OF LICENSEE' PERFORMANCE INSPECTION REPORT NUMBER 86-99 J
PUBLIC SERVICE COMPANY 0F NEW HAMPSHIRE g
SEABROOK STATION, UNIT 1 -!
ASSESSMENT PERIOD: . APRIL 1,'1986 - JULY 31, 1987
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BOARD. MEETING DATE: SEPTEMBER 17 AND.0CTOBER 2, 1987 i
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4 SUMMARY OF RESULTS I .0verall Summary:
During this assessment period, a major transition occurred as con-struction' and preoperational testing were completed, Land startup .
testing and ~ operations under the technical specifications (TS)' and: '
license conditions- commenced. Throughout this transitional period,
.the licensee's commitment.to quality, along with its safety-conscious
' attitude: 'and - management support of quality ' assurance '(QA) initia- !
-tives, has been maintained. It is noted that . some .of the functional- '
areas are being evaluated for the first time. In- certain of 'these '
areas, the station ~and its personnel may not have- been significantly i challenged due to plant conditions and license limitations. In all a, cases, assessments are made based upon program adequacy and . observed i
' performance. .However, in those areas where activities were limited,
.such performance may not be truly indicative of station response .to future, more challenging events and situations. During this assess-ment period, t.he licensee demonstrated the ability to conduct limited operations along with a state of readiness for future, more expansive
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operational activitie .
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Some transitional problems' nave been experienced during this assess- ;
merit period. Both .the programmatic and organizational interfaces :
between the Seabrook Station staff and the New Hampshire JYankee !
engineering and quality assurance ' groups required clarification. The operations QA program, while implemented properly from a compliance standpoint, did - not ' evidence. total E effectiveness with respect to causal analysis of identified operational problems or the evaluation of related generic weaknesses. Also, plant cperations and startup testing activities were somewhat negatively impacted by divergent requirements to conduct system testing and to . troubleshoot problems, while. at the time adhering to the TS and 'special conditions pre-scribed by 'the zero power license. Likewise, new reporting require-ments (e.g., licensee event reports) were exercised based primarily on legal interpretations, rather than normal operating condition The shutdown plant conditions and lack of radiological activity -did not provide the realistic bases for such notification As an example, during the one emergency event classified during this SALP period, there were interpretation problems as to whether the plant's nonradiological status warranted declaration of an Unusual Event with its attendant notifications.
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Notwithstanding these difficulties, the licensee's establishment of a new program of controls, which is operationally based, has been effective. Construction completion has resulted in quality hardware, which is being, maintained at the same leve Similarly, the licensee's approach to component problems and testing anomalies reflects the same comprehensive attitude toward corrective action that was evident during construction. Management attention to plant readiness and independent, internal review of plant performance
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While the'overall. transition from construction to. operations.has pro-ceeded in a relatively smooth manner,;the latter part of this curren assessment period pr_ovided some evidence ~of the future. problems which might be encountered. The PCCW heat exchanger problems.. discussed
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'in Section:IV.G of this report,. represent an example of the. componen degradation which may result, in part, from lack of . system; operatio This type' of concern could become even more troublesome if: Mode.- 5-
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operations -continue for a long period of time. Licensee preplanning in the areas of water chemistry control, surveillance and maintenance '
activities, which have been evaluated as ' subcategories of- the appro-priate functional areas in this SALP, will .become even more important for . equipment preservation during prolonged periods o shutdown conditions. In the past, licensee responsiveness to problematic d issues and~ NRC initiatives has been appropriately di'rected. In ~ the j future, even more aggressive and innovative corporate management b
- involvement may be necessary to sustain the same high ' level' of j performance, j B_ackground Licensee Activities Over the course of this SALP period, major changes in both the scope-and organization of plant activities occurred -- as con'struction was completed and operations commenced. On April 1, 1986.a construction work ' force. of approximately 3500 personnel was still on .' site as pre-operational testing, building turnover and . final support system in-stallation activ ties were ongoing. In the ensuing months, construc--
tion was effectively completed and the licensee filed a motion pur-suant to 10 CFR 50.57(c) before. the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testin On October 17, 1986, a1 Facility Operating License was issued for Seabrook Station Unit Specific license conditions limited activ-ities to "zero power" operation and preci aicality testing, but did allow the licensee to load fuel and conduct hot operations in Mode 3 in accordance with the Technical Specifications. Initial fuel load was conducted during the period October 22 to 29, 1986, i
Plant heat-up for the conduct of the precritical phase of hot func-tional testing (HFT) commenced on February 9,1987. Over the follow-ing six weeks, startup testing activities were in progress with the
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plant achieving normal operating temperature and pressure conditions L and with the conduct of operations in accordance with Technical o
Specifications and special license conditions. Post noticeable among
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the routine operational activities and events which occurred during i this period. were the declaration of an Unusual Event on February 11, '
1987 based upon commencement of a plant cool-down from Mode 4 to com-ply with a Technical Specification related to containment air lock !
operability; and a steam generator safety valve actuation on February 26,1987, ' as a result of emergency feedwater (EFW) system testing. The conduct of specific tests on the steam-driven EFW pump itself was one of the more significant areas of testing during HFT, because major design modifications had been implemented for this system since the previous HFT in December, 1985. Plant cool-down-from hot operations was initiated on March 19, 1987 and the plant has remained in Mode 5 through the remainder of this SALP perio Since the completion of HFT activities, the licensee has initiated )
some extensive maintenance activities. These include the inspection, .l baffle repair, and tube plugging and sleeving operations on a primary l component cooling water heat exchanger; and the inspection, l i r.i ng j configuration redesign, and - lining repair and testing on several i service water valves. As of the end of this assessment period, these repair activities were continuing with additional heat exchangers yet '{g to be inspected and additional valves yet to be reline i Completion of this maintenance, along with the associated, routine '
operational surveillance activities,- are scheduled for a November, 1987 time frame to support heat-up, initial criticality and further testing, if a low power license is issued to Seabrook, Unit 1. In anticipation of license issuance and in response to the Commission's Memorandum and Order (CLI-87-03), the licensee has committed resources to several emergency preparedness (EP) activities. In addi-tion to working with New Hampshire to improve the state emergency response plan, which is the subject of ASLB hearings scheduled to commence in October, 1987,'the licensee is formulating a utility plan with the stated capability to compensate for Massachusetts emergency ]
response functions. Submission of this plan to the NRC in September i has received priority attention along with the conduct of other j licensee EP activities required to meet the criteria provided by ;
CLI-87-03 for issuance of a low power operating licens l Inspection Activities Two NRC resident inspectors were assigned to the site during the j assessment period. The NRC inspections are summarized in Table 1 and i represent an inspection effort of 6972 hours0.0807 days <br />1.937 hours <br />0.0115 weeks <br />0.00265 months <br /> (5226 hours0.0605 days <br />1.452 hours <br />0.00864 weeks <br />0.00199 months <br /> calculated
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on an annual basis) with the total inspection hours distributed in the various functional areas, as shown in Table I Special inspections were conducted of the compatibility between the plant and the facility Technical Specifications (May, 1986); in re-sponse to the Unusual Event (February, 1987); and in three follow-up inspections of allegations raised regarding construction quality and the as-built conditions of the plant (October,1986; November, 1986;
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' and April-May, :1987). An Emergency Plan Implementation -l Apprais'al . '
follow-up kinspection was also conducted in June, 1986. Seven en-forcementoa6tions, including a Severity Level IV violation ,resulting from -. follow-up. inspection of. the Unusual Event, were issued. The violations iss'ued during this' SALP period are tabulated in. Table o It is = noted. that construction was L completed during this SALP. period-and ~ NRC inspections of the various ' technical disciplines were con--
ducted, as necessary, to examine' final- construction activities; Al-legations 'regarding construction quality were also received .during i this assessment period af ter construction of the plant- was .essen-
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tial.ly~ complete.- In order to objectively. ' address 'these allegations,'
over.1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> of additional inspection were expended to investigat the stated concerns. -Section V. A of this report' generally discusses -
the Investigation and Allegation Review conducted during this SAL ,
The: expenditure of this large inspection effort into the several con-struction disciplines and areas of as-built quality has resulted in a i reaffirmation 'of the NRC position that Seabrook Unit 1 was construc- '
ted in accordance .with its design-bases and regulatory requirement This report also discusses " Training and Qualification Effectiveness" and " Assurance i of Quality" as . separate functional areas. Although these topics, in themselves,' are assessed in the other functional- , i areas through their use as criteria, the two areas provide a synop-sis. For example, quality assurance effectiveness 'has been assessed
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on' a day-to-day basis by resident inspectors and as an integral as-pect. of specialist inspections. Although quality work is the respon-sibility of. every employee, one' of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that' influence quality,.such as involve-ment' of first-line supervision, safety committees, 'and work atti-tudes,' are discussed. in. each are ..
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7 Facility Performance Analysis Summary 1986 1987 FUNCTIONAL AREA CATEGORY CATEGORY TREND Construction Completion 1 1 Startup Testing 1 1 Plant Operations 1* 2 Radiological Controls *
l Emergency Preparedness 2 1 ;
1 Security and Safeguards *
1 Engineering Support **
2 Licensing Activities 1 1 Training and Qualification *
1 l Effectiveness 10. Assurance of Quality 1 2
- During the previous SALP period, " plant operations" was evaluated in terms of " operational readiness", which included " radiological controls",
" security and safeguards", and " training / qualification" assessments in one general functional are **During the previous SALP period, Engineering Support was not evaluated as a separate Functional Are .
