ML20247R245

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Confirms Substance of 890711 Conversation Re State of Nh Independent Inquiry Into Circumstances Leading to Suspension of Low Power Testing at Facility
ML20247R245
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 07/12/1989
From: Huntington G
NEW HAMPSHIRE, STATE OF
To: Russell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20245K651 List:
References
FOIA-89-309 NUDOCS 8909290213
Download: ML20247R245 (85)


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  • PARALEGAL M ARCIA A B THL'NFERG f \[ ^f THE ATIORNEYGENERAL ENVIRONMENTAL PROTECTION BUREAU STATE HOUSE ANNEX e 25 CAPITOL STREET CONCORD. NEW HAMPSHIRE 033014397 wen n cc: J. Gutierrez M. Miller July 12, 1989 WTR 7/20/89 Mr. William Russell Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406

Dear Mr. Russell:

This is to confirm the substance of our conversation of July 11, 1989 regarding the State of New Hampshire's independent inquiry into the circumstances leading to suspension of low power testing at the Seabrook Nuclear Power f acility last month. It is my understanding that prior to the release of the NRC's report concerning that incident, the State cf New Hampshire will be provided with the opportunity to review the report and speak with cognizant NRC staff members concerning any questions this office has relating to the June 22, 1989 incident at the Seabrook facility.

This agreement has been reached with the cooperation of the Nuclear Regulatory Commission, in recognition of the State of New Hampshire's request to receive information in a timely manner and in a context preserving the integrity of the Attorney General's independent investigation. In recognition of your request to do so, this offica has agreed to preserve the confidential nature of all information received from the NBC until such time as the Commission's report is released to the public in July or August of this year.

I thank you for your cooperation, and I trust we will be in contact in the near future.

Sincerely, CC ,

M GeoffreY4. Huntington' Assistant Attorney General GMH/ den 8909200213 890926 k 1 PDR FOIA .

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Nsw Hqmpshiro MEMORANDUM SSPi 890965 BASIS FOR THE MINIMUM PRESSURIZER LZ'YEL TRIP CRITERIA FOR THE NATLTRAL Subject . CIRCULATION IEST 1-$7-22 ,

from R. A. Owinn Does June 29, 1989 To P. V. Gurney Reference Westinghouse Precautions, Limitations, and Setpoints (PLS)

The f ollowing is a response to the question regarding why the Natural Circulation Test. 1-57-22, required a manual trip at a pressurizer level below'172.

The mar.ual reactor trip requirement on pressurizer level of 172 is based upon the ability to operate plant in a condition where reactor coolant system pressure is capable of being maintained, and without violating plant technical specifications ( 3.4. 9. 2 i t es c ) .

At a pressurizer level of 17 and decreasing, the reactor coolant systwm flow to the chemical volume control system is' isolated and the pressurizer heater groups are automatically deenergized. This is a normal system control function as defined in the above Reference. Once reactor coolant system letdown flow is isolated and pressurizer heaters are denergized. the sbility to use auxiliary spray to reduce pressurizer is greatly minlaised since the charging flow to the reactor coolant system is no longer heated though the regenerative heat exchanger. Without this charging flow preheating via the regenerative heat exchanger the differential temperature between the preseuriser spray noazie and the fluid can be exceeded if auxiliary spray flow is used. Vichout the use of sumiliary spray and backup beatera presruriser pressure is not controllable and fui rier test performance cannot be expected to continue. Since it is not the intent to perform startup tests that would violate technical specifications or plant i

I design parat.eters the*'eanual trip criteria of 171 pressurizer as well as the other trip criteria were established to be utilized as anticipatory reactor

.$4s ,*f tT1(reguirgenda$ty gtop the test abould rpecified plant condffiens bej'b .Ab t eiceeded. .

M R. A. Cvinn cc: D. E. Moody J. M. Crillo C. J. Kline C. A. Kann L. V. Rau '

W. J. Tample New ." J.:.e Yease Didsien el Mdc Serse Cumpssy el New Ham,sbe .

P.O. som 300. Sa.d, m 03sn . Talsp6ae (603) c+9521 s.

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PRESSURE / TEMPERATURE LIMITS PRESSURIZER LIMITING CONDITION FOR OPERATION 3.4.9.2 The pressurizer temperature shall be Itaited to:

a. A maximus heatup of 200*f in any 1-hour period,
b. A maxieue cooldown of 200*F in any 1-hour period, and
c. A maximum spray water temperature differential of 320'F.

APPLICABILITY: At all times.

AC':0N:

With the pressurizer temperature limits in excess of any of the above limits, restore the temperature to within the limits within 30 minutes; perfore an -

engineering evaluation to cetermine the effects of the out-of-limit condition or the structural. integrity of the pressurizer; determine that the pressurizer remains acceptat.le for continued operation or be in at least HOT STANDBY within .

the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure to less than 500 psig #

r 'I within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.4.9.2 The pressurizer temperatures shall be determined to be within the limits at least once per 30 minutes during systes heatup or cooldown. The spray water temperature differential shall be determined to be within the limit at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during auxiliary spray operation.

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vankee NEWS for Imediate Release

Contact:

Ron Sher (603) 474-3564 7/13/89 (603) 474-9521 j NEW HAMPSHIRE YANKEE PRESIDENT RELEASES REPORT ON JUNE 22 SEABROOK SHUTDOWN

$TATEMENT OF EDWARD A. BROWN PRESIDENT -- NEW HAMPSHIRE YANKEE Today we are submitting our report to the U.S. Nuclear Regulatory Comission (NRC) on the circumstances surrounding the June 22 shutdown of our reactor.

The day after this event occurred, I stated that we did not strictly adhere to our test procedures, and that we would be investigating this incident thoroughly. The report we are releasing today includes a detailed chronology of the incident, an analysis of management actions and communications, and a corrective action plan to ensure an incident such as this will not occur again at Seabrook Station.

We have spent the last three weeks exhaustively reviewing all the circumstances which occurred before, during and af ter the shutdown. While there was no risk to the public, plant personnel or plant systems during this incident, it is absolutely clear that our operators failed to follow a specific test procedure.

This lack of compliance is not excusable.

We recognize the trust and responsibility given to us by the NRC with the issuance of an operating license. It is our comitment to take all actions necessary to fulfill our responsibility and to maintain that trust.

I would like to briefly review the circumstances surrounding the event and the corrective actions we are taking.

The shutdown came following nine days of highly successful low-power physics testing of Seabrock Station's reactor. Having completed low-power physics testing, on June 22, we were conducting a natural circulation test of the reactor. As part of the procedure for this test, operators were required to shut down the reactor if the Water level in the pressurizer dropped below 17 percent of capacity. The pressurizer is a component which regulates pressure in the reactor coolant system.

This 17 percent level is a very conservative limit. During nonnal plant operations, the reactor would not be shut down until the level was at 5 percent.

-more-New Hampshire biee Dwmori of Pubbc Servge of New Hompshire P.O Bcs 300 Seabrook. NH 0387d 10d CNN IN3GIS38 >IGO3803S 6E:90 68, t'l W

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Page 2 During the testing on June 22 a steam valve on the non-nuclear side of the plant malfunctioned. This resulted in the pressurizer's water level dropping.

. below 17 percent of capacity for approximately five minutes. When the levet dropped below 17 percent, our operators should have followed their test procedures and imediately shut down the reactor -- but they did not. During this time, the operators were in complete control of the reactor and the lowest point the water level reached was 14.5 peretnt -- well above the minimum 5 percent shutdown level during normal operations.

In our internal review, we determined that our control room operators believed that the shutdown criterion in the test procedure was only a guideline -- not a requirement -- because it was much more conservative than the shutdown criterion contained in normal operating procedures.

  • This interpretation of test procedures was unacceptable. Our company policy has been rewritten to clearly state that all test procedures -- as normal .

operating procedures -- must be strictly followed.

We also concluded that the pre-test briefing given to control room operators was not effective, because the control room operators believed that the shutdown criterion in the test procedures was a guideline. Our pre-test briefing program will be revised to prevent this misunderstanding from recurring. ,

During the five-minute period in which the pressurizer's water level was below 17 percent,- personnel from the NRC approached three New Harpshire Yankee staff members to remind them of the procedural requirement to shut down the .'eactor when the water level drops below 17 percent. The response by these New Hampshire Yanket personnel to the NRC was ineffective because the New Hampshire Yankee staff did not specifically recommend to control room operators that the reactor be shut down in accordance with test procedures.

Letters of reprimand have been issued to the operations management personnel present in the control room that day, to the personnel spoken to by the NRC in

-the control room. and to certain operators and engineers involved in the test.

Our internal report focused on the technical circumstances surrounding the June 22 shutdown, and we also reviewed our management respons1 to the shutdown.

This review icentified other problems which we will resolve to the satisfaction of the NRC and ourselves. A number of actions taken by various New Hampshire Yankee management personnel were inappropriate, and do not reflect New Hampshire Yankee policy.

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Page 3 Our first oral report to the NRC that day was not precisely worded, contained inaccurate infonnation and contributed to miscomunication between New Hampshire Yankee and the NRC. We are establishing new reporting requirements to ensure that all future communications with the NRC are reviewed for clarity and accuracy.

Five hours after the reactor shutdown, members of New Hampshire Yankee staff condutted a conference call with the NRC's Region 1 Office in King of Prussia.

Pennsylvania, to review the circumstances of the incident. During this phone conversation, sorne New Hangshire Yankee managemett personnel made inappropriate statements to the NRC it defense of the actions of our control room operators.

The Vice President of Nuclear Production made unauthorized and inappropriate statements to the NRC during the conference call reg?,rding his desire to restart the reactor before the completion of a full evaluation' of the shutdown.

These statements were made without my knowledge, Concurrence or authorization, and I was not told that these statements were made by New Hampshire Yankee.

personnel to the NRC.

I later'retteved the Vice President of Nuclear Production of his duties at Seabrock Station. He subsequently resigned from Public Service Company of New Hampshire. We will be annnuncing our management realignment plan to the NRC by July 28.

While the shutdown of Seabrook Station's reactor on June 22 posed absolutely no risk to the public, plant personnel or plant systerfis, our procedures were not strictly followed and some communications with the NRC following the shutdown were inappropriate.

I recognize the credibility all of us at Seabrook Station have worked so hard to build over the years has been threatened by this incident. Our clear challenge now is to implement necessary corrective actions, satisfy all of the NRC's concerns, and maintain the public trust.

Speaking for the management and employees of Seabrook Station, as well as the Joint owners, I want to make it clear that we will be satisfied with nothing less.