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IV. PERFORMANCE ANALYSIS- Construction Completion (1349 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.132945e-4 months <br />, 19.4%) Analysis During the previous SALP assessment period, all of the construc-tion disciplines were combined under one functional a re a .
Significant NRC inspection effort, including two team inspec-
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tions and an additional NDE Van inspection, revealed adequate control over construction processes by licensee management and few hardware deficiencies. As construction was nearing com-pletion, as-built inspections by both the resident inspectors and regional specialists confirmed a high degree of plant conformance to the design bases and technical details provided by the . FSAR. A Category I rating was determined, based upon an effective construction management program with resultant evidence of quality hardware, material, components and system During this current SALP period, an assessment of construction l completion was conducted to not only evaluate the plant's as-built. quality, but also. to provide an independent review of the results of inspection effort into allegations involving the plant hardwar Several NRC inspections were conducted to re-view licensee corrective action on previous construction find-ings (e.g., open items and construction deficiency reports) and to investigate the validity of several allegations raised re-garding construction qualit The results of these inspections essentially confirmed previous assessments that Seabrook Unit 1 was constructed in accordance with regulatory requirements and licensing commitment As construction was being completed, an NRC inspection review of all unresolved items and licensee corrective action on pre-vious inspection findings was conducted to determine the readi-ness of Seabrook Unit 1 for issuance of an operating licens This review revealed both an aggressive construction management approach to the implementation of corrective measures, where necessary, and a responsiveness to NRC initiative Routine inspection results also provided evidence that the licensee's internal as-built verification programs (e.g. , the pipe support closecut task team, PAPSCOTT; and the cable tray and support qualification activities) had been implemented in a technically competent manner. Effective licensee controls of both construc-tion completion and the process of reconciling the as-built plant with the design details were noted. A strong QA involve-ment in the conclusion of construction activities and in the assurance of quality records storage and retrievability con-tinued from the previous assessment period into this SALP,
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.x An independent verification of plant quality also arose from NRC:
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followup of a number of allegations regarding the construction processes'. Because of the nature of several of. the stated -con '
' terns and the fact that .they were raised afterfconstruction wa essentially complete, the' quality of hardware and ability of the:
as-constructed system to function as . designed became the focus-of a multidisciplinary NRC inspection effort. 'The effectiveness of licenseeL programs, which had .been inspected in ' progress over the course aof construction,:was Previsited and the' qualification; 4 of. ' personnel - to ' perform safety-related~ activities . reviewe Systems.were opened and inspected;-independent measurements were l, taken;. tests 11n progress were witnessed; . and both design ? and !
-as-built construction records were reviewe This collective NRC inspection effort to investigate the tech'-
nical validity. of several allegations' did not identify. new prob-lems,r but instead confirmed .the effectiveness ~ of licensee cor- ,
rective action in response to known problem areas and provided k-additional assurance of the measure of quality that construction completi(n has receive . Conclusion-Category 1 3. -Board Recommendation None l
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B. Startup Testing (1244 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.73342e-4 months <br />, 17.8%)
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During the last assessment period, nearly 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> were ex-pended in the inspection of the preoperational test program of Seabrook Unit 1. Over that course of time, major testing was completed including the pre-core load Hot Functional Test (HFT),
the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT)
and Containment Integrated Leak Rate Test (CILRT). It was de-termined that a high level of performance had been maintained during the entire SALP period and for the majority of the pre-operational test activities. Accordingly, this functional area was given a Category 1 ratin The current assessment period provided the opportunity to assess
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not only the completion of preoperational testing, but also the conduct of fuel loading and post-core load testing, including another HFT. The completion of the preoperational test program and final closure of the remaining test exceptions proceeded smoothly with the transition into the startup test progra NRC inspection coverage of initial fuel loading, as a startup testing activity, identified a mispositioned valve in violation of operating license conditions. The programmatic deficiencies associated with this problem are described in the Plant Opera-tions section of this repor Licensee preparation of the startup testing procedures was excellont. All 56 startup test procedures were finalized in a timely manner. They were well written and received adequate reviaw and approva Industry experience and NSSS vendor review comments were properly incorporated into the procedures. Major test evolutions were verified and transient test responses were evaluated on the Seabrook site-specific simulator with the eval-uation results incorporated into the test procedure Fuel load and post-core load HFT testing activities were delib-erate and well coordinated. Adherence to procedural controls was well in evidence. The conduct of startup testing was noted to be performed by qualified personnel, who interfaced well with their operations counterparts, and with management involvement in the prompt resolution of equipment problems and test defici-encies. Test records were well prepared and maintained. Test exceptions were few and dispositioned in a technically appro-priate and thorough manne .
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One significant testing issue regarding the emergency feedwater !
(EFW) system carried over from the original HFT, as difficulties had been encountered in the conduct of the turbine driven EFW pump preoperational test. _ The steam supply system to the Terry ;
turbine was redesigned after the identification of the original '
HFT water hammer problems. An NRC zero power license condition mandated successful completion of the subject EFW testing prior to initial criticalit A specific. startup test (ST-53) was formulated te verify system modification and design adequac i During the conduct of this testing, weeping valves were observed !
to affect test conditions which necessitated the continuation of ~
testing with an abnormal valve lineup. .This unusual lineup contributed to an unexpected steam generator' safety valve actu- j ation in February, 198 It also resulted in a testing issue which remains open, since the completion of the post-core load ;
HFT and cooldown in March, 1987 has not yet provided complete !
. evidence that the EFW system functions as designed. The post-core load HFT had to be extended over an approximate six week 3 period to troubleshoot the testing problems which were identi- 1 fied. During this . time, the licensee employed a ' trial-and-adjustment iterative technique to problem solving which is more l
characteristic of a "preoperational" rather than "startup" pro- :
gra Review of the test results with a more systematic and !
analytical approach to resolution of the' problems appeared to be warranted, given that operating license conditions and technical l specifications were in effec The licensee has attempted to !
address all NRC questions on this issue and has planned conduct !
of a special test (STP-101) to verify adequacy of the normal start and operation of the EFW turbine driven pump. Thus, in general the EFW problems and how they have been handled by the l licensee validate the position that the startup testing process is functioning as intended, to identify problem areas, ef fect corrective measures, and retest as necessar I Overall, the NHY startup testing program planning and implemen- s tation have continued to provide the same level of technically competent confirmation of system and component adequacy, as was provided by the preoperational test program. Licensee manage-ment and startup personnel continue to demonstrate not only a responsiveness to NRC concerns, but also a technical determina-tion to objectively verify EFW system operabilit n
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12 Conclusion Category 1 l Board Recommendation None
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j iC.. Plant' Operations (2667 hours0.0309 days <br />0.741 hours <br />0.00441 weeks <br />0.00101 months <br />, 38.2%) l l'. . Analysis l
The operational readiness functional area was evaluated in the previousLassessment period in the areas of procedures and staff- i ing,-operator licensing, security and radiological controls. An a overall Category 1 -rating was assessed in this area based upon ,
thorough licensee planning and a high level of management atten-
- tion to the development of . procedures and' programs in- the indi-vidual areas and in the' preparation ~for a receipt of new fue .'
During this assessment period, security and radiological con- ;
trols will each be evaluated as a separate functional are Maintenance and surveillance activities have been added to the !!
Plant Operations functional area for this 'SALP evaluatio ,i During the current assessment period, core loading, pre-critical-hot functional testing (HFT), and operational controls under the t Technical Specifications provided the bases for evaluating the .;
effectiveness of the station programs and procedures,.which.had" '
been ' under development in the previous period. . Analysis of each {
area contributing to an overall assessment of plant operations '
is discussed separately belo y a) Procedures and Programs 3 The evaluation of procedural and programmatic controls weighed heavily in the assessment of plant operations since i the "zero power" license conditions limited the scope of j
. ope ra tional ' activitie s . As initially inspected by the NRC, 1 the implementation of' the independent verification program !
was determined to contain certain weaknesses which include j vague selection criteria and inconsistent application among j various station department Other programmatic- areas '
where NRC inspection identified areas of concern included 1 the equipment tagging, valve lineup and temporary modifica-tion programs. These problems were the subject of enforce-ment action on two occasions. Additionally, during startup 'l testing, a violation of the "zero power" license condition 1 concerning locked valves was identifie This violation I related directly to a deficiency in the operational con- l trols for identifying the position of locked valve The l identified program development and implementation problems '
- have required concentrated licensee effort to upgrade the affected program .
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In the area of procedure ' development, weaknesses in format,
. content-and. consistency were- first notedL by: the NRC in the operations surveillance procedures and later in plant oper-ating procedures. NHY' task- teams of experienced; operators-
'and _ test engineers were . formed. and a procedure consistency review process was initiated. NRC review of the'se licensee
. efforts revealed a significant improvement in the quality .j and accuracy of these procedure a
' Licensee initiatives and corrective measures in the above two- areas have been. responsive to both internally and i externally generated programmatic. reviews. While the time- -
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liness of response to certain' procedural concerns has been ,
questioned, management attention to the problem areas, once .i identified by' the NRC, has . been - thorough. Particularly in l the areas of independent verification and .the procedure
- consistency review, quality products have resulted once the !
~ licensee dedicated. sufficient resources to the corrective measures, b) Conduct of Operations !
Since Seabrook is not a fully operational plant, the basis '
for assessment in this sub-area is nec'essarily limite Notwithstanding the limited . scope of licensee. activities in this area, significant NRC inspection was conducted into i routine operations, response to events / transients and TS i interpretation / reportin Routine daily operation of the plant both in Mode 5, cold I shutdown, and in Modes 3 'and 4 during HFT was excellen A high degree of professionalism and competency of the con-trol room operators was in evidence throughout the perio Control room logs and records showed continuous improvement over.the period. The shift superintendents (SS) are tasked with a high level of responsibility for station operation Their judgement is routinely conservative and demonstrates a safety conscious attitud Individual control room ,
operators and shif t supervisors are vigilant and knowledge- j able and have taken a significant initiative in providing >
quality on-the-job training to licensed operator. candidates on shift. As evidenced by a review of the LERs in Table 4 of this SALP, operator error has been identified as the cause of several inadvertent engineered safety features (ESF) actuations. In one case, improper switch operation resulted in an inadvertent safety injection (SI) while a
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second SI was generated due to tagging procedural- erro
On another occasion, a switch misoperation resulted in a
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diesel generator star In two separate events, substan- .
l tial volumes of RWST water were inadvertently transferred, l
once to the containment and once to the refueling cavit While NRC review of each of these incidents has revealed
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timely corrective action on the part of the operations department, the number- of problems experienced warrants increased management attention to detail in routine, daily operations. Additional operational experience and famil-iarization with a zero power license environment reduced l
the number and frequency of such events during the latter l
part of this SALP perio During this assessment period, the operators were not severely challenged to respond to significant plant trans-ients and events, however, several minor occurrences war-rant discussio In addition to the events related to operator errors, discussed above, several other ESF actua-tions occurred. NRC evaluation of operator response in the
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control room verified effective use of procedures and
, appropriate operator judgement in restoring the unit to a
! normal configuratio Most notable of the above incidents
! were two inadvertent safety injection actuations caused by malfunctioning control switche The station response to the declaration of an Unusual Event is summarily assessed in the Emergency Preparedness section of this repor No specific technical problems related to the conduct of operations were identified as a result of this event. However, it was noted that an internal dis-agreement between members of the operations staff developed as the event progresse This disagreement, relating to event classification and notification requirements, contri-buted to the delay in reporting and therefore resulted in the issuance of a violatio Additional training and specific delegation of responsibility within the operations department were necessary to clarify operational duty roles within the Emergency Response Organizatio Some dif ficulties were initially experienced in the inter-pretation of Technical Specification (TS) limiting condi-tions for operation (LCO) and the deportability of events under 10 CFR 50.72. The most significant example was the handling of equipment and procedural problems associated with the control building air handling (CBA) system where
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eventually, a definition of C8A single train operation had to - be disseminated for generic interpretation by the sta-tion staf Presently, licensee awareness of reporting requirements and the training provided to those individuals responsible for interpreting these requirements have imprnved in the wake of the initial difficultie In another administrative area, however, the paperwork /
nonoperational workload of the Unit Shift Supervisor (USS)
continues to represent a potential problem, since .it diverts his attention from shift operations. This situa-tion has not improved significantly since initial NRC dis-cussion of the concern and merits further station manage-ment attentio With' the exception. of the potential problem related to the USS administrative burden, operations during this SALP period have been conducted safely by qualified personnel, utilizing adequate procedures and controls in accordance with the Technical Specification Certain problems attributable to inattention to detail have been experienced, but appear to have been appropriately disposi-tioned by station management. The real effectiveness of licensee corrective actions in this area can only be measured during future hot testing and operation c) Surveillance During this period the licensee implemented the Westing-house computerized TS Appraisal Program and began conduc-ting surveillanc The licensee instituted this program on an accelerated schedule in order that surveillance were performed in advance of the actual required operability re-quirements, thus enhancing the procedures and establishing baseline data. Additionally, surveillance and operating procedures were utilized as much as possible during the test program to allow additional trial usage. While a few surveillance errors have occurred, the overall surveillance program has been effectiv The licensee also established measures to strengthen this program with new initiatives involving TS log reviews and the surveillance procedure consistency review program referred' to in paragraph a)
abov The NHY Program Support Department Staff which is respon-sible for certain surveillance testing (e.g., ASME Section XI and 10 CFR 50, Appendix J) is highly competent and professional. One notable example of this was the dis-covery by surveillance test engineers of the common mode
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valve' failure on the equipment. hatch a'ir lock doors (dis- !
cussed in section IV.G-of this report). Performance of thel 1 surveillance' on the-hatch doors at that- time was in ' paral- l 1el: to, . but not directly' responsible for identification 'of:
the problem. It was '.the alertness of the surveillance J q
engineer himself that' identified the. malfunction and i eventually. led to the declaration of an Unusual Event. The "
technical support staff has also been extremely responsive to NRC questions and concerns, p
Although the plant has not conducted sustained power oper-ations, .- challenging the capabilities of the surveillance .
programs, inspection to date.which has sampled higher mode 4 operations indicates that licensee efforts in this area are effective and the programs are appropriately staffe d) Maintenance y The licensee.has reorganized the maintenance support' organ-- H
'ization, establishing separate Maintenance and. Technical Support Departments. Electrical, mechanical, and I&C func-tions 'are performed by the mai nter.ance department while !
system support is' provided by individual' system engineers who have been delegated responsibility ' for, the -separate' l systems. This organizational concept hcs provided consis-
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'tency and accountability in the maintenance chai As a- ;
result, the Maintenance / Technical Suppor t capability has ;
been significantly. strengthened. The mos . visible example '
of this was the primary component coolir gL water heat ex-changer repairs where follow-up to this m.tintenance activ-ity led,to identification of the service water valve. lining !
problems, discussed in'Section IV.G. These two jobs re-quired considerable expenditure of maintenance resources, extensive hardware disassembly and complex special process controls. There has been extensive involvement by Station Technical Support Engineers in the maintenance area. The competence of these system engineers and their supervisors is a licensee strength. Liaison between technical support and maintenance has been an effective part of the work con-trol process. The NHY maintenance organization (including I&C) continues to' demonstrate excellent maintenance tech-niques in the area of pre-staging, cleanliness, temporary support and storage and procedural adherenc .
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~ An additional licensee' strength lies in the area -o'f plan-ning and scheduling. Daily' " plan of the day" meetings are effective in the coordination of the diverse requirements of'the many station departments. The computerized planning schedule is kept current so that future planning is based on accurate data. A high degree .of management attention has been directed to the coordinationLof the support activ-ities- of various departments to meet the established'sta-~ '
tion work schedules. A recent positive initiative. involved the establishment of a new - maintenance concept whereby -
preventive and corrective maintenance periods are pre-established for each system on : a . rotating weekly basis, Station maintenance has been conducted in a highly effec -
tive manner with no maintenance-related failure or events identifie Future . plant operations will provide more significant challenges, but- the maintenance and ' repair activities conducted to date indicate well controlled efforts capable of supporting ' more complex operations.' H
Plant operations at Seabrook-have been conducted professionally, safely and conservatively. Initial weaknesses in the develop-ment of procedures and programs .have, for the most part, been-corrected. Licensee efforts in strengthening the tagging pro- 1 gram and the consistency review- of operating procedures are l ongoing. The skills and knowledge of the licensed operating j staff remains a strength and initial problems with_ inattention
~
l to. detail have been overcome. The maintenance and technical !
support organizations remain a significant asset.
< -l 2. Conclusion i Category 2 3. Board Recommendation
Licensee: Station management 'should emphasize attention to de- {
tail in the conduct of routine operations, assess the .i ef festiveness and control of operational programs and !
evaluate methods to reduce operational error E: None i i
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D. Radiological Controls (739 hours0.00855 days <br />0.205 hours <br />0.00122 weeks <br />2.811895e-4 months <br />, 10.6%) e A,
- .i % Analysis , 1'
( !
A Cate' gory I rating, as part of the Operational Readintss area, ' g'
was. provided for this area in the last assessmpt .per.f Ad based upon the observation that the licensee's operattoriab readiness in the four radiological control arets (radiation protection, q waste management,,: transportation and effluent control and ' mon-itoring) axereded that ' routinely found at similar plants at the [i same preoperational stage. This fact was attributed to a high h level of management commitment, the degree of prepla'nning and i
'
preparation, and the level of attention to detai This current assessment is based upon both an observation of ongoing plant activities and an evaluation of the programs which ^
have been established. Since radiological conditions at the
'
-j
'
plant were limited, the scope of this assessment necessarily J emphasized programmatic and operational readiness . reviews, '
rather than demonstrated implementation of radiological con-trol It was noted that while the licensee was not greatly i ,
challenged in this functional area during this assessment period, a meaningful evaluation is still pr.ssible based upon review of the limited activities (e.g., fuel road) and the con-trols in evidence during their conduct. ' Pragram areas inciqde In-Plant Radiacion Protection, Radioactive Waste Management, Ef fluent Controls,, Nonradiological Water Chemistry, and Environ-mental Monitoring, Radiation Protection During this assessment period, the licensee continued to make significant progress towards operational readiness in 4 the areas of staffing, training procedures, and equipment and instrumentation. The continued posehce of a motivated ;
and professional staff and managemeht commitment to the program were evidented by an increase in staffing level (
aimed at commercial operation. .Ine. Radiation Safety l Committee met at the required frecuency and was tracking , I and evaluating program development; implementation, main- /' I tenance, results, and outstanding action items. Formal and l timely evaluation packages on previnusly identified NRC inspector concerns demonstrated licerste responsiveness and attention to these item As a further licensee initia-tive, a supplemental HP training progre.n we developed and implemented. During this period, the 1!cer.see's principal
,
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l M' N; (corporate) health physicist and the ' licensee QA organiza-tien performed evaluations of the . health physick (HP) pro- ,
gram. The corporate review resulted in several recommenda- l
% i< tidns being evaluated as program enhancements while the QA
'
ahdit < addressed good practices in addition to the regula-
't tpy! t requirements. Both evaluations were timely- and encompassed the full scope of HP activitie f During this appraisal period, primary startup sources were l
.' installed in fuel assemblies in the fuel storage buildin ri !