IiiI 89-07-01 ,

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FaultyTalve. shuts Seabr6bkWinliel,ireadt.or,? '

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Dy kick TATE that the problam n5t Neewould a 'l A be cor ?[ntiPonution Imague, said A 'y'AULTT steam s alve forced operators of the 8eabrook nu- . rected ta "another day or two" thtah it's time sur the NRC'td clear plant to shut the reactor ,to allow low. power tests to be serious about safety one yesterday. 7s minutes s.fter the completed over the weetead. and (close) this plant?

faci!!!y reached the peak power But seabrook opponeats  :' ;The tch eesurred durlag levels -3 percent - in its low said the incident underscores "the phase of Seabrook's power testa

  • safety problems" at the New I',;ow. power testa, a arvetal first Seabrook spokesman Ron Hampantre reactor and the Nu A'stepiin.*the'imbattled' plant's Sher said engiacers shut down clear Regulatory Commission .4mov the 58 bluton plant at 12:34 p.m. . should keep the 1,160 .To * .amegawatt fun. cow' er .Thon'ement M- .toward after the valve. which controls ; plant shut. ., ...-  ; . -.ar .; -cense, Saabrook musf first re ..

operat!ons ta the plant's noo* . "It's extraordinary to.ane "oe!Ya *NRC ayp riv a;1. o f .

nueJaar area.s," remained open that this would happen at thle emergenef 'ev'acuation plana longer than it should have." plant, which they've said is the for sta Bay State communttles Sher said the incident djd beat run plant in the workl." within 10 miles d it , . ,

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3 Seabrook halts low,..... G.. power.q tests. m when steam valve malfunctions' .

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By Larry Tye last night.' ' ' .

At 5embeook, however,'

the testi N be M  ; Nom Dudigy, the NuclearJtegu-The Seabrook nuclcar plant 14 tory Commteaton's etaler In- phase became a battleground 14; unexpectedly halted its low-pv n.g spector at Baabrook, agted with tween owners d the $6 bt!!!on (e Sbsr that "Ibere la no risk ... I ' actor a.nd critics such as Oov. Du-f tests yesterey and shut down still don't completely understand kahta and Attorney General whtk workers tried to determine T9e sabet to

  • James Shannon of Manachu-;

why a sica.m valve in the nonnu. what hap'pkned clear side of the plant remained the srdonned of results af Sea- e octta. Cdtics said the tests would brook opersters* review." ' . contaminate the reactor with ree' .

open longer than required. The 5eebrook N.H.. plant was bioactivity, making it Impossible, "Because that valve stayed open, the attam being directed to running at 3 percent ofits power- touse!!for anything else tfit does; the condenser actually cooled generating potential when it shut not get a fu!!-power !kenee. Soa-.

down the nuclear side of the plant down at 1206 p.m. Once the valve brook's owners say the plant bly w!D be producing power ,

more quickly than test conditione probhm ta corrected, operators the end of the year. ,1 it." said Ronald Sher, a Sea- plan to reetArt the reactor and k spokesman. "As a resalt c( complete the severs! hours d tests 'Ite valve involved in yester .

that change in plant conditione. that remain. . day's Laddent is dealgned to direct ,- ;

the operators dedded to snanuaDy Iow-power tests are deafgned steam from the four steam gestar . t, I to determine how plant equipment ators to the plant's condenser. It is ,

shut the reactor.

"This wasn't ready a .aafety perfonna under actual operating not associated with the three' I e consideration. After nine days of ' conditions and to c*,rrect any steam valyce that malfunctioned testing this was the first interrup- equipinent'or management prob- and delayed the start dlow

  • power; tion in the achedule ** Sher added lems before th* plant la cleared to testing two weeks ago.
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NRC places Seabrook . .

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nuclear plant operators did not go by . .

the book whan a valve in a non4uclear i ana am!fse bringing low-lew! .

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testing to an inda$nfte halt, the plast's , . . . ,

asecutive said Friday  ;

Brown, pewsidaat of New' -

Hampshin Yankee, said in a pre .. .

sta:emaet that the Nuclear Regu.atoryl Af no time or the Mh~

penarelMpublic" Ot Sher t a Commission beUnse opemton W ey,"tecas en.m) muut " too ung beton shut. .4d g ting down the roecer at 12:36 p.m. gg i

  • 9 mea. - 14 use. no e.u %

%d u,t procedu, no;wecy in are m.pzto toou,J am- '2tuat = 1. =t parumistiy unn,uai, peratun and chana*8 in earl. A decade behind schedule ared 10

  • ous syetama, said, times over badget, the bitterty can. '

MRC spokesman Frank Ingram said tested plant won permission to conduct seabroor low ter.1 t** ting uonna u twpour swa ruer this month. n not affected by the beid="+. and the layed by one vults malfunction. h ww -- awon't *=y Cop *mtore) .

saade a mistaks." -

tagmm . aid arown and NRc Deputy gegiona! Mm'aimerator 'Ibotnas T.

Martin discussed the lpoldent in a tek.

pbce,e call Friday. _ , _ , , , _ ___ .

hh . .

It is appropria e for the NRC to take the hard Ilne on . .

saky. It is also reassuring to know that the NRC istaking t

  • if appropriate procedures at the plant were not ,

followed* an.henann

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tests began June 13 and had been run.

Ingnun amid Brown agned that the n!ng ereothly unto the shutdown, plant wiu delay resumptice of low. mead by the laaet va!n mamme.

power teste unts operaten pinpoint tion on the nooeuclear side d the why the valve malaunctioned, make any plant.

noonasary short- or long term repairs. Dianna Dunfey. a memkr # h '

and review the actions with NRC staf anti-Seabrook Omm^=D A13anos, said in a meeting - as yet unschdukd ,

  • ~ har group thinks the aftnation is amore Ih*h*EI D'ggC sam t ta tbrough serious than Seabrook or fadaral co!.

nelew d tb reactor shutdm" bdors c!als haw said.

3crw. power tests resume. "Our fullas is that fbe the N'RC, Seabrook -}1 spokesman Roo. Shr eald. chametsrtstically irresponafble la their ud1!n3 of probleens of this nature, to take this step indloates a very serl. .

ous breach by operstars." Dunfey said.

Gov. Judd Gregg said he was not dio- .

f turbed by the attuation, "It la appropriate for the NRC to  !

take the hard lins on safety" Gregg said. "It is also rsassuring to know that the NRC is taking the necoseary sups to ecuare safe operations if appropriate procedures at the p; ant were not ~ ibl.. .  ;

lowed."

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'l Crteking down on po11nters a

in ~ cne-~na.

Incident nresents Shannon hu more than 250 etyt!

.E i g and 31 criminal cues pending -

, agamauu--s au a forum for Shannon tes suspected ofillegauy damsing of tex.ir. wastes or l'uting th air, He hu shut,

, uter or wetlan h(( The routine is becoming familiar - the Nuclear

' den firma whose products emit -

chemicata that puncture the ' '

i carth's anore layer, fweed tod!. '

, Regulatory Comm!*alon announces a dectaton on the

Scabrook or Pilgrim nuclear planta and an hourl Lynn lat- and.other communides toupgrade their sewage tre er Meanebusetts' boyish looking attorney general I cracted bra on texte dmapers steps up to the televiaton cemens, excoriating the , and ydned with Gov. Duktkis to.

NRC and vowing to fight on. create what may be the natim's To his crities, the scene is a powerful symbol of what they consider James Shannen't hot dog ap- toughest environmental strike ge, proach to volattie energy and environments: tasues. Whfie thtre is riot enough data "His posjtson on Scabrook is highly politicaPy mo-ttvated. He and his people knew he dian't hr.vt a le- to compare his reced fair'ly with those of his predecessors, one ga! leg to stand on in his attaels on the kne power Iscwoe," said one energy special:st whe also opposes yardstick of succesa, the collection of environmer.tal civil penalties, Scabrook and who. hke others critical of Shannon. hu risen stead!!y since Shannon insisted hb name not be used. took omae more than two years l But td his supporters, Shan. ago. .

non's outspoken oppositten to in fiscal 1985 and 1986. when

.' Seabrock. P!fgrim and the NRC yrancis L BcDont wu amey have been on ta and vital to general, the omce netted $557,000

ceunter utilities' - er financed' and $806.000, respeettvely,in fle better orchestrated campal s. cal 1967.when $hannon wes tak-I

. "He has been both e ettve l ing over for Bellotti, it coDected and committed !*m just real e912.000, and in fiscal 1964 col-pleased about it " said Robert i nections shp to 41S mm.

4 Backua, an attorney who hu bat- "Enytid:iment is very ti!g. and -

tied Seabrock for 17 yests. Ed. 1 view enytrorunental arob; ems in ward Brown, president of New this state he betog Ilks drugs: .

Harnpahlre Yankee, the company They pose a tremendous threat to that runs Seabrook, also paid tri- our security and they're perva- ,

buta to Shannon: "He's a whale of sive," Shannon said in an inter-an opponent toug:. and hard- v!cw. "In fact. they're so perra.stve -

working." you know you'll never have the A fair tesding of Shannon's en- k.nda

' of rentnes you nw! to ,

ergy and environmental record bring all the cases yera need to weaves together both outlocks. ac- bring. So ytra must up the s.nte cording to interviews with 15 peo- and change the whole attttude ple who follow the issues closely. about environmental epforce-The attorney general clearly ment.

courts the press e.nd rellahes the "We'rs trying to show poUuters chance to speak out the way he they're not poing to get a alsp on did afteritst night's suspenalon of the wrist. They run the risk of Seabrock's low-power IIcense. Yet criminal recxcs and very heavy-be can attract attention because f!nes EDd the stigma of being a be has succeeded in prosecutin( polluter." he addec.

polluters, defending consumers Interests in ut!!!!y rate cues and, as he did 14st night, championing the antinuclear cause.

Shannon's atyle and subatance .

are receiving increued scruttny

< now as the final battle shapes up over seabrook, as Pilgrim nears full-power operat:an and as the at- .

torney general faces what la ex-pected tQ be a tough Democratic primary cha!!cnge from Scott Harshbarger, district attorney in' Middlesex Caanty.

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DATE: 6 ,,26 gf PAGE: / 4 a./ JW [g j deprootsting bf: pay [rA .,

Shannon's office also repte, preaches developed in the atter Bad a tough act to fallew ' T-ney generars ocice are not so!Jd ht e d sents ratepayers every time an

  • electric or gas company asks the - legal representsum. They are p
  • they are 1 uca uvated s,nd desfgned to . u,. Bem w 15h 7 Department of Pubhc Utilities to

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,g i . years in omce was seen widely as i increase ratas. 'We have saved g h nr a 1 ng . I aa naue n Co P1 m

.. brock and Pfigrim, ts many ,jen at. enew and -nnw is ,rg; a ha 11 n do! .

say cannot be wm an take away ',-

D puty Attorney General Donna "l5ellotti mans to do the nt-from other programs. But Stephen a as annon, but . ,e Jonas, a deputy sttorney general '.[

g $ tate Ayers only paid who overseca the nuclear cases,.