.
The fuel assemblies were moved into containment hnd loaded into t.>e reactor vessel. Also, calibration of area and '
process radiation monitors and of other radiation detection i instrumentation was conducted. The licensee reported mini- l mal person-rem exposures (less than 1 man-rem for 1986 and i
for the first quarter of 1987), indicating that appropriate I';
radiological controls had been exercised over the limited activities which were conducted during this assessment gj perio I In summary, the licensee has developed an aggressive radia- !
tion protection program in preparation for commercial oper-ation. Considering the nature of the activities conducted ( to date, effective radiolo'g1 cal controls have been imple-mented. When areas for improvement have been identified by l 9 '
j either the licensee or NRC, site and corporate HP manage- q 1, ment has initiated timely and appropriate corrective ;
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' '
) t actio y, '
.,
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< Radwaste Management / Effluent Controls
!
The licensee demonstrated aggressive oversight of the i radiochemi stry program in preparing for fuel load and j responded to NRC identified concerns in a timely manne '
Regarding radioanalytical standards submitted to the !
licensee for analysis, disagreements in two samples were 2 resolved promptly, indicating a high level of radiological j chemistry s nagement involvemen The radiological j environmental monitoring program (REMP) is implemented
!. through a clearly designated program which interfaces the site and corporate groups. The scope and method of over-view audit functions were clearly state ;
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Several aspects of the' REMP program implementation 'd'ur.ing
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the preoperational, phase exceeded . regulatory requirement Although not required, the direct radiation monitoring .
environmental TLD program was found to include efforts ' to-meet. criteria for. quality' control found in USNRC' Regulatory
~ Guide 4.13 and ANSI N545. The lic'ensee also,' participates in the International -Environmental . Dosimeter Intercompar-L
.ison project. These licensee initiatives indicate a high level 'of corporate management' awareness,.- commitment ' of
'
i resources and- sensitivity to the needs of this-. progra . Procedures for effluent measurement and' control'are coupled 1 to an ' administrative procedure for surveillance for' comply-ing with- the requirements of the Technical Specification The program -for preoperational and acceptance testing: of radwaste systems was found to be effectiv Test 1excep-tions and identified weaknesses were addressed in a _ timely manne c, .Non-Radiological Water Chemistry During the assessment period, the licensee made . progress .
, in nonradiological water chemistry for monitoring para-meters' of . primary and secondary water and preoperational and acceptance test programs. . Prccedures were found to be technically sound and adequate to meet TS requirement However, an initial inspection of this area identified certain weaknesses. The licensee was unable to analyze samples' in the concentrations normally found in an opera-
"
ting reactor. Also, the inadequate calibration of instru-ments was noted. Follow-up inspection in these areas found considerable improv" ants in the sample analysis and
'
quality control in ins leh was upgraded. Again the~11cen-see management demonstrated ti volver snt in the program and responsiveness to inspection recommendation Review of the water chemistry control program indicated a clearly defined policy, competent organization, effective-administrative procedures and adequate resources for imple-mentatio Based in part upo a study done by the station "
chemistry department, the licensee continues to explore additional enhancement options to the present program pf all-volatile treatment (AVT) for secondary side water treatmen I
. - _ _ . - _ - - _-__--_-_____--______-_____________-A
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- Although the~ fun'ctional ' area was 'not~ severely challenged durin .this assessment period, the . licensee demonstrated levels .:of- s l
, preplanning, preparation and program development co_nsistent with
- a; plant- ready - for - operation. In: those' activities - where the'
.
R
- radiological controls. were: tested,' good results were achieved.' '
The ~ licensee organization 'is staffed with qualified-: personnel, 4 from the station .HP, and chemistry management.down.. The overall:
-
. performance during this period ' indicates that the site radio- ?!
logical, effluent control and chemistry ' programs- have been establis.hed with the capability ' to1 effectively support plant:
operation ~ .- !
l 2. Conclusion Category 1
]
3. Board Recommendations None:
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I
E. Emergency Preparedness (219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br />, 3.2%) ' Analysis
)
During the previous assessment period licensee performance in this area was rated as Category 2 (improving), based upon per-formance during the Near Term Operating License (NT0L) Emergency Preparedness Implementation Appraisal (EPIA) and the first full-participation emergency preparedness (EP) exercise. During the current assessment period, one NT0L appraisal follow-up inspec-tion, one routine safety insp6ction, and one special safety inspection were conducted. Additionally, changes to the Emerg-ency Plan and Emergency Plan Implementing Procedures were re-viewe Although not specifically addressed as part of their f assessment, it should be noted that licensee initiatives for off-site planning have been implemented and preparations by the site staff to support such initiatives are in progress. Licen-see efforts towards obtaining a workable off-site emergency plan reflect a strong commitment by licensee management towards a complete emergency preparedness prcgra Two NT0L Appraisal followup in:;pections were performed in March and June, 1986, specifically to follow up on twenty-four open items resulting from the appraisa While the first of these two inspections concluded on March 28, which was during the last-SALP period, it has been included in this assessment because it represented the conclusion of the EPIA inspection process at Seabrook and the report results were not available until well into this perio Licensee management aggressively addressed i NRC concerns resulting in the closure of twenty-two open iten The remaining two open items are required to be corrected prior i to issuance of a full power licens A routine EP safety l inspection, conducted in March,1987, related to inspection of l the training program, operational status of the emergency pre-paredness program, and security / emergency preparedness program interface Inspection results indicate a comprehensive onsite emergency preparedness program is in plac The special safety inspection conducttd in February, 1987, re-lated to follow-up of the sequence of events and circumstances ;
surrounding the classification of an Unusual Event on l February 11, 1987 and the required notification process. This
'
special safety 11 pection identified a violation of the licen-see's internal procedures. The licensee failed to follow the requirements of emergency procedure ER 1.0, " Classification and Notification of Emergencies at Zero Power", which requires i
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notification of both Massachusetts and New Hampshire within !
fifteen minutes of ~ classifying, any emergency condition (as de-' i fined .in procedure ER 1.1). The causes of the violation, spec-ifically the failure to' notify . Massachusetts "within fifteen minutes, were - related to weaknesses Ein ther training of the operations. management and supervisory staff and are discussed in more detail in Section C.I.b of this repor The- emergency preparedness planning function continues to be
.
controlled by the NHY corporate staff located 'at the plant site and close liaison exists.within the site organization. .09 ring this. assessment period, the position 'of ' Director of Emergency preparedness and additional corporate planner positions were filled by permanent NHY employee The. installation of. equipment and training of personnel to ful-fill their emergency response organization functions, while on-going, .has been substantially completed. First aid capability and nursing coverage have been addeo to-the. staff. Also,.addi-tional personnel to fill the key' emergency response organization )
positions on a twenty-four hour basis are currently involved in
"
qualification activities. The lack of on-shift dose assessment capability has been corrected and the addition of iodine deter-mination for off-site dose estimation-has been complete The licensee has been responsive to NRC initiatives. -This is in evidence not only by the addition and training of personnel to fill key functions within the emergency response organiza-tion, but also by the cooperation provided by NHY on the resolu-tion of NRC issues concerning the emergency plan and procedure Additionally, significant effort has been expo.9ded b/ licensee management toward the resolution of of fsite concerns. Although weaknesses 'in the training of supervisory personnel were uncov-ered during an Unusual Event, this incident was quickly and comprehensively addressed by licensee management. Overall, the commitment and performance by the licensee in emergency preparedness remains hig l 2. Conclusion Category 1 3. Board Recommendation None I
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25- j F. Security and Safeguards (175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, 2.5%) Analysis i
l During the previous SALP period, the licensee was assigned a '
Category I rating, as part of the Operational Readiness evalua-tion, for preoperational activities involving security personnel i training and the installation and testing of new systems and equipment for the Unit 1 Physical Security Program. In the cur-rent assessment period two preoperational security program reviews, one routine physical security inspection and one pre-operational nuclear material control and accounting review were conducted, along with physical security inspector participation in a Region I team inspection. No violations were identifie The NRC completed its evaluations and approved the Seabrook Station's Physical Security, Training and Qualification, and i Safeguards Contingency Plans on July 23, 198 i Over the course of this assessment period, the licensee's staff has been involved in monitoring the performance of new security systems and equipment, evaluating the effectiveness of training and procedures and assessing the need for changes based on pro- t gram experience and feedbac Both corporate and station management involvement in and support for the security program were evident and restited in the initial implementation of the Unit 1 Physical Security Program with few identified problem The allocation of sufficient number of technical and support personnel resultea in sound designs, good planning, and timely procurement and installation. Such oversight underscores senior New Hampshire Yankee management's support for an effective security progra Throughout the preoperational phase, the licensee was responsive to the resolution of weaknesses / concerns identified during NRC inspections and in NRC Bulletins, Circu-
,
lars and Information Notices. The licensee also initiated liaison with other Region I licensees, visited other sites, and developed feedback mechanisms to resolve security program .
I issues. This has resulted in security program enhancements being implemented at the Seabrook sit Effective communic.ations exist between the security organization and the other station departments, as evidenced by the station response to security events. Program support and cooperation is also evident from local law enforcement agencies. The licen-see's security organization is actively involved in the Region I Nuclear Security Organization and with other nuclear industry groups engaged in the development of security program standards m and innovative approaches to security issue ,
C
,
. .