(Dg polltleal, enjd a 65 g our 1 representa- said spendi on Seabrook and udht oh An energy lawyer ,~,.

tion. If eJectric utfhues saw a re- said hannon is "about ens tenth m scal M which .:.. what ScDotti was, which is OK in turn that good or. their tnytet- ** . .e snent, their stockholders would be in seventh heaven. ahe added.

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$20 milhon, or 4 percent.

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some cassa, but overaH. there's no h*5 comparison." A third observer ## .

John Rowe. president of New Shanno h high Whte Aamm' E d Ele rtrJc Co., compliment- , .;. In any elected office. "Behatu h

annon for helping work out went in sa ng he was to ed .h & Mde make this 'best law fu a deal last year where a subsid- If not only has top al talent but nh 0" tary - New Eng7and Pcnrer Co. -

to write off more than half incred:ble pubhc re attons efforts. nj ,he t

,,.gymE' g W m ww Prl

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~03 o its investment in Seabrock. They're well-financed and try to' '.f. But homac K!!ey Bellott!*s

" first saa!stant, said it is unfair to 0 "The settlement was pra matic and constructive. It cau us to

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y A comparc Shannon's reoart! aAer

l Y ust we'll match in lose money last year, but we're a eoor or te the DPU or RC. f.r. just two years in oMce to Bellotu' ac sounder company because ofit. in Alan Nogee, an energy special- 700.re t j to a very com licatedjob.and Frank m tot at the Massachusetts Pubtle in.

..A these peop e are sur we lear da t ht h A m u N "

prised by the degree to which we years. If M aW 2 h a -

terest Research Group, amid Shan-non has done an "exce1}ent job" match them every place we can. y comparison compare both c(theer. l' first years in c#hes." Kucy t sid.

protecting ratepsyers* Interests in ut!!!ty cases. "He also has been "When Jim s***W Frank. :I very aggress!ve pushing util!Ues Frank told the world tlus we a n-to invest in energy emclency, co- .

worthy suemuar eag from the **ri same general mold as htm. with a t-genernuon and renewable prejsets commitment to the en-neron alnking money into build-ing unnecenaary power plants." vironment." . "That er was absobtely true." y.

"A profsesional politician a

  • Shannon said be is not intimi Others see Shannon's record dated by taking over fmm Bs!)ottt:

diffuently. "It has been very .

spotty." said one lon me energy 'It to torn eatfer succeedbg cral than !! would beatogood g at g;.

attorney. In highly pu heteed rate su a bed attorney .

cases such as the one over PU- We s!Arted with a t and

m. the attorney general has then I est my prierttise ased j .. r very acuve, but in less vist- have,,my own ,teproach aswL g ,

ble ones - Involving Boston Gas, *!Y IC- '.-

. I for instance - Shannon "was a "' " ~ ~~~~

~ * ~ ~ ' " * " ~ ~ ~ '

partlefpant but not a central p!sy-er. If someone te!!s you Shannon doesn't do anything. that's unfair..

But," the attorney added that "tf they te!) you the omee does every-thing." Inst was not the case.

Another energy expert -

"Shannon is a profenalonal hu-clan. He has never pract law.

A lot of the decisions and ap-l I

i

FAPER: hM M _

- Lf 6 .24.pf PAGE: / x.s / .a g DATE:

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,. NRC.tvwn said

.NRC omeials that they.also will U s-

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.. how a eeu * ;,/.

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- 1 Cited

,m m. % <. ope,a,,,s Re m.e.f. Edward Markey (D .a r,ue e gy,ry.- closed the valve and continued to brook,last ritght offered an anal-!

for recent events at the plant ,

The Nuclear Regulatory Com.' montt6r .

l the system. H!nutes hter.

  • brook ooerators wen trying ,

misalon last night took the unusu. I they dedded to shut down the re.

scior manuaDy. to ptJe their driving test altar,,

al step of suspendmg low. power - We did not strictly adhers to having taken the written esam.

teste at the Seabrook nuclear I our test procedures during these Mt the car out for the plant until its owners explain When first time, th;;t M NRC found it neces :

what went wrong during Thur, ebanges in systern condluona," nry to rea.ch in and put on the, daYa unplanr>cd shutdown of the Drown said in a statement. "The brake to shut the plant down be ,

NRC said we wajted several min- .-

reactar. cause Seabrook operatogftdsot-Before the icsts can resume, utes too bng before actua!)y per-forn11f$he Ahutdown. t loow what they were doht 'N *

"they*!! have to corne down here '1 think It's very frightening to han a management meeting . "At no t!me'was there a risk to think what wouM have happened 838 with us, explain whn they've ' CF plant.e tems or.to the general if this plant had been operating at '96 k executive l d"** "*I public, the y' .. 70 to 80 parts 1t of power,' "84 o sel"g,a .in said the NRC Kar! Abrahazn.right l 8 added.

t thin .conymoe us it's the there had been no NRC "S

, of!dIln PensiiFylvanisi.~" _rtgiona Seabrook NRC sWaman Abraham sam the control room." Markeytr . ..

.se h. i Seabrook onicials last night operators "dM not do things the procedures caDed for."' . Shannon sam be wGIinne this'%q said they have no idea how bng The shutdown they wen under- week's events to beAste~ .as the de!.ny wtD last. Edward Brown. board ,!d taking, the NBC cmetal added. MRC a president of New Hampshire Yan- er tests unutAH iki.-

kac. whjeh runs the pknt in Sea- "has been requirtd of every plant tasues requ or fuD5oweroper-brook. N.H., sam the NRC's accon ainee then was a Three Mile le- ation have tw.:n revi',wt.

w s prompted by the fact that * !and." referring to a twar nelt . .

tr*.

down at the Pennsytytnia pkut The 44 btnion plant was rup7 ni "we walted several minuten too  ;

long before .actuauy permitting ' in 1976. . ning at 3 percent of its power po- p l 3 ,

i the shutdown." .

' tental when it was shut. Before it ~

1 But Massachusetts Attorney William Ruseell. bend of the can get a fuD-power license, plant g3 General James Shannon said the NRC regionaloffice,sent a htter to omctala almo must eattafy the NRC .3.n troubles at Seabrook run much the plant's crwocrs last night set- svacuate ting four cooditsons for the tests to that they couM saf er an acci go ,m deeper:"It le a question of wheth- nearby communtues er. operators kno_w _. how

_ to.respoode.. 4 cumenting resume: Thursday Seabrook mustde-

  • a evmta, linkh do- dent. ,,

c -

,~ m

' cpproprately in the event c( an *

.. '" ' wi termine what quick f!xes ad need- *

' accident ... the NRC pointed to - - o .. #

' those same problems a year ap . .

after a rnock evacuation exerciec I Seabrook started sta low power .

teats June 13. and they were scheduled to.run about a week.

On Thursday, however. a :

steam valve ~in the nonnuclear s

sMe of the plant renained open '

longer than intended and too

/much steam was sent to a con-

, denser. causing changen in pres-sure and temperature. In the con ;

DATE: (g .26 ff PAGE: / LM A -

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L N N h By NICK TATE

? lie NUCLEAR Regulatory Commission L ~~

ht 'rde~tN ~crities, Johgy Bay State Attorney Generaj James Shann6rt aaid the gliteh a and operator errors point up se- l 1 6 h} der'tsk

%xrvra wha

.have been for the people !!ving A nsarby).", & 4 .'s , ,

. Saabrook officials acknowl-edgid operators fMied to ad- l.

4 rious flais in equfpment smer. ' hare to NRC regulations in de- I rd . red Seabrook Station yesterday to gency preparedness plans and

. bort low power tests until operators ex- laying the plant's shutdown, employe* training. but denled claims the incident

.ls.in why workers ignored safety regula- *1nevitably, if you shortcut ions and failed to shut the plant after a safety procedures you're going highlights caws in plant prooe-naffunction. i to have preblems and that's duren.

Handing Seabrook a serious setback in ! what we're s+e!ng here," sajd At no time wu there a rtak ta atemmering first steps towa.rd full Shannen, wbo hu led the to Pl ant systems or to the gsn-state's opposition to the plant.

eral public." said Edward

,pera13on, the NRC indefinitely suspend- Drown, president of f,cabrook d reactor operations and faulted contro!- ."The EC has been doing operator New Hampahlre Yan-oom workers for wrJting 'severa! min ;, whatever it could to make !! i kee. " Control room operators at easy for these guys," he added. l all times mdntained safe oper-Jtes too long" to turn off the reactor after "and the 'rer41 is rnistakes t faulty valve failed Thursda'y anernoon. have been maae and the plant ation otJhe reactor."

Rep. L! ward J. Mukey (D Mass.). a ' is not ready for even low power . Tankee a okesman Ron

'.abrook opponent, sald top NRC officid:  :

sbar said the . dent osm t e sts."

.old him an NRC officlaJ in the control -Shana aW en pant & M j ,c,r,m m, @ M M ,

room ordered workers to shut the plant ues said ne EC dedsim non plant was running at I pe -

down when the problem s. rose, but noth- echoes concerns raised last cant power.the peak of.the lo**..l

.ng was done until he " grabbed" one em- sumrner during a mock emer- power testing procesa.

p;oy,,, . g ency at Se atrook. .which . A valve on the non nuclear i turned up "wesiness" in re- cide of the plant dulgned to

.What we have here is a situation direct steam from four g;snera-where the Seabrook reactor operators sponse efforts that rafaed ques- tors " stayed open too long." .

cre not able to follow their own proce . ttor.: about workers' ability to handle an unexpected event. The malfune!!cn caused Igps, An.d_an_]iR_C,pjffg!g!_fu#e. control. more steam to be convarted to But ne EC last faM dented water than is prepar, which ,

room, first having given a verbal Instruc, Shs.nnon's bid to initiate full-tion, had to physically grab one of the scale hearings on those weak- would cool the nucleu core too -

Seabrook operators to ensure that prooe- neassa Ironicany, an C quickly.

dures would be followed to shut the plant, Eher yesterday said the panel b ard rejected sha.nnon's Mukey said' ' '" ## "' E#* * * " " " #

down Seabrook immed!s.telb"sman spo Rob M1111ams " EP' "'

ce$ca t ciftt[$

laputed Markey's account, saying,"That d'U I[on't want to say, 'I told dn't happen. P!s.nt officials said it was you ao,' but I did in this case," cials.

he said, vowing to mount new But NRC rnonitors inside not NRC mon! tors but Seabrock stafi that the control room observed a first noticed the glitch. efforts to open hearings. violation in regulations when ,

Markey said the incident Seabrook operators waited l Thev.also aald phgrettwas no "rnoving" b#

  • Per' backs ctponents' ctdms that-i ators or test supervisors b7 three to four minutss" 8.fter

,C yRC monitors during the he . rata rgh19rAnnet M matelyLad the inadequMa' malhmetton~eva-to shut down

, ev t, and rndatained the inci- cuation plans for Assfby test- lant.