Twenty-four event reports were submitted in accordance with 10 CFR 73.71 during this period. Twenty-two of these reports resulted from minor problems typical to those encountered during the startup and continued testing and maintenance of new secur-ity equipment and systems, including the security computer and its associated software. While the licensee's event reporting program was found to be acceptable, NRC evaluation revealed that several reports required further clarification from the licensee l with regard to the analysis of causes and planned corrective i
actions. During the latter portion of this assessment period, both an improvement in the quality of event reports and a reduc-l tion in the number of security event reports were note Staffing of both the proprietary oversight and contract security organizations was timely and effective. Management and super-visory personnel appear to be well qualified, experienced and motivated. Clear and concise security procedures were devel-oped, approved and implemented to ensure program cohesivenes Modification of these procedures is continuing in response to feedback and experience gained through use. The self-identifi-cation of program weaknesses and needed improvements by both the
,
contractor and proprietary staffs is encouraged by licensee l management and reviewed in a timely manner. Special emphasis is l currently being focused on the performance of security systems l and equipment, and their reliability. This ef fort is intended to enhance the ef festiveness of both short-term reactive and long-term . preventive maintenance for the systems and equipmen The level of staffing for security equipment maintenance program further reflects the licensee's commitment to a high quality progra The security organization's training and qualification program has been well established with full-time experienced instruc-tors, lesson plans, state of the art instructional aids and adequate facilitie Entry level training and annual requalif-ication training of security force members are administered in conformance with NRC approved criteria. Oversight by the pro-prietary staff ensures that the program is continuously updated to include feedback from operating experience. Members of the security organization were observed to perform their duties in a professional manne During the assessment period, the licensee submitted two revisions to the Security Training and Qualification Plan and a revision to the Safeguards Contingency Plan under the provisions of 10 CFR 50.54(p) and provided its response to the recent mis-cellaneous amendments to 10 CFR 73.55. The revisions were of high quality and indicative of the station management's continu-ing oversight of the program to ensure it is consistent with NRC
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4 performance objectives, Secur_ity personnel ' involved .in plan 3 maintenance are knowledge'able of NRC _ requirement Addition- ;
ally,.'the licensee's program - and procedures to control and !
account- for special nuclear material were' reviewed and found to- 1 be adequate, as _was the licensee's' plan for the protection of special nuclear material- of low . strategic significance .(new
r fuel).
In - summary, the licensee has established an l effective Physical Security Program. Efforts to improve the' operation and reli-ability of systems and equipment ' and personnel qualif.ication have - continued. The security program is actively supported by.- .
)
other plant functional groups,: as evidenced by the lackof problems _ in _ the maintenance of security equipment,_ response 'to 1 events and other areas where effective ~ interfaces- were necessa r Both corporate and station management ~ support of security programs and initiatives is evident, l Conclusion Category 1-
- 3. Board Recommendation 1 i
Non . .
j i
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l t I i
I 28 ! Engineering Support (579 Hours, 8.3%) -{
1 Analysis This area was not evaluated as a separate Functional Area during the previous :SALP period, although the engineering services
.provided to support construction activities were considered in the overall assessment of the' construction are During this current SALP period, engineering support to . the station staff is assessed based upon the engineering services provided to ~ the plant maintenance -and modification processes, the analyses performed to address NRC concerns 'and self-identi-fied design problems and the: licen_see's overall. technical ability to . support construction completion and ongoing opera-tions fromL an engineering . standpoint. It is noted that _ during this, period, a reorganization of both the corporate engineering and technical support staffs occurred. . A New Hampshire: Yankee . i engineering organization was established with a smaller in-house review capability than existed during the period of full con-struction .and architect / engineer presence. However, well de-fined agreements with . both UE&C and YAEC were established to provide additional engineering services on an as-required basi The station staff also restructured their technical support capability to align with a system / discipline service orientatio While this licensee reorganization has tailored the engineering staff more directly in support of operational activities, cer-tain problems have arisen during this SALP period which high-light the need for more timely and complete engineering analysis of deficiencies particularly by the corporate engineering staf Examples of such problem areas included NRC identification of a Control Building Air (CBA) system which deviated from system-design commitments provided in the FSAR and also of a Contain-ment Building Spray (CBS) piping design which required upgrade and implementation of a design modification to meet the intent of the pertinent ASME Boiler and Pressure Vessel Code. In each case, licensee events or observations had identified evidence of the problem areas (control room ventilation isolation events in the case of CBA and leaking check valves in the case of CBS),
but were not sufficiently developed by engineering review to effect timely corrective actio Ultimately, in both cases, system modifications were effected and NRR review and approval of the CBA and CBS designs were require .
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l
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,1 4
S q
,
Other noteworthy problem areas included the' identification b "
.
the licensee of. tube erosion and pitting problems in the primary i component cooling water (PCCW) heat excha ngers ,- evidence of valve lining detachment and ' degradation. in the Service Water (SW) system, and a common mode failure of equalizing valves in the containment equipment hatch' air lock doors. The latter two 3'
issues represent items which were reported by the licensee unde the provisions of 10 CFR 21. Unlike the handling of the CBA and
- CBS problems, however, licensee > reaction by the station . tech-
.
i nical support' staff to these. major problems . was_~ thorough,- j methodical and.well scheduled. Eddy current testing lof the. PCCW - !
heat . exchangers ; was implemented, . resulting in the conduct of i tube plugging and sleeving operation The SW valve ' lining- I configurations were redesigned' and .a comprehensive test program j was implemented to verify adequacy. The equipment hatch air j lock equalizing valve ' linkage was also redesigned to preclude l recurrence of a similar failur i i
The only negative aspect to the . licensee responsiveness to these problem areas. was the fact that the SW lining problems repre- -
sented, in - ef fect, a weakness in the licensee's corrective l action. for a 10 CFR 50.55(e) report issued in 1985. At that time, the original valve rubber-like linings were replaced by "Belzona D&A" elastomer. However, it appears that both the replacement design and the construction bonding process . were defective, resulting in the current problem The licensee's j current approach to both the engineering and process. controls required to repair these valves, however, appears to be thorough i and well directe _l In response to concerns raised by the NRC with respect to the !
engineering department interfaces with the station staff, the licensee has implemented new initiatives to foster mutual co-operation and reliance on technical expertise to address prob-lems. This cooperation has- evidenced itself in corporate engi-neering management attendance at " plan of the day" meetings, the more timely involvement of the corporate engineering staff in operation decisions related to the FSAR and design basis 1 analysis, and plans to relocate corporate engineering personnel !
from the general office building to offices closer to the plant !
itself. Both the Independent Review Team (IRT) and Independent l Safety Engineering Group (ISEG) appear to be functioning in an !
atmosphere which provides valuable overview to not only site i specific engineering problems, but also generic issues affecting :
the industr Current New Hampshire Yankee Engineering Evalua- I
'
tions from the corporate staff provide a documented, well defined approach to technical questions. Thus, the licensee has demonstrated a willingness to implement programmatic improve-ments not only where deficiencies are identified, but also where weaknesses are perceive ii
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( 30 As was discussed in Section IV. A with respect to construction completion, engineering support activities related to the design reconciliation of the as-built plant (e.g. , PAPSCOTT) were ef-fectively implemented to assure compliance with the design bases and FSAR commitment Licensee corporate management has demon-strated a willingness to implement design modifications where justified by internal engineering evaluations or independent staff reviews. This -licensee responsiveness to determine and effect the proper engineering solution to identified problems (e.g. , EFW Terry-turbine testing; service water valve lining repairs) continues to represent a licensee strength. The recur-rent nature of some of the problems described here and in other sections of this SALP report does, however, highlight the need for additional licensee attention to adequate control of the corrective work processe In summary, engineering services to the station construction completion, maintenance and modification efforts has evidenced some transitional problems from reliance on a large staff, heavily dependent on architect / engineer (UE&C) support, to a smaller New Hampshire Yankee in-house engineering program. The licensee has recognized these problems and appears not only to understand the need for improvement in support of future opera-tions, but also to have initiated corrective measures to proceed in the proper directio . Conclusion Category 2 l Board Recommendation None
.
__ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - ~ ~ ' - " - - - - - ' - ' " - - - - - - - '-- - - ~ ' '
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H .- Licensing Activities I Analysis This area was rated as Category 1 during the previous assessment-period based upon the required preparations, responses to open items, and.overall readiness with respect to the issuance of an !
operating . licens The previous assessment. concluded 'that .I
,
' management involvement was evident and effective, that a high' {
degree of responsiveness was apparent, and that corporate staf- !
fing levels were sufficient to support licensing . actions. Since the previous assessment period, a license has _ been is' sued to permit fuel load and the conduct of' precritical test A license to. operate.up to five percent power has been requeste The current assessment is based principally on NHY performance !
in support of those. actions which were required to obtain a fuel l
. load license and which were taken in connection with its request I for issuance of the five percent licens The licensee . has continued' to demonstrate - strengths in their approach to problems from a safety standpoint, in the qualifi- !
cations and level of staffing and in the active involvement of-corporate management. The licensee has provided 'the needed tech-
.nical capability in the engineering and scientific disciplines to' resolve items of concern to the NRC. Resolutions to tech-nical issues have been consistent and thorough. The licensee has been willing to perform additional studies, as necessary, to answer any outstanding NRC question . Thu s ,- on technical matters, ef fective communications between -the licensee and the NRC staff have been beneficial in processing licensing action The licensee. f acilitated timely resolution of the majority of outstanding licensing issues. . In .most cases, acceptable pro-posals were submitted with the initial licensee response. The overall responsiveness to NRC initiatives was generally satis-factory, except for certain issues, where in the first part of the current SALP period, additional NRC requests were needed to gather ' complete information. For these cases, NHY corporate management involvement and timely action were effective in promoting satisfactory resolutions to the specific problem NHY management has actively participated in licensing actions and generally has maintained awareness and knowledge of current and anticipated licensing activities .during this evaluation period. On several occasions, licensee management has demon-strated not only involvement in licensing, but also p romp t ,
l -
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appropriate corrective ' action to situations where . the respon-siveness to NRC initiatives was deemed unacceptable or not timely. --NHY has also demonstrated a willingness to ' meet with the .NRC Licensing Project Manager to; discuss licensing action status on an as-needed' basis and with a cooperative attitude to resolve problem NHY. licensing and engineering groups have b'een adequately-staffed, as' indicated by the qualified representatives attending-numerous meetings with the NRC, . Competent technical staff have
-
participated' in scheduled reviews and . effected satisfactory
. resolution of open items. The NHY Bethesda Licensing. office has
. remained active throughout this SALP period as a significant licensee -initiative which continues to provide priority atten-
-
tion toL NRC concerns. In ' general, - the licensing group has ef fectively coordinated the effort of providing input from 'the -
,
.differeht functions within the NHY organizatio ' Conclusion
,
Catego'y r 1 3 '. Bosed Recommendation None
> ,
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l 33 'j
)
' Training and Qualification Effectiveness
'
i Analysis Training and Qualification Effectiveness is an evaluation cri-
.terion for each Functional Area. 'In .this appraisal, it is!also being considered as a separate area and as such, represents c a synopsis of the assessments .in the other areas. Training effec-tiveness is measured by observation of licensee personnel per-formance and through reviews of licensee. programs, _
The limited scope of operations during this assessment period has not allowed for an appraisal - of the - effectiveness. of train-
.
{
ing over the full . range of operational activities:which will be I implemented in the future. However, in those. areas where the measures of licensee performance can be related. to ' training and - !
qualification criteria, this assessment provides an overall i evaluation of the effectiveness of control and conduct of' i licensee work activitie !
In the last SALP period, this functional area was not evaluated !
separately, but Operator Licensing was assessed a Category 1 rating as part of the overall operational readiness appraisa !
During the previous assessment period, the licensee had demon- ;
strated a commitment to quality training. This commitment has remained evident through the current SALP period based upon licensee initiatives in the areas of simulator enhancement and efforts directed toward licensed operator training program accreditation by the Institute of Nuclear Power Operations 3 (INPO).
The first group of operator licenses at Seabrook became due for renewal during this period. Two year license renewals were issued for these individuals. A requalification program eval- q uation was also iritiated to provide a basis for the license >
renewal. To date, this evaluation has consisted of an NRC review of the requalification program and an NRC requalification examination administered to eight licensed operators. Three operators failed one or more portions of the NRC administered !
requalification examination and are being upgraded in accordance +
with the existing NHY requalification program. Training Depart- l ment actions to address NRC identified generic weaknesses and j strengthen the overall program have been initiated and appear i well directed. As had been evident in previous, less formal NRC appraisals of operator training with respect to requalification, the licensee has demonstrated a willingness to devote adequate l resources to the training goals and to commit additional )
resources to upgrade identified areas of weaknes I l
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.34
> 1 It..should be::noted 'that' another initial operator licensing
-
? -
examination .was administered in August,= 1987. . Although this '
examination'was conducted shortly aftere the end of this current SALP assessment period, the results Lindicate ; a high initial >!
. examination pass - rate which is consistent with the previous ~
initial. license' examinations:at Seabrook Station, A review of the LERs and enforcement actions issued during this SALP ' period identified certain problems 'related to training effectiveness. ~As discussed in other Functional Areas, viola-tions resulting from the failure ~ to ' maintain a.. valve': locked-- ,
closed in accordance with license conditions and the failu're to-
'
follow' procedures in notification during_ the Unusual Event, were caused .in part by training deficiencies. Additionally, . incom- i plete operator understanding of - the design bases of . the CBA system design, as noted in Section IV.G, led to a violation, af ter a deviation from FSAR commitments had already been issued l-on the same subject. The problems, however, appear to have been "
isolated examples,, as the' overall training provided the opera- 1 tions staf f.is of high quality with no major generic weaknesse An.eva'luation of the LERs issued during this assessment period identified no specific causal linkage between performance-related problems and the adequacy of trainin In the area of general and specialty training, a reorganization-has consolidated all training functions under the-Training Center Manager who previously was responsible only for licensed operator trainin This change should enhance the overall training effort while reducing the administrative resp'onsibil-ities'of the Station Manage NRC inspectors monitored various licensee training sessions both for the purpose of on-site program familiarity and to assess the '
effectiveness of licensee training in areas such as general employee training, radiological controls and fitness for dut Also, NRC inspections of other functional areas have evaluated the conduct of training (e.g., Technical Specification revision training for operators, entry level and annual requalification for the security force, supplemental HP training, and general EP training provided the licensee Emergency Response Organizatio This inspection effort has confirmed that the training and qual-ification criteria inherent in the implementation of other tech-nical programs have been effectively utilized. Region I special team inspections into allegations regarding Seabrook construc-tion hardware and programs revealed no specific disciplinary ,
training deficiencies and no generic problems with the licensee program of education and handling of substance abuse policie .
.
__ _ - _ . _ l
.
. -
,
'
,, -
y,. or
.j..' i 13 -
=
.
l-
.
.-l Thus, 'a review of flicensee1 performance across Lthe. range, of
.
"
'different disciplines,- as .' highlighted 'in .theidifferent' func -
-
tional areas, reveals that- the. conduct of. adequateLtraining and
qualification programs have contributed to the successful'imple- ;
cmentation JoF overall station objectives. An additional example {
'of licensee; philosophy in this regardLwas the wide disseminatio l of technicalinformation, either industry initiated oraNRC' I
! originated, throughout'the station staff. This information flow has effectively increased the; station's awareness to problem areas-in the industry and.has provided guidance.to the technical
' staff for' performance improvement N ' In summ'ary, in those 1 areas 'where : NRC and licensee- evaluation I have identified ;trai.ning related weaknesses, prompt. and ef fec-
.
tive , corrective ' measures, including the retraining of ~ personnel, have'been implemented. With respect.t'o the overall: control' of j training ' functions and ~ performance by statio_n personnel, NRC l inspections over' the course of. this SALP period have found the
-
i licensee programs and_ staff.to be effective, i Conclusion-
.
i,
.. Category 1 - Board Recommendation ;
'
None i-1
,
j
I
- _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - - --
. .
J. Assurance of Quality Analysis Management involvement in assuring quality is an evaluation criterion for each functional area. Quality assurance (QA) also l
'
is an integral part of each functional are This appraisal of the assurance of quality is a synopsis of the applicable aspects s of other areas, including worker and supervisor performance, management oversight, and safety review committee activitie During the last SALP period, this functional area was assessed a Category 1 rating based upon an ef fective QA program, which assured construction quality, and the continued management support of QA initiative;.
During the current assessment, an entirely new QA program, that of operational quality assurance, was subject to evaluation along with a new organizational structure, revised interfaces, different work controls, and the necessary shif t from construc-tion processes to maintenance and modification activities. The interdependence of NHY QA policy and procedures with the Yankee AtonHc Electric Company (YAEC) program was eliminated and key personnel responsibilities shifted accordingly. It is note-worthy that the licensee retained sufficient experienced per-sonnel from contractor organizations (e.g., YAEC, UE&C, Westinghouse) to effect a smooth transition into the operational system of control However, certain transitional problems have been experienced in the restructuring of the QA organization to fit its operational responsibilities. While management support of an effective QA program remains strong, the relative strength of the QA organi-zation as an independent force and prime mover in the corrective action process has diminished. This may be the result of and a normal consequence to the establishment of a strong station staff with particularly qualified and technically competent operations, maintenance and technical support groups. However, one negative aspect of this has persisted throughout the current SALP period and relates to the feeling that the station staff can disposition their own problems without the need for QA involvement and that the QA staff mission relates more to pro-grammatic and procedural overview than it does to the effective-ness of control . - - _ _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ _ _ - _ __ _ _
. .
. .