2e 17her asJd a report on the e would not prove a major - dents w{ll leave thoussnds at event will be completed next g - risk. . . _ .

M .

"I th!nk the 14ason that he.s week.

g - The NRC. wh!ch lut inonth -

. authorized to be learned la regard!an of 14w power tasting at the Seabrook to begin 1,150 megt,, watt pts.nt, the first a!! the assurar.ces Seabook offt-

. the tests. said the action did not - c!als are giving that no acci- phase in Seabrook's operation. ,

constitute a revocaten of the dent wf!! happen, we see that was approved fast month by low power license, but opera- human beings make mistakes." ! the NRC. Put to move to fuit-

.tfons will rems.In on hold until lhe sald.  ! power operatiot a, Seabrook

, S(strook officfals provide an ' mui{ first wto NRC Approval nccountlng of the shut:fown and - "Th!s event occurred at a f for.'s!* Bay Etate towns inear percent power with MRC mon!. I the plant. < -

.f take f% m long. m e... and sho.rt4erm.

. . . . . . ae,.

. im In the mom: If this hat-

' PAPER:

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/p - .2e/, 79 PAGE: lo DATE! _-

. el . . y. n. .. .*. ,

lfarley: Seaarooforder.[gJ*.#eignored  !' .

SEABROOK, N.H. (AP) - A NuclearW M N h Phyelen% eseb ese Re tory Ccem!wton oWW had to physi...at the Seabroek opmeses k meursvabet ca[' grab a Seabrook r.ucJear plant omcW to . M be h to h ,theM kmediately."_Masbay4 d make opentors shut down the reactor when a - A two.to.four.mtmrts tima pedod had ,

valve  :::dationed. a 1+adir.g nent said he was told yeetarday.-

Seabroek oppo. .

.e'apsed before then,was.stf.dl trip. Ma{ key ;!

J. Markey U-Mann. said top d  :

ometals described a a*yaence of Itat didn't happen." Seabrook apobeman i NRC . .

Rob WiUkms aid in response to Markey's >

eventa which an -NRC o&ial in the decription.

Seabrook control 'soom Thursday ordered Williams said contro! room operators el.

workers to shut the plant dewn, but they did jready were sware of the situatica when the .

I not Ynd. NBC oWW spoke up. nad thew minutes hter "What we have ben is a sitantian when the decided to sbut 6:wn the nector. No one was .

Seabrook resetor operators were not able to pebbed.be said, foDow their cwn procedures, and an NRC Markey is a member of the House Energy s 8

,omeW fu the control room, fint haing gfvon a and Commerce Committw.

I t

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9 8 1

1 1

PAGE: / 4.s 4 e5 (p / p'.2) 5 a2 -5 4 7 -

r DATEf -u g But the test director then

  • i ta ed to the shift supervtaar, a

'S' *R*u^ , 3 ' im.ior h nh,n ome a,. ho .d t pressure was dropping on its O oEh and that there was no need to q

[ I da '

Ru y p eo in at that op-

~

sy Tye critions manager. The amnistant s

f, Gio aggpager consulted the operatsons Nue) car Reguktory Comm1 melon inspectors ad- sepager *wbo acktenrkdged the yked three omekts at the Seabrook nuclear plant to ' int 8rmation and deferred to the turn the reactor c6 last week. but that advice was p of the shift supervisor to ignored. NRC omctah said yesterday. continue to operate. Itorwitz It was not until stem:n pressure began rising that Seabrook officials finally fonowed their own j said. _

dural requirements and closed the pknt. Noel .

-**They were making a con __

Dudley, the senior NRC inspectoe at the plant in t Seabrook. N.H. If pressure had continued rising and

  • r meious dectaion to attempt to re- T other safety systems had not responded. p! pes even- gain pressure control. Du ey could have cracked or other probens devel-tumDy% added. he the wa M oped.

That delay in shutting the reactor lasted only 5 '. , _ _m , .w recufnM_. {

minutes. Dudley said. But NRC omcials felt it re- ihey had wittten into their I flected a sersous enough disregard for plant proce- i

( dama . . . a was a cow " rs na .

dures - and apparvnuy for the advice of federal " SiiabrMk spokesman Ronajd .

safety inspectors - that on Friday they took the .] Sher said that the operster in highly unusual atep of suspending low-power testa. I charge Thursday chose to con-

' tinue to monitor plant conditions litore than a dozen Scabrook of .

  • because were nturning to ficials are working this weekend . tbc test uon . . . Several min-to sort out what went wrong last * '"***'"***'
  • cck *nd to el ** "P '2'h *h*r M~~m "t**

that " the'h*

phat "P*dition con was not 5-

,d ten -range p ans to cormet within the parameters c( the test ,

t 'p .a. While they hope to procedure, and then he shut the ;

t those plans to the NRC ' phnt down. .

week, otnervers may It win .

s not longer to Irpair the Phnt ame%1a maintain that then was never a threat tgo .

feed public tmage of the con. ~ Rep. Edward Markey (D*

I 66 billion plant. t Mass). a mensa Seabemk foe.

h first hurdle is to retrace ' aaid he was tdd byNRC chsArman tned habpened dudng the un 3 utdown Thursday.

Lando Zach Jr.amiother W 4---

anon omeials that after federalin; e reactor was in its 10th day s{wetors were ignh they aW*

Qw-power tests aimed at deter- say grabbed Seabron operatom g how vital systems perform to th*gn to respond.1Andky &

er actual operating condt- that.sa "It,,was only w

. Shortly after noon, a valve J """" "** l B2he nonnuclear side of the plant Wh!)e a five minute delay may }

.alned open longer than in. seem tneonsequential, industry and too much steam went spectansts say fath!re to follow condenser, causing pessure procedures to turning a plant a6 g3se, , could create cafety problerne.

M"easure hit 17 percent Even more important, they said.

Wiey and an NRC spokes- gg .g.bree Mt)c laland and Cherno-inTLn. Steve llorwitz, said that an a@ts show how vital 11 ts ligp inspector then approached for operators to be weD-trained thy startup inanager who osm and to follow procedures.

ka-power tests, remindtng him Winiam Russen, head of the (Mt pressure had hit 17 percent. NRC regtonal omee, we.s sum-t , point at which the plant is to My merr,ed that be set four

. . shut manaally. When the tnan- conditions for Seabrook to resume apr did not respond, the NRC in- low-power testing: Plant officials s;2xtor approached the test direc- I torrwho was ekmer to the scene in tWeontrol room, and the director agreed the plant should be shut.

PAPER: dent- //2c _

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DATE:

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'It's very frightening to think what would have aappened if this plant had -

been operating at 70 to 80 percent of power and there had been no NRC peo ;

ple in the control room.'

-Rep. Edward Markey, a longtime Seabrook opponent t with no Dew plants being buh must fimsh documenting Thurs- worry thati e federal govern day a events, determtne what has g3ven their many critics new commiasion staffers "8'" have more time to pollec eXi*l10E quick fixes are re$cd. speU out ammunition. "There are people long-term corrections and review who are opposes! to nucles.r power. Others said it evidences a new those !asues with the NRC. and they always try to genern!!ze toughnesa by the NRC.Dut Pe from a specific mistake." vald an top nuclear s,dvuer, was akepth 4RC launches own probe executtYe at a nuc)caJ plant that hfiis'iiDie. LDe~ 3 cal: "The NRC may want to dem.

1surched its own tovesugation of has faced similtr ersticism from - <

- 4 the incident, and thadley said that the NRC.

wary puby

) onstrate to a (y.guant s,nd caust wtU take longer than the week , "Very f%tening to think" that 11 is very

%orooK esumats for its renewf Massachusetts Attorney Gen. some people to relax a bft a Neither NRC nor Seabrock of71- eral James Shannon, one of the future events on bcensing - .

cials would speculate on when most persistent ertt:es. already while it shown extreme Iow power tesung may continue. has vowed to use the NRC suspen. to very minor technics.1 While issues rstaed by the sion to raise larger questions continues to {Mrtgard larger ,

shutdown probably will be re- about whether Seabrook opers. ty ques *Jons. l solved soon. obsencri say it wiu tors are qualified. Markey said.

take far longer for sesbrook to re- It's very frightening fo think store its image, what would have happened if this Righ level NRC omeia.in have pts.nt had been operating at 70 to lavtahed praise on the New HamP- 80 percent of power and there had shirt plant in recent years. In con

  • been no NRC people in the control '

trust to their frequent cridciam c( m-file Seabrock's public stand-the Pilgrim plant in Plymouth, Masa. &abrook umetals regularly ing probably autrend a setback assenet! that the reactor is the sa- frorn last week's episode, tbe fest in the country. NRC's may have been bolatered.

Now. those same ometale may The agency has never turned down a l$cer.se for a completed nu-char plant, . a.imeet always iets cloecd ones reopen, and substan-tially amended its ru}ea to ease Seabrook's path to heena!ng. Mar-key says the agency has become a lap dog, rstber than the watchdog 11 was intended to be.

l Given that history. the dec!-

l sion to suspend testing surprised f and delighted some NRC crttics.

One industry source said It reay simply reDect the fact that l

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wup SEA p ~ BROOK , N.H. (UPI) _ Secbrook nucloor pownr p3cnB o00icioBe, @e00ro finally complying, shunned early warnings by Nuclocr Rugulatory Commission incpectors monitoring low-power tests to chut down the rocctor brcouse of a malfunctioning' valve, commi ssi on of fici alo said.

The shutdown on the 10th day of low-power tests last Thursday at the coastal reactor prompted the NRC to suspend f urther tests pending a complete review of ths scenario that led to the unplanned shutdown.

The shutdown was prompted by a malfunctioning valve on the non-nuclear side of the plant which produced readout changes in the nuclear portion of the plant that did not conform to operation guidelines.

NRC inspectors interviewed by The Boston Sunday Globe said they approached three different plant officials to point out the problem. Seni or NRC inspector Noel Dudley said the officials acknowledged the problem, but did not immediately respond in accordance to their own operation guidelines.

Seabrook spokesman Ron Sher acknowledged Monday that the operators did not initially adhere to the guidelines, which call for an immediate plant shutdown during such conditions.

"Our control operators knew at all times we weren't in the test conditions we established." he said.

But. Sher noted. the operators knew there was no safety risk posed by the problem and attempted to remedy the situation before shutting the plant down l several mi nutes l ater.