NRC inspection issues which have highlighted this concern include questions into tagging controls, station operating and surveillance procedures, the use of unauthorized operator aids, general housekeeping and corrective action processes, and utilization of Station Incident Reports as an information source for root cause problem analysis. In several of these cases, where a specific NRC recommendation for QA follow up of the identified deficiencies was made, audits were conducted. These q audits proved to be extensive and thorough and generally con" firmed a need for corrective actio However, the fact that such QA reaction to the problems was not routine, but evident only upon NRC interest is a matter that warrants further manage-ment evaluation of their QA program of controls, t
One strongpoint of the present QA program is the effective use
'
of quality control inspections and holdpoints to confirm the 5 proper conduct of special processes. The implementation of such l QC measures has strengthened an already strong maintenance pro-gram in the area of independent checks and assurances of the adequacy of controls in the various discipline Another pro-g rammatic strength is the individual expertise provided by the i
technical support staff. The NHY system engineers, while not QA l
'
personnel, provide a definite measure of effectiveness to the overall station assurance of quality, based upon their knowledge and technical interfacing with other personnel on the station l P.aff and with the QA and engineering organization This strength relates to an overall NHY organizational structure which appears to be effectively working, while still providing a system of independent checks and balance Examples of independent groups within NHY which provide quality services which have supported the successful functioning of the overall organization include the Independent Review Team (IRT),
the Employee Allegation Resolution (EAR) program and the Independent Safety Engineering Group (ISEG). Both the IRT and ISEG have been involved in design evaluations, and the analyses of component failures and human factor problems which have led to reportable events. In the same way with respect to allega-tions, the EAR program has provided a " third party" review of concerns which has not only proved beneficial to the investi-gative process f o'r worker concerns, but also has provided a measure of independence to the normal management review of problems. The IRT and the EAR were also both noteworthy as licensee initiatives which were established and maintained, not because of regulatory requirements, but because of the benefits the licensee knew would accrue from independent self-evaluation Programmatically, these independent groups, along with the Nuclear Safety Audit and Review Committee (NSARC) and the use of special review groups where necessary, have provided a measure of the licensee's ability to self-criticize and thus learn and improve with the corrective action proces __
- - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
L. . ... .;
1
, . 38'
{
Another licensee internal review group, the Station Operation Review Committee (SORC), has also ' been . active during this assessment period in reviewing program and procedural revision Some ' administrative problems in SORC. effectiveness were iden- i tified by the NRC with respect to the application of safety j review criteria to "nonintent" procedural changes, _ Also, the "
practice of conducting such reviews outside the. scope of the SORC rneeting was questioned, On both these matters, the licen- i
.
see' recognized the . advisability of . instituting . improvements to ,
the SORC and safety . review processes and implemented additional !
systematic review measures to address.the NRC concern ,
Another program where - NRC ' inspection revealed the need for i further development was the licensee's implementation of a Quality Trending System. Weaknesses . identified ' in .this area -
related to the lack of corporate and QA management attention to i the availability of problem trending mechanisms and ' also to a I database which fails to track the valuable. trending information available in documents other than nonconformance reports, j Licensee . QA management was apprised of these concerns and 'has ,
instituted. program reviews intended to upgrade ,the defined cor- i rective action proces Continued attention to the controls l which integrate plant activities and ' problems (e.g., Station Incident Reports) into a QA trending system,- thus providing insights into the lessons learned, is warrante Overall, in evaluating this _ functional area, in the context of
quality criteria affecting other rated areas, a high level of performance was note Effective work controls, strong first i line supervision, timely QC inspection and a continued emphasis on quality performance, to include management support of QA ,
goals, have resulted in evidence that the plant is being oper- i
^ ated and maintained safely. While some areas requiring improve-ment were identified,. positive licensee initiatives were also noted to sustain the Assurance of Quality during the major transition from construction to operations. A strong quality conscious attitude is evident throughout all levels of the plant i organization. The increased involvement of the QA organization into operational activities and problem analysis should further enhance the overall effectiveness of the quality progra . Conclusion Category 2
0
'
- _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ . _ . . .
- ____ __ _ _ _ _ _ - _ _ _ - - _ _ - _ _ _ - _ _ _ - _ - - - - - - - _ - - - _ - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
. .
39 Board Recommendation Licensee: New Hampshire Yankee management should reassess the role of the QA organization in the analysis of opera-tional problems. The licensee should consider expan-I
'
ding the scope of quality assurance functions to more effectively utilize QA as a management tool to recog-nize the generic impact of certain problems, and thus allow corrective action to be directed to related areas of programmatic weaknes NRC: None
- _ _ - - _ _ _ _ - _ _ _ - _ _ _ - _ _- -
't
. ...
..
40 ; SUPPORTING DATA AND SUMMARIES
.. . Investigation and-Allegation Revie ]
- During .this assessment period, a total of four separate and gener- }
ically categorized allegations were received by . the NRC. One of
these. generic sets of concerns was-multifarious and' involved concerns of. a broad and general. nature. To date, over 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of direct NRC j i- inspection effort have been expended to determine whether quality construction ori. safe operation had been 'o r could be adversely l j
l impacted by this ' set of stated allegations. In. this case, as ..with : j the other' three. allegations, no violations were identifie ~l It is noteworthy that while several of the stated concerns involved nonsafety-related components, NRC inspection treated - these allega- ,
tions rigorously as technical issues to determine if s' ome deficiency '
could be linked to safety-related activities. No linkage was-identi-i fied, and, to date, no hardware problems (either safety or'nonsafety)
!
have been-in evidence. While evaluation of several new concerns ' is in~ progress, the findings 'so far corroborate the quality of con-struction. These results also confirm previous NRC . assessments that-
-over the. course of construction -completion, few hardware . problems have been identified and those that had existed have been adequa'tely-correcte Escalated Enforcement Action None L Management Conferences No conferences with the licensee dealing with enforcement were held during the appraisal period. On June 10, 1986, a management meeting at NRC request was conducted at Seabrook Station to discuss the results of the Region I SALP board convened to evaluate licensee performance from January 1, 1985 to March 31, 198 Review of Licensee Event Reports (LERs) Tabular Listing Refer to SALP Table 4 for Listing of LERs by Functional Area s
e
_ . , _ _ . _ _ _ _ . _ _ _ _ _ _ .
'
g4
-
-
..
,
,. s.-
t
'
41' <
_ Causal Analysis 7 Analysis of the LERs listed in: Table 4' has identified no unac--
ceptable. chains per statistical acceptance criteria.' . An AEOD evaluation of-Seabrook!s LERs indicated that the reports were of
. generally above-averageL quality. . ' Additionally, one ' other non -
. reportable event was' identified which Was lin ed to.a reportable
. ,
event. While the licensee ' had notn recognized this. linkage 'in subsequent reporting, this had no effect on the causal analysis-
.or the'result . Summary of Licensing Activities Significant-NRR/ Licensee Meetings-a. June 26, 1986 --
Operational Readiness of.Seabrook Unit 1 b. August 6, 1986 --
Seabrook : Station. Risk' Management and Emergency Planning,.(RMEP)'. Study. and-Emergency Planning Sensitivity (EPS)
Study c. September 4, 1986--
. Seabrook Fire. Hazards Analysis j u
d. September 8-9, 1986- NRR '& Brookhaven National Laboratory (BNL) Site Tour for RMEP & EPS Studies e. September 23, 1986 - RMEP & EPS' Studies
'f.' March 18, 1987 -
Seabrook Unit 1 Licensing Issues g ' March'25, 1987 --
BNL Report on RMEP & EPS Studies i
". h. May 7, 1937 -
Seabrook Unit 1 Licensing Issues 1. July 30, 1987 -
Utility Compensatory E-Plan for Massachusetts Commission & ASLB/ASLAB Decisions a. October 17, 1986 - Issuance of Facility Operating License (NPF-56) for Zero Power Testing b. November 20, 1986 - ASLAB Denial of Zero Power License Appeal (ALAB-853) by Massachusetts c. January 9,1987 -
Commission Review of ALAB-853 Stays Issuance of Low Power License l
_ _ _ _ _ _ __________ ____--_ __ -_ - E
._ . _
. _ - _ _ _ . .
- ,
. .
l
.
d. March 25, 1987 -
ASLB Issuance of Partial Initial Decision on Low Power License e. April 9, 1987- -
Commission' Order (CLI-87-02) Retains
,
in Effect License Stay f. April 22, 1987 -
Full Power ASLB Denial of Licensee Petition to Reduce EPZ g. June 11, 1987 -
Commission Order (CLI-87-03) Denies !
Licensee Motion to Lift License Stay
_ _ _ _ _ _ _ - _ .
- .
I, TABLE 1 INSPECTION REPORT ACTTVITIES Report No. Inspection Hours Area (s) Inspected
- 86-09 74 Routine Inspection of General and System Operating Procedures l
86-19 86 Routine Inspection of Preoperational Test Program 86-20 439 Routine Inspection of Construction Completion, Preoperational Testing, Training, TMI Action Plan and Previous ;
Items 86-21 43 Routine Inspection of Previous Items
!
86-22 160 Routine Inspection of Chemistry, Effluent Controls and Radioactive Waste Programs 86'23- 122 Routine Inspection of QA Program and Previous items 86-24 37 Routine Inspection of Records Related to reactor Yessel and Internals and Previous Items 86-25 123 Routine Inspection of Occupational Radiological Protection Program 86-26 33 Routine Inspection of Nuclear Material Control and Accounting 86-27 240 Special Team Inspection Comparing Technical Specifications to As-Built Plant 86-28 135 Routine Inspection of Operational Readiness and Previous Items
86-29 74 Routine Inspection of Security l Plan and Implementing Procedures '
l
_ _ = _ - _ _ - _ l . .
'
Table 1 2 Report No. Inspection Hours Area (s) Inspected 86-30 113 Routine Inspection to Follow up Emergency Plan Implementation Appraisal and Previous Items 86-31 32 Routine Inspection of Startup Test Program and Procedures 86-32 27 Routine Inspection of Fire Protection Program 86-33 37 Routine Inspection of Abnormal and Emergency Operating Procedures and Previous Items 86-34 333 Routine Inspection of Construction Completion, System Design, TMI Action Plan and Previous Items 86-35 110 Routine Inspection of Chemistry, Effluent Controls and Radwaste Programs 86-36 91 Routine Inspection of Operational Readiness and Previous Items
, 86-37 88 Routine Inspection of l
Preoperational Test Program l
86-38 32 Routine Inspection of Radiological Environmental Monitoring Program 86-39 79 Routine Inspection of Occupational Radiological Controls Program 86-40 47 Routine Inspection of Preeperational Test Program 86-41 44 Routine Inspection of Security Plan and Procedures 86-42 -
Inspection Number Not Used
- _ . _ _ _ - _ . - - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -
.
_
- ,
.
'ht ' g 3 o L "
' Table m s i Report N Inspection Hours Area (s) Inspected 86-43 115 ' Routine Inspection of Seismic'
~ Piping Systems, Pre-Service Inspection ~ Program and As-Built 1
- P1 ant-86-44 '68- Routine Inspection of Effluents JI Control and Radwaste Programs
~86-45 36 Routine Inspection of Electrical and I&C Procedures and Previous Items 86-46 358 ,
Routine Inspection o Construction Completion Activities, Design Changes, :
~As-Builts, TMI Action Plan,- >
Previous Items 86-47 '428 Routine Inspection of Testing, License Issuance, Cor'e Loading, Maintenance, Surveillance, ;
Operations and Previous Items 86-48 48 Routine Inspection of Startup Test Program and Procedures; Review of Containment Sit Report 86-49 39 Routine Inspection of Pre-Service Inspection Program and Records and Previous Items
'{
86-50 131 Routine Inspection of Initial Fuel Loading Activities 86-51 97 Special Team Inspection To Review Allegation of As-Built Drawing Discrepancies 86-52 478 Special Team Inspection to Review Allegations by ELP 86-5'3- -
Inspection Number Not Used 86-54 187 Routine Inspection of Operations, - .
Maintenance, Surveillance, 1 Startup Testing and Previous j Items '
___
_-_-
.r .
t Table l 4 Report N Inspection Hours Area (s) Inspected 86-5 . Routine Inspection of Occupational Radiological ..
'
' Controls Drogram and. Previous Items
!
86-56 24 Routine Inspection of Physical Security Program and. Previous Items-86-57 -
Inspection Number Not'Used
.86-58 118 Special' Team. Inspection To Review. Licensee ~ Action on GL 83-28, ATWS 87-01 128 Routine _ Inspection of'
Preoperational Test Program, Test Procedure Review, Test. Witnessing ~j and Test Results Evaluation'
87-02 432 Routine Inspection of .. 4
.
Post-Core' Loading Heat-Up and i HFT, Maintenance, Surveillance, -l Operations and Previous Items i 87-03 '56 Routine Inspection of I&C Surveillance Test Progra '30 Routine, Inspection of Radwaste Program and Pre 0perational Test Results Evaluation 87-05 69 Routine Inspection of Startup Test-Program, Post-Core Loading Hot Functional Testing and Test Results Evaluation 87-06' -
Inspection Number Not Used
. 87-07 583 Special Team Inspection of -j Allegations Raised by ELP 87-08 26 Special Inspection to Follow-up Unusual Event of 02/11/87 87-09 34 Routine Inspection of Post-Core Loading Hot Functional Testing
,
_ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ -
l *. }-
1; 2 1 N <
.1
..
,.
' J' m Table 1 ,
5 l
, -
o, ,
Report N Inspection Hour's Area (s) Inspected
~87-10 346' . Routine Inspection of Post-Core '
Loading Heat Up and HFT and- j
~Cooldown,-Maintenance, Training, Operations and Previous Items 87-11- 32 Routine Inspection of Startup Test Program, Post-Core Loadin Hot Functional: Test Witnessing-and Test Results' Evaluation.
'-
87-12 -54' Routine Inspection.of EP Progra'm~,- ,
Organization and Managemen l
. Control, Training and Previous '
Items ,. ;
87-13 268 Routine Inspection of Design ,
l
.
Control Program, Testing,- .
!
Maintenance, Surveillance and 1 Previous Items 87-14 34 Routine Inspection of Occupational Radiological Controls Program 87-15 33 Routine Inspection of !
Non-Radiological Chemistry Program 87-17** -
Operator Licensing Examination 87-18 35 Special Inspection of Service Vater Valve Repairs 87-19 -
Operator Licensing Examination 87-20 34 Routine Inspection of Eoutpment Tagging and Temporary Modification Programs-sirst inspection conducted during this SALP period was IR 86-19. 86-09 was subsequently conducted out of sequenc **87-16 report will be included in next SALP perio {
l p
i I
Y _ -_ -_ - -_
2. :.
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'
-
TABLE '
,
'
9- . INSPECTION HOUR SUMMARYJ .
. ,
. . .
HOURS'
FUNCTIONAL AREA 5 Actual ' Annualized- . Percent
'
IL : Construction' Completion' 1349- 1012 :1 . Startup' Testing.' :1244 932- 17. 8 ': '
- ,
a- .o
' '
p Plant Operation '
2667 2000 '3 .'4'-. Radiological Controls 739 554- 1 J
, : 5.' - Em'ergency Preparednes .
219- 16 .2l 3 U
L 6.:-- Security.'and Safeguards 175 '130- n ,
.
- 7,.-- Engineering.. Suppor . . Licensing Activities - - -
9.- Training and Qualification -
'
- -
. Effectiveness-
-
~
10. -Assurance'of Qualit .-
-
._____ _____ _____
TOTAL .- '6972 -5226 100.0
.,
f v
I t A,,.,,__,_ ____2..mm_,. _._m.w_ ____-m-w--.a..-
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TABLE 3:
a4 g', '- '
>>
. ENFORCEMENT ACTIVITY
+
~
'A,- Violatio'ns Versus Functional Area By Severity Level'
. ;; -
, t No. of Violations in Each Sevarity. Level ic Fun'ctional Area V I V,' III' II 'I ' Total '
.. . 1. -Construction Completion- -
O sy Startup Testing 'O Plant Operations- 1E 4 5 Radiological Controls .
<
<
5. . Emergency Preparedness 1 .1
- Security-and Safeguards ~ 0
~ Engineering' Support- 0
< 8. , Licensing, Activities
-
0 . Training and Qualification 0
.1 Assurance of Quality'. 0 TOTAL 1 5- ~0 0 0 6 i
.
a 1'a'.
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,
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-Table 3
'
L2l
' '
q ; Summary
,
. Inspection . Severity Functional Brief-1 Numbe .. Requiremen Leve : Area . Description-
-
86-46 110 CFR 50, 4 Operation Seismic 2 Over ,
'
c APP.'B~ Controls'For-Temporary Equi pment'"
'
i- ~ 86-47~ .10 CFR 50,. 4 Operation . Locked Valve ,f APP. Controls "
.87,-02 '10 CFR-50, 4' Operation CBA Sys;em Noti Ao Operated;I Accordance With Design Requirements
'
87-08' T..S.6.7.1' 4 Emerg. Pre . Failure To Report:
Unusual Event'
.87-13 10 CFR 50.59 4 Operations SW/SCW Temporary
. Modification 87-20 10 CFR 50, Op'erations
~
5 Tagging Program APP. B Deficiencies
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, 77-- -- .- .
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,
TABLE 4 a LICENSEEEVENTEEPORTS
.
LA . LER By Functional ' Area- .
' Number By Cause Code *'
'
' Functional Area- A! 8 -C- D- E 'X l'.' Plant' Operations 8 2 4 3
?2.LRadiologicalControl '
e ' Emergency. Preparedness Security and Safeguards- Startup. Testing
.,
,
Licensing-Activities
' ' -
. 6 .'
.. Construction Completion - ! l
. Engineering Support- '
,j
. ~ .Trainin'g. Qualification:and
- Effectiveness-
@
10. Assurance cf Quality
.___ ___ ___. ___ ___ ___
8'
.
'
TOTAL 2 0 4 3 0
- Cause Codes'
!
1 A Personnel Error i
B . Design,' Manufacturing, Construction, or Installation Error 9 C - External Cause D - Defective Procedures E - Component Failure X - Other
Cause Codes in this table are based on in:pector evaluations and may differ from those specified in the LE .,
i
-
I
'
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. '
-
%,-
'- --
.. . _ . _ _ .I
_ _ _ - . - - -
+ _,1
' .: + '
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.(
, Table 4 2 s-
_
t 'LER Synopsis l
<
LER Number Summary Cause 86-001 Normally Locked Closed Valve Found Mispositioned A . l '86-002 ' Inadvertent Safety Injection . :ESF Actuation-- Control Room A-Ventilation Isolation 287-001 ESF Actuation - Control Room E l
Ventilation Isolation -i 87-002 ESF Actuation - Loss of Offsite Power A-
'
'To Essential Switchgear Bus87-003 Source Range Analog Channel Operational ~ A' -
Tests.Not Staggered 87-004 Containment Equipment Hatch Air Lock B 1 Equalizing' Valves Inoperable
'87-005 Main Control Board Indicators Not B Properly Mounted
._f'
!87-006' ESF Actuation - Loss of-Power To Vita E Instrument Panel 87-007 Solid State Protection System-Auto A Shunt Trip Test i
.,.87-008 Technical Specifications Daily Log A 87-009 ESF Actuation - Improper Tagout Of A MSIV Actuation 3 87-010 ESF Actuation - Main Feedwater D !
Isolation '87-021 ESF Actuation - Loss of Power To a 0
'
>
Vital Bus
'87-012 ESF Actuation - Failure of SI Reset E Switch o
.
____ _ _ _
, . . .. ._ _ _ _ . _ .
Y e
.e *
,
.
. Table 4 3
.
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87-013 Area Temperature Monitoring In
'
B Batter / Rooms87-014 ESF Actuation.- Start of EDG "B" 0 i
i
_ _ _ _ _ _ _ _ _ _ _ _.