An unidentifi ed inspector first approached Seabrook's startup manager about the pressure reading. the Globe said. When the manager failed to respond, the NRC inspector approached the test director, who was closer to the scene in the control room. The director agreed the plant shoul d be shut down.

However, the shift supervisor, a higher ranking of ficial, told the director the problem was correcting i tsel f and there was no need to turn off the plant, NRC spokesman Steve Horwit: told the Globe. Dudley then approached the assistant operations manager at the pl ant , who relayed Dudley's concerns to operations manager.

The operations manager def erred to the decision of the shift supervisor to continue operations, Horwit: said.

Dudley denied cl aims by Rep. Edward Markey. D-Mass., a leading opponent of i

j the plant, that NRC officials had to grab operators to get a response to their Concerns.

Nevertheless. Markey said the reluctance of Seabrook of ficials to abide by operation guidelines that the) established i s troublesome.

"It's very f rightening to think what would have happened if this plant had l

I been operatino at 70 to 80 percent of full power and there had been no NRC l people in the control room," Markey said.

_________ upi 06-26-89 08:39 aed (Editors: spelling of Ronn is correct) Official: Wolf Creek already controlling radiation exposure BURLINGTON, Kan. (UPI) _ Wolf Creek nuclear power plant officials have already taken steps to beef up some weaknesses as outlined in a Nuclear Regul atory Commi ssion report, plant spokesman Ronn Smith said Friday.

NRC officials met with authorities at the Burlington plant for just over an hour Friday to review a previously released report on-Wolf Creek's performance, Smith said.

Different operation areas were given ratings of category one, two or three, with one being the highest, he said.

Smith said Wolf Creek was scored in category two or above in all, areas of the report, which covered the period from April 1, 1988, through March 31.

A rating of category two means that utility and federal of ficials should continue to be diligent in that specific area, Smith said.

~ -c w -

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DATE: 6/27/s9 PAGE: 12 I

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'th , . .n*.* F A$RG#-pl. a*'+.' * * *!* f ' .*.T.*ns>probee . . .

6f Sealiropltglitch.s  ;

By NICK TATr' elose the $6 bt!!!on plant la a, -

timely marmer.

THE NtJCLEAR Re latory NRC =ha==e Karl Atra. I Commlaston yester ay an- ham eald the team wi!! take %

enounced plans to send its own to t!.ree W to conduct thel. ~ /-

Jnvest!gators to.Beabrook- - And premed us endings to - f-Station to probe a lant mal' 'RC occials who have the ,l function that led a NRC to power to uft the stay et the testa, svepend the reactor's low which are the erst stop toward WE N -

power tests last week. - ha- 4mapproved fu!! power.' ' * '? , ,D.W %3 3. -

gp. s; The five member Au ent- a NBC halted ,t'

'ed Inspection Team ( ) will Seabrook workers wsjtedtesta after

" sever- ~ * 'a meebor acted the hf l UA 4 Edward (D-arrive tomorrow to conduct in. ' al minutes too long* to shut the . Malden) said an NRC nen tpid

. torviews and reviews to supple , plant after a vs.lve malfunction. ' Mm R wrant usstU an NRC anass.

, ment' Seabrook ofoclais' eelf- NRCccontrol. room anociws assessment of the incidents told sourcea the' operators faded ,' ter , =5ralAed" and amoved htun a cosdrottoose into surrounding a valve malfuction that the was iThursday, during which con , to- violation rwpond dtoNRCthe regulations malfunction in .

and gegangok who haes

trol room operators !alled .to , hesitated,toAhut the reactor after
  • gh;ee naar==dt saidther full m ,", he.T .coperets" . .. .$ tho' In a esperata sotica punter-day theNBC permisoloa

.to the puolear peer M to aque frosa se pe,r, cent to N porosos power, aspart of a gre.,

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603 474:9521 2728 AN-27-1989 . 08:40 FR0t1 14W CORP. C0tti. TO. 1512153375241 . P.03 Seabroph Continuedtremrage supervisor.

~eeptable under New Bam According to the NBC. the opera kee'stestingprocedures. pabire YaE.

tions shift supervisor reported that

$ber stressed Needay morning operators were taking corrective ac that at 30 time was the plaatle viola-tJons and the plant systems were tion of federal safety proo:dares. He reaching the recovery level, Homwitz said the operations shift so- said the test procedsres were estab-pervisor did not tale action to Abut liabed by New Bamsphtte Yankee down the plant. and are more stringest than NRC guidellaes.

He said the senior NRC toppector Contradiettag the NRC's report in the cordrol room then rained the and New Bampshire Yaakee's issue with the assistant operations of the massal abutdows n manager who acknowledges the situ- 17.$. Rep. Edward Markey. D Maasa.

stion but deferr atiens manager.ed action to the oper- chusetts, said NRC ed5cials had to nab a plant operator le force a ab*

Rorowitr said at this pc4at opera. Down erthe sneletyreseter.

tors did plant orderpressure because the shutdown in the of the Ifarkey said as NRC ed$cial told systems was increasing rapidly. plant him that plant stars we**

  • down the plant baBr warned to Artc; ding to SeabrSok Station med then, wbes the order was not te spokesman Roc Sher. operators were loved, a federal taspector grabbed sware of the situation is the ecotrol and forced an operstar to abst dews room when an NRC einefal an the reactor, nouoced that test procedures caDed NRC et5cials deny met W W for a eanual shutdown. He said op. spectors had to grab a control rose erstors had deelded to monitor ecc. operator as was s5eged Friday by , ,

trols untilwas shutdown it became required. clear that a MarkeF '

.PlantN*ta also deny met a M

$ber r.ald. at about 12:30 p.m. era!!aspectar grabkd astreet la the nursday, plant eperators became controlroom. .;

sware that a steam by pass valve oo De shutdown of the resetor oe-the non-cuelear side of the plant was carred is the leth day of remaining open too leag. The valve testing as plant aperators ted was dutetlag the steam that during the flaal test, the astara! Mtics normal operations eould drive the test.-

turblot into the condenser, ne reseter was opers Aetarding to $ber. because the eest et fuBoower capa at3g valve was remaining open teolong. it the problem with the valve was de-erested conditions on the suelear teeted and the reactor was tripped ,

side et the reactor that were act ae. .

1 EughmEDeG.

4

_ (&dtinuedftedFage'Unet . +

pptretiIns lbr hall. pow 2r cper tirn. It w:s a lowpow;r licenzing process and thus held the mannement Cilliamt stid. decision a business dieleIIn." force cren NRC rssulatirn.

g Instead, the operat:rs balked fbr about 4.

< Williams. said such under a full. power liconse." but seabrook tests "cre usually done five minutes. First. according 13 NRC spokesman

. omelais had initially thought it more prudent to . the ptgesuriser to the plant test director. Steve k* H

-deltnow.' ' '

Edward A- Brow n. president of Seabrook ' "this individual nodded his acknowledge's operator. New Hampshir, Yankee. said. *We ment." said Horowits. Dudley said the indl.

now want to concentrate on two issues belbre us vidual. because he is not an ' operator, wpi

- thoroughly fulnlling" the NRC request for not empowered to trip the plant.

' 4

e Trapp then approached the last engineer

  • Information Pr* parley theabout plant fbr thefbil-power unplanned shutdown and and test enortlinator "and raised the sanpe -

operation. .

. .i e

, eh ometals at the plant hope to begit. by the Assue with them."Horowits said.

  • year. ..They eeneurred with th's need for'd, .M Plant omelais - acknowledged their opera- saanual shutdown and the engiacer approached - .'

lors should have shut down the plant last the shin operators supervisoc.who is la charge of .

Thursday about 11:30 p.m. as soon as a water controt room aperations. Ne thee ralsed the lseqp * . ..

pressurher in ' the reactor sh!! to a level with the test supervisor." ...

which had been pre-designated as the level By that time several minutes had passed .!

requirtag a manual shutdown. and the supervisor pelated out that the Why they did not follow procedures is a pressurtser level was beCinalag to correct ,, ,

primary pomt of the Internal Inquiry ordered by itself.Horowlta said.

the NRC.asid W1111ams' Dudky then entered the evntrol room and .'.,.

pointed out the problem ' to the assistant

..::i Brown, who admitted yesterday Se did operations manager. Horowita said. 7 4 M <*

not strictly adhere to a test procedure" said . 1 SDM Yank xpects to submit its report to the NRCin "He said something to the effbet. *You*ee' early y, . got something there/" said Horowit.s. "He *I " .

  • then went to his boss. the operati ne manager.
  • *7' The NRC will then hold a hearing in public who said that he understood the problem but .

on the incident.

headquarters in King most or Prusses.likely atFa.its regional deferred to the judgment of the smit supervi.  ;.

aor

  • Brown said operators "were in control or the plant at all times. and there was no - At that point, said Horowits. the lowered .

possible hasard tr plant systems or the pressurizer reading had caused increasing water pressure against the walls of the 5.* J '.;-

general public." but said. "we will take the piping in the plant coo!!ng system. It wa'.s  ; !. /.'y

..- - appropriate steps to ensure that a circum- Horowits said. a second reason to shut down s ;, .v /

stanee like this does not occur again." the plant. . { C, :,y' t. ?. .

..

  • r.$. .,

- According to the NRC. at 12:30 p.m.. NRC

' [2 "My understanding." said Dudley. "was that. .>.

N inspector James - Trapp noticed the wster they did feel they were regaining the appropriate .y -'r. -;y:.y?'l W p,3; 7.-l.9 levelin the reactor pressurizer had dropped to 37 levet and they had contret .

percent. The change in pressure was caused by a "But the procedures require an immedi. . .yc.

i );',y. .yJs, ,, s *

'?- , .,

. Yl- ' system. malfunctioning valve in the secondarynotcoolant ate comply."said Dudley. shutdown and fbr five minutes theyg g. did e ., . ,

wg . t /p lg? ,r -

Horowits said "It is thr to enrly to speestate,, so .  ; " L . ,..* *. . ,

"As soon as the' operaters noticed" the what action the NRC may same. Enfbreement .,yg,l-readout. said NRC senior on. site inspector 'actionsrangefrom finestoaaorderofacomplete.-

t Noel Dudley; they should have saanually shutdown, as was done at the Peach Bottom .

,","c,

  • i
a. '

" tripped" - or shut down the plant. It plant in York.Fa. r , .'.;; f 4. ',;v -

C

' ' ' was a step anandated in plant procedures. "But this is not even remotely siellar to  ; 4.fi .f,b' . . .

'. imhich had been approved by the NRC during the that situation."Horowitz said. *

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DATEl 6ho/89 PAGE: uu Seabrook curtails official after shutdown'

~

Globe Staff for the advloe of federal safety in

  • owners of the Seabrook nuclear plant spectors - that they took the high-yesterday said they have alleved d all re. . , lyunusualstep deuspendinglow-I rponalbultles the vice president in charge  : / t about the cir-of plant operationa because of "inappro. tances pnomas' leaving subsequently power testa. Seabrook decided ometals to end the priate management actions" involving yThomas
  • couk! not be reached testa, which were in their 10th

' last week's flawed shutdown d the mac- for,-comment. .

day and were nearly costplats.

tar Jbe action against Thomas Four extra NRCinspectors now

) The emcial.' George S. Thomaa, subse. ma be related to the inconsistent are at Seabrook reviewing events ,I quently resigned, plant spokesman Ron. g l

and Sher said last night. Asked whether CYi Week. re ports from the plant lastsurrounding the shutdown. New Hampshire Gov Judd 0 this ether resignations are planned. Sher said.

A nursday. Sher said the ' week ordered the state erney "It is premature to s shi tdown occurred because a generalto launch his own probe.

adon at thh time." peculate on any other valve in the nonnucket part M Robert Backus. ~an attorney The unprecedented and unexpected th@ ant " remained open longer who has batt?ed Seabrook for 17 I move comes as the Nuc! car Reguletary r thaa required." And his re .yeam, said last night that Dane "in Comm!sofon and the New Hampshire at* lease said the plant was indicates that the torney general are investigating what accordance with the stdct techn!- an' leaving stakes are " kind of high over happened dudng the shutdown. NRC of[l' caftrfteria geverning the curmot there" from last week's troubles cials say Seabrook operators ignored their' lo# power test pmgram." involving the shutdown, repeated advice to close the plant. %e next day, however, the. S!nce 1982. Thomaa. 48 .has f NRC ordered the 'sepc,wJ tests been vice president for nuclear Thomaa. who worked at Seabrook for 12 years, was the senior plant official in, suspended.sayingplant operators production, a poet in which he the control roorn during the shutdown. had. violated their own procedures oversaw all plant operations and But his being'reheved of duties stemmed in21ostog the plant. And Edwant operations snpport. Sher said. He from actions subsequent to the June 22 Brtfwn. prealdent of New Hamp- was one of two vice pmaidents.

I reactor shutdown." Sher said. He declined shire Yankee which runa Sea- both ,of whom p directly to to elaborate, saying details of what hap- brook, acknowledged that "we did Brown. the plant a top official.

pened would be revealed early next month netstdctl Thornas worked for Puhue Sar-cedurce." y adhere to our test pro- vies Co. of New Hampshire, the when Seabrook submits to the NRC its of-ficial report on the episode, in the days that followed. Dud- plant's primary owner,which has Noel Dudley, the senior NRC inspector ' ley provided a detailed review of filed for be.nkruptcy. Brown and at Seabrook, said his agency had nothing what happened in the control many other Seabrook officials roorn June 22: NRCinspectors ad- work directly for New Hampshire to do with Seabrook,s actions against vised three Seabrook omclais to Yankee, which is a division d Thomat. The 'factfinding" phase of the turn the reactor off, but that ad- Pub!!c Serviec. Tho:nas began NRC investigation into the Seabrook shut- vice was ignored. It was not untti working at the NewIIampshire re-down .should .be complete by the end of stegm pressure began ria!ng that actor in 1977 when he was hired this week, he added, but we have not p! t operators finally followed by the Yankee Atomic Eleefde Co.

even begun reaching any conclusion or th r o~n procedural require. Managers who reported to any neommendations, ments and cloed the plant. Thomas now wf!! report dfrsccy to Off!cials at the to b!Ilion plant main- # pressart had continued Ms- prown. Sher said, tained an uncharacteristic s!!ence last ing'Dudley explained. pfpeo even. Seabrook owners hope to get a tually could have cracked or other full-power license this fall, but problems Mped. fimt they must .:ade the NRC

The delay lasted 5 min- that they -

safely evacuate utes, but NRC felt it re- people from a 10 mile radius flected a serious en diaregard around the nactorin the event af for" plant rules - apparently an emergency. ,

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1 FROM PRN PHILA 6.38.1999 14848 P. 1

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\/ T ammmen an amuss m amma a sem m

. i the Comp!!ments of t

r nsvavvavvuse l 117 South thh Suocl Sude 210,R46;Wua At 1010121%GBM) l ~' '

. lane Booth Manspor ,

I i L WBONESMAN SAYS NO. a EXEC AT MJCLEAR PLANT FIRED SEASRDOK, N.H. -AP- THE SEABROOK NUCLEAR  !

F PLANT' W NO. 2 EXECUTIVE HAS BEEN FIRED ONE WEEK i AFTER LOW-POWER TESTING WAS ABRUPTLY SUSPENDED l- CECAUSE OF - IMPROPER CONTROL ROOM PROCEDURES, A I

SP2KESMAN SAID TODAY.

GEORSE THOMAS. A VICE PRESIDENT IN CHARGE

.OF NUCLEAR PRODUCTION AT THE $6 BILLION REACTOR,

'WAS RELIEVED OF ALL PLANT DUTIES YESTERDAY 2ECAUSE :OF ' ' INAPPROPRI ATE MANAGEMENT ACTIONS' '

AFTER THE JUNE 22 REACTOR SHUTDOWN, PLANT CPOKESMAN RON SHER SAID.

-- 18 59 AM EDT 96-30-89:

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l.

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MASMMM: EXEC FIIED -t-6 SPOKESMAN FOR THE SEABROOK NUCLEAR PLANT-JULDL.NOT SPECIFY WHAT' ACTIONS SY GEORGE . THOMAS, VICE PRESIDENT IN CHARGE'OF NUCLEAR PRODUCTION J TM REi4CTOR,. LED TO HIS FIRING,.SAYING ONLY i

~-4RT. THOMAS' WAS . IN. THE CONTROL ROOM AS. AN

'99ERVER AT THE TIME OF THE SHUTDOWN, AND THAT j

'4E PROBLEM WITH THOMAS CAME AFTER THE' SHUTDOWN, 3T:BEFORE.;

j. - ' ' IT. IS PREMATURE TO DISCUSS JUST WHY HE n

~

AS DEEN : RELIEVED, ' ' SHER'SAID.

THE NUCLEAR REGULATORY COMMISSION, THE-M TE.-ATTORNEY GENERAL AND THE PLANT ARE t WVESTIGATING WHAT OCCURRED AFTER CONTROL ROOM '

?)RKERS-LEARNED OF A VALVE MALFUNCTION'THAT~

32CED THEl9HUTDOWN AFTER'NINE DAYS OF TESTING.

AFTER HE'WAS FIRED FROM'THE KABROOK-RELATED PO5ITION,LTHOMAS. RESIGNED FROM IS POSITION As A VICELPRESIDENT WITH PUBLIC ECVICE CO.. OF NEW HAMPSHIRE, THE CHIEF OWNER.OF'-

44E PLANT.

DETAILS OF- THOMAS' DEPARTURE WILL BE IN- A EPORT=TO THE NRC,.WHICH THE. PLANT HAS SRID WILL.

E.SUDMITTED'TO THE COMMISSION'sY.EARLY.-JULY.

.THE UTILITY HAS ACKNOWLEDGED THAT SEABROOK 3NTROLl ROOM OPERATORS DID NOT FOLLOW-PROPER.

. 40CEDURES AFTER A FAULTY VALVE IN.THE 3N-NUCLEAR'91DELOF THE~ PLANT CAUSED A ~

- 4LFUNCTION IN PRESSURE DURING LOW-POWER iEST!NS. .

NRC OFFIC!ALS.HAVE SAID IT TOOK INSPECTORS IVE MINUTES ~AND' DISCUSSIONS WITH AT LEAST THREE StDLE TO PER9UADE THEM:TO SHUT DOWN THE SACTOR.-

iTHOMAS: COULD NOT BE' IMMEDI ATELY REACHED FOR DMMENT TODAY.- THE ONLY HOME TELEPHONE IN THE

. EDION UNDER THAT NAME WAS BUSY AT MIDMORNING.

8- 11 23 AM EDT.06-30-89:

) 1.

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w --

NrN HAMPSHI RE YANK!'E PRCSIDI.!NT Alli.*ACCC REPORT ON JUNE 22 SE AlsROOK s SHIJ TDOWN ; GTATEtTNT OF [*DWAPD A. BROWN PRE 510ENT

f. SEABNUDDK, N.H., July 13 /PRNowtutrD/ '7oday we are cubrnit t i ng our report t o the U. S. Nocicar Regulat ory Comraission (NRC) on the circurnstances currour.:11rD the June W shutdown of our reactor.

The day a f ter this r? vent occurred, I stated that we did not st rict ly adher'u t o our t rn.t peccedures, . and that we would be investigating this incident thoroughly. The report we are releasing today i nel vdet, a det ailed chronology of tho incident, an analysaw l

of managemer.t actions and communications, and a corrective action plan to ensure an incidsnt *,uch en thid will red veeur again at Baabrook Station.

We have spent the last three weeku exhaustively reviewing all the circumstances which occurt'ed before, during and at'ter the shutdown. .While there web no ritk to t he r"blic, plant personnel or plant synteras during thin i nc i deo nt , it .s absolutely clear that our opwrators felled to fol1ow a specttac tent procedure. That I ce k r. coraplianr.e is not excusable.

Wa recognl:e the trus t and ra.ponsibiI11y gtven to us by the NHL.

with the issuance of an operating 11 cense. It is our comtnitroent to toka all act ions neccesory to t ul f ill our responsibility and maintain that trust.

I would like to briefly revistw t he circuidst ancer surround 1nD the avont and thecorrective actions we are taking.

The shutdown came f ollowi ng nine days of hi ghly succes*;f ul Icw-power phyo cu testinD of Seabrook S;at ion' u reactor. Havim; completed low-power physics t et,t i ng, on June 2J., we waro condueling a natural circulatier, test of the reactor. Au part or the proceJure for this t act, <>poretors were required to chut down the reactor if the water level in the pressuri:or- dropped below 17 percent of g copacity. The pecnt.uri:ur ib e compor.ent which reg 21stec prcst ttre

  • in the react or cool .<nt system. ..

This 17 paicent level i s a very evnservat I vo limit. During ,'

normal plant operat lora, the reactor would not be snut down unt 'l l .-

tho level was at 5 percent .

During the testing on June E2, e steam valve on the non-nucacar side of the plant malfunctioned. Thfu resulted in the preunut i m e'u water level dropping below 2/ parcent of capuesty for approxit.utely fivn minuten. Wher, tha level d e'o p p ed bulow 17 percunt , our operators chould have f o l l owc-d theit tent ptvtedurcc and imraediately shut d.w r-i the roartor - but thev did not. During this time, the operatoru

ws
re i n cornplet e cont ro l ot the reettor and the lowet,tpoint the wdter level reachert was 24.5 percent --

well above the minimtur.

5 percent shutdown lesel during nortnal operations.

In our intm nal re d ew, we de t e rta i nec' that our control room operators belin edthat the shutdowr. criterion in the test procedure was only a guideline -- not arequircraent -- because it was much enore cor.scrvat i ve t han the shutdown criterion contained in nurmel

! oparutinq procedures.

I This interpret at i:.n of tect procedurec was unacenptable. Our coropany policy has boer. rewritten to clearly utate tnat all te t proc.ed urs. -- an nor rael operating p e vi e d u r e t. -

roust be strict ly l foilo e d.

We a1:.o conc 1 orbd that the pri. te51 briefiny given to cuntn.el l room operator., w W nct effective, becauno the cont rol reora oprerat oc".,

believed ihat t he shut down eraterinn in the tert prutedures, wet. s q u i de l i nte. Oui- pro te.t briefinD program will be revised to prev.eil i thin misund0 rst enrj a 69 f t ora recure i nQ. {,

During tho f a ve--ras nete. perloci in which thn ibressuri zer's water-2 evel f was beJ ow!'/ perccont, pert.ohnel troro the NRC approacheci three New Hamp hire Yankee c.t af finornbaru to corna nd them of the procedur.il

[ requirermnt tv dtut down the reactor wb nn t he wat er' level d r e p t., below v- 17'porcent. Tho $espOnse. by these New Harap.sh i re Yankrac+ peerw e. r.e er l to 1 'the NRC WGH inoffwtive becauce ihe New HempshireYankee St6ff did not speci fically rivomir. cod to control room operators that the reactor be chut dvwn 4o .necordar.cn with iest proced u ret,.

Lottars vf-reprimand haVF; bMGn Issued to the operations manageraent pertennel presunt 2 n the contr o1 room thet day, to t h e-per%cnne 1 spuhen tn by the NRC inthe contec1 room, and io certain opegrators end eng : rieory, involved fri the.teut.

[ Our internal repvrt focused on the tec.hnical circe.unst ance:

s.urrounding the Junu E& shutdown, and 'we also reviewed our taariagemont I responue to the nhutuosn. This re,vlew 3duntified other problemr.

which we'will resolve to the satisfaction of the NRC and ourt. elves. '

i A number of action % tahan by various New HarapshireYankiee manageruant prerr,onne l were inappropriate, and do not reflect New Harnpubire Yeuik en iI pm icy.

Oui . first oral report tn the NRC that day was not precitely  ;

worded, contained inaccurate infortoat ion and contributed to I rot scomenunicat ion between Now Harapshire Yankee and.the NRC. Le at e ctablinbing new report i ng req uireinent <., to ensure that all futurv comeaunications wit h the NRC ~are rev:eWed for clarit yand a ccu r.s ey.

Five hcure, af te:r the react or shutdown, raernbors of New Harapnh o r  ;

Yankun r, tat f conducted a conf erence en21 witri t he NRC' u Hirylun 1 l Offlee in K2ng of Prussia, Penn., to review the circurostaneen of thia incident. Duri nr4 this phone conversa t ! c.n,. corae New Hwiip .b l e r j Yankee roanagement personrnsi faano s nappropr i a t et at oroont o t the l NRC.in cietenuir vi the actions 0+ our eerdeol evou operatcww. j The Vice President of Nuclear Production roode unauthorized om.'

2 nappropr iat o ntateraent t. to thre NHt; during thra conference enll reym ding ha s desire te restart the reactor biefore the comp 2rtion, of a fnJ3 evaluat ion of i he shut dcmn. Thouc r.t et eraent k w e t it so.,0 w without my knowledge, c ;neuer ence or .a ut hor i n a t i on, ane.l I wau r e. L told that t hot.e t t s t otor nt ., win p tr.a d v *2y New Harops,h i r e- Nenhee pe rs.onnel to the NRC.

1 lator r+1iovrad t he V2 ce Presictent of Nue ear Pevduction of h i s.

d u t i e., at Coabevob Gtatson. He subsequent!y resigned f r ora Public Service Company of New Harapch a s cs Wca wall be anr.ouncing our j raanca g ement vs. a l i g raaen t plan to the NRC by July 28.

Wh : 3 er the tthutdown of Seabrook Sta t ion' c react vr vre June 22 p%ed abno t ut ely norick tu the public, p; ant personnel or plant v.ys t e m ,,

our prorcedures wen notstrictly followed anct 7.ome commusiira.t ic.no with the NRC following the shutdonn ware inappropriate.

I reevynire the credibility all af oc 6t "tvabr evk St at ion ha ee .

worht?d so hai-d to build over tnc years han teen thrnatened by this 2 n c i d es.n t . Our clene chajlenge new id tv implement r eme.vno ry cere.e.t-t i ve artiona, satanty alI of the NAC' n centerna, and ma i n t. . i i . )

' t.hif publ i c trust.

S pea k i s .;j for the m.snagement en:t empluyees ..f Scabrev'. ,Cl at : vr., vs was ; 1 .u tho Joint Ownor , I want to mako it clear thet we ws1: Le si.. 1. f u.-d wi t h not h i nr: : e na.

- r> / /1.U U'3

/f $NT ACT : Non Cher of L'nw Horap h i r e Yankee, CC 4 74- 9S21/

Ctj 4 New HmoP.h:ec Yanizen Ul: New Heueppinii e IN: s'I I 1.

ch

.. NrOM -

__-__-________.___=__________..___-__________-____-_-_________ _ -

. form NRC 489 (I 76)- .

U. S. NUCLEAR REGULATORY COMMISSION

. NRC MANUAL TRANSMITTAL NOTICE

~

[ CHAPIER NFC-0513 NRC INCHENT INVESTIGATION PROGRAM SUPERSEDED: TRANSMllTED:

Number Date Number Date

.TN 050> 18 Chipter Chapter NRC-0513 8/8/86-Page Page Appendix Appendix NRC-0513 8/8/86 REMARKS:

This new chapter and appendix define tM scope, objectives, authorities and responsibilities, and establish the basic requirements for the investigation _ of significant operational events involving reactor and non-reactor facilities licensed by tM NRC.

i .-

6 f

a ,:..

.  ;~ ~

U.S. NUCLEAR REGULATORY COMMISSION

'. Volume:

NRC MANUAL 0000 General Administration Part: 0500 Health and Safety AEOD l

l CHAPTER 0513 NRC INCIDENT INVESTIGATION PROGRAM

'0513-01 ' COVERAGE This chapter defines the scope, objectives, authorities, and responsibilities, and establishes the basic requirements for the investigation of significant operational events involving reactor and non-reactor facilities licensed by the NRC. The incident investigation Program includes two investigatory initi-atives involving ' responses by either an Incident investigation Team or the

'less formal Augmented Inspection Team for certain safety-significar.t apera-tional events. The investigation begins after the facility is placed ino a safe, secure and stable condition, and, if applicable, after any incident re-sponse' as defined in Chapter NRC-0502. Operational events of lesser safety significance will continue to be reviewed and evaluated as described in N R C-0515.

0513-02 OBJECTIVES -

The overall goal of the incident investigation Program is to promote pub-lic health and safety and provide for the common defense and security by re-ducing the frequency of incidents and preventing accidents. This goal is accomplished by ensuring that the investigation of significant operational events' is timely, structured, coordinated, and formally administered; and that a ' complete technical and regulatory understanding of such events is achieved.

The following objectives are designed to meet this goal:

021 ~ Ensure that significant operational events are investigated in a manner ' that is timely, objective, systematic and techr.ically sound, that fac-toal information pertaining to the events is documented, and that probable cause(s) are ascertained.

022 Increase the effectiveness of NRC regulatory programs and licensee operations by the prompt dissemination of the facts, conditions, circumstances, and probable causes of significant operational events and the identification

.of appropriate followup action.

023 Improve regulatory oversight of licensee activities by uncovering facts that could show whether the regulatory process prior to the event con-tributed directly to the cause or course of the event.

Approved: August 8,1986

J.' .'

N R C-0513-03 MRC INCIDENT INVESTIGATION PROGR AM' 0513-03 RESPONSIBILITIES ~AND AUTHORITIES .

.(

031 The Executive Director for Operations approves the investigation of significant operational events by Incident investigation Teams and is respon-sible ' for and ensures that followup actions are taken as a result of each investigation, as defined in Appendix 0513, Parts I and 11.

032 The Director, Office for Analysis and Evaluation of Operational Data, maintains responsibility for establishment and maintenance of NRC investiga-tory capability and for arranging for trai.Qg of ' designated team members, as defined in Appendix 0513.

033 Other NRC Offices have responsibilities for the incident Investiga-tion Program as defined in this chapter and appendix.

034 NRC staff- functions in the execution of the incident Investigation Program as defined in NRC Appendix 0513, Parts 11 and Ill.

0513-04 DEFINITIONS 041 Incident Investigation. A formal process conducted for the purpose of accident prevention which includes the gathering and analysis of. Informa-tion; the determination of findings and making conclusions, including the determination of probable cause(s) concerning significant operational events; and dissemination of the investigation results for NRC, industry, and public review. .

042 incident investigation Team (llT). A group of technical experts who do not and have not had previous significant involvement with. licensing and inspection activities at the affected facility and who perform the single NRC incident investigation of significant operational; events as defined in Appen-dix 0513, Part 11. The llT is led by a senior NRC manager. Each IIT reports directly to the Executive Director for Operations, and is independent of Re-gional and Headquarters Office management.

043 A_ u,qmented- Inspection Team ( AIT). A group of Regional ; technical experts augmentecP oy personnel from Headquarters or other Regions, led by a Regional ' manager, that performs incident inspections as defined in Appendix 0513, Part 111. Its members may have had prior involvement with licensing and, inspection activities at the affected facility. The AIT reports directly to the Regional Administrator. - -

044 Significant Operational Event. Any radiological, safeguards or other safety-related operational event at an NRC-licensed facility which, by its consequences, poses an actual or potential hazard to public health and safety, property, or the environment. A Significant Operational Event may also be referred to as an incident.

The investigatory response is defined by the potential safety sig'nificance of the event, the nature and complexity of the event, and the potential generic

~

safety implications of the event. The levels of investigatory responses are defined as follows:

l Approved: August 8,1986 1

L

NRC INCIDENT INVESTIGATION' PROGRAM N R C-0513-044

a. An llT performs the single NRC investigation of significant opera-tional events which may include one or more of the following characteristics:

(1) A significant radiological release, a major release of uranium recovery byproduct material to unrestricted areas, or personnel over-exposure.

~

(2) Plant operation that exceeded, or was not included in, the design bases of the facility.

(3) Appears to involve a major deficiency in design, construction, or operation having potential generic safety implications.

(4) An event that led to a site area emergency.

(5) A safety limit of the licensee's Technical Specifications was exceeded.

(6) A significant loss of integrity of the fuel, the primary. coolant-pressure boundary, or the primary containment boundary of a nuclear reactor.

(7) Loss of a safety function or multiple failures in systems used to mitigate an acttral event.

(8) An event that is sufficiently complex, unique, or not under-

) stood to warrant an independent investigation, or an event which warrants an investigation such as an event involving ,

safeguards concerns to best serve the needs and interest of the Commission.

I

b. An AIT performs inspections of events of lesser safety or safe- i guards significance. Events whose facts, conditions, circumstances and probable cause(s) would contribute to the regulatory and tech-nical understanding of a generic safety concern or an important les-son of experience will be assessed by an AIT. The characteristics l of these events may include one or more of the following:

(1) Multiple feilures in safety-related systems.

(2) Possible adverse generic implications.

(3) Are considered to be complicated and the probable causes are ,

unknown or difficult to understand. ]

1 (4) Involve significant system interactions. I (5) Repetitive failures or events involving safety-related equipment.

or deficiencies in operations. j (6) Involve questions / concerns pertaining to either licensee opera- I tional or managerial performance.

Approved : August 8,1986 1

I l

i

N R C-0513-05 NRC INCIDENT INVESTIGATION PROGRAM

~0513-05 BASIC REQUIREMENTS 051 Applicability. The provisions of this chapter and its appendix apply to the Headquarters and Regional Offices of NRC.

052 Appendix 0513. Defines the major components of the incident investi-gation Program (i.e., incident investigation and augmented inspection).
a. Appendix 0513, Part I, INCIDENT l' INVESTIGATION FPOGR AM. Es-tablishes. responsibilities . and functions for NRC offices for inci-dent investigation; general guidance. _ defines objectives, authorities, and provides
b. Appendix 0513, Part 11, INCIDENT INVESTIGATION TEAMS. Out-L lines incident investigation Team (llT) response, objectives, and authorities, provides guidance for development of procedures, and establishes followup responsibilities.
c. Appendix 0513, Part lil, AUGMENTi!D INSPECTION TEAMS. Outlines Augmented Inspection Team ( AIT) response, objectives, authorities, and provides general guidance.

Approved: August 8,1986

m ,

-NRC INCIDENT INVESTIGATION PROGR AM NRC A'ppendin 0513 s

PART l lNCIDENT INVESTIGATION PROG.7AM p .,

A. COVERAGE This part defines the responsibilities and functions of the various Offices of NRC in establishing and implementing IITs and AlTs.

B. DUTIES

1. Executive Director for Operations (EDO):

o

a. Determines whether a potentially significant operational event is to be investigated by an incident investigation Team (llT)

(See Appendix 0513, Part II).

b. Selects the llT leader and team members, provides policy and technical dir,ection, and ensures the independence of the inci-dent investigation Team.
2. Director, Office for Analysis and Evaluation of Operational Data:
a. Administers the incident Investigation Program to meet th'e objectives set forth in this Chapter, with the assistance of other NRC Offices.
b. Assures that procedures governing IITs are developed, i:oordi-nated, approved, distributed and maintained.
c. Identifies and provides staff to be' members and leaders of IITs and AITs. .
d. Provides administrative support to llTs necessary to achieve .

objectives defined in Appendix 0513, Part il, with assistance from other NRC Offices. L -

e. For events which warrant at least an AIT response, consu'lts with the Regional Administrator and the Directors of NRR or NMSS, and IE to decide if an AIT or itT response is appro-priate. Identifies the potential safety issues and provides recommendations to the EDO on events warranting an llT response.

. f. Establishes and maintains rosters of potential team leaders and team members who are certified in incident investigation via formal training, and makes recommendations to the EDO concern-

. Ing IIT composition.

g. Identifies needed training and coordinates training require-ments for llT candidates with the Office of Administration.

1 Approved: August 8,1986

o - l NR,C. App:ndix 0513 1 Pcrt i NRC INCIDENT INVESTIGATION PROGRAM

h. Assesses the effectiveness of the incident investigation Pro- (

gram activities and recommends action, as appropriate, to im-prove the program.

3. Director, Office of Inspection and Enforcement:
a. Assures that procedures governing AlTs are defined, developed, coordinated, approved, distributed and maintained.
b. Identifies and providet staff to be members and leaders of IITs and AITs.

s

c. Provides assistance in implementing the NRC incident investiga-tion Program.
d. Recommends to and coordinates with the appropriate Regional Administrator on events which may warrant an AIT as defined in Appendix 0513, Part lli.
e. For events which warrant at least an AIT response, consults with the Regional Administrator and the Directors of NRR or NMSS, and AEOD to decide if an AIT or llT response is appro-priate. Identifies the potential safety issues and provides recommendations to the EDO on events warranting an llT re-sponse, including the llT composition.
4. Director, Office of Nuclear Reactor Regulation: (
a. Identifies and provides staff to be members and leaders of IITs and AITs.
b. Provides assistance in implementing the incident investigation Prog ram.
c. Recommends to and coordinates with the appropriate Regional Administrator on events which may warrant an AIT as defined in Appendix 0513, Part lli.
d. For events which warrant at least an AIT response, consults with the Regional Administrator and the Directors of AEOD and IE to decide if an AIT or llT response is appropriate. Id ent'l-fies the potential safety issues and provides recommendations to the EDO on events warranting an llT response, including IIT composition.
5. Director, Office of Nuclear Material Safety and Safeguards:
a. Identifies and provides staff to be members and leaders of IITs and AlTs.

l l b. Provides assistance in implementing the NRC Incident Investiga-tion Program.

Approved: August 8,1986 2 i

l L _ _ _ _ - - - _ - - _ - _ - - - - - - - _

i NRC Apprndix 0513 '

NRC -lNCIDENT INVESTIGATION PROGRAM Part i

c. Recommends to and coordinates with the appropriate Regional Ad-

< ministrator on. events which may warrant an AIT as defined. in-Appendix 0513, Part ll1.

d. For. events which warrant at least an AIT response, consults with the Regional Administrator and the Directors of AEOD and IE to decide if an AIT or llT response is appropriate. Iden -

. tifies the potential safety or safeguards issues and provides recommendations to 'the EDO on events warranting an . IIT re-sponse, including the llT composition.

6. Director, Office of Administration:
a. Provides staff to assist IITs in writing, editing, word proces-sing and publication of reports through the Division of Techni-cal Information and Document Control.
b. Manages, directs and coordinates the training program for-IIT l candidates through the Dnployee Development and Training l' Staff.
7. Regional Administrators:
a. In coordination with NRR or NMSS, and IE, determine those operational events - warranting investigation by an AIT; and as soon as it becomes clear that at least an AIT is ' warranted, 3 preferably before an AIT is actually established, consult with J the Directors, NRR or NMSS, IE and AEOD, to consider whether an ilT response is appropriate. Identify the potential safety issues and provide recommendations to the EDO cn events war-ranting an llT response, including the llT composition,
b. Select the AIT leader and team members and direct, coordinate and approve the performance of AITs.

c Provide assistance in implementing the NRC incident I nvestigc~-

tion Program.

l d. Identify and provide staff to be, members and leaders of IITs and AITs.

e. For all llTs and some AITs, issue a Confirmatory Action Letter, as appropriate, to the 'affected licensee requiring that, within the constraints of ensuring plant safety, relevant failed equip-ment is quarantined and subje:t to agreed upon controls for troubleshooting, that information and data related to the event is protected, and that the plant is maintained in a safe shut-down condition until concurrence is received from the NRC to restart.

1 3 Approved: August 8,1986

't _ _ - _ _ _ -

m. .

y t,*-

NRC IAppsndix~l0513 -

Part ~ l NRC INCIDENT INVESTIGATION PROGRAM

8. Director, Office of Public Affairs,:
a. Follows established NRC pu'blic information policies for release of information relating to NRC-investigatory responses to oper-E ational events (See ' Appendix. 0513, Parts !! and ill).

l,

b. Promotes the NRC policy of encouraging licensees to. take the lead in information dissemination activities related to incident investigations at their facilities.
c. Identifies and provides staff to support llTs.
9. Director, Office of Nuclear Regulatory Research:
a. . Identifies -and provides staff to be members and leaders of IITs and AITs.-
b. - Provides assistance in implementing the NRC incident investiga- .j tion Program.
10. Office of the General' Counsel:
a. Provides assistance 'In implementing the NRC Incident. Investiga-tion Program.

b.. Identifies and provides staff to support ilTs. ,

s c.

Approved: August 8,1986 4

' ~

[ NRC INCIDENT INVESTIGATION PROGR AM , NRC Appendix 0513 PART 11 INCIDENT INVESTIGATION TEAMS This Part defines the investigatory initiative involving a response by an inci-dent Investigation Team (IIT).

A. OBJECTl'1ES OF INCIDENT INVESTIGATION TEAM Conduct a timely, thorough, systematic, formal and independent investigation of certain safety-significant events occurring at facilities licensed by the NRC.

Collect, analyze, and document factual information and evidence sufficient to determine the probable cause(s), conditions, and circumstances pertaining to the event.

B. SCOPE OF INCIDENT INVESTIGATION The investigation performed by an llT emphasizes factfinding and determination of probable cause for a significant operational event (as defined in this chap-ter). .The scope of the investigation is sufficient to ensure that the event is clearly understood, the relevant facts and circumstances are identified and col-lected, and the probable cause(s) and contributing cause(s) are identified and substantiated by the evidence associated with the event. The investigation shall consider whether licensee and NRC activities preceding and contributing ,

to the event were timely and adequate.

It is expected that the scope of an llT will include conditions preceding the

{~ event, event chronology, systems response, human factors considerations, l equipment performance, precursors to the event, emergency response, safety i significance, radiological considerations, and findings and conclusions.

l The scope of the investigation does not include:

1. Specific assessment of violations of NRC rules and requirements; or
2. Review of the design and licensing bases for the facility except as necessary to assess the cause for the event under investigation.

C. SCHEDULE The llT shall be activated as soon as practical after the safety significance of the operational event is cletermined and will begin its investigation as soon practicable after the facility has been placed in a safe, secure and stable con-

  • - dition. If there is an NRC incident response, the investigation will begin af-ter it is deactivated.

- The llT shall issue interim reports at appropriate intervals outlining the sta-tus, plans and relevant new information related to its investigation.

i

)

5 Approved : August 8,1986

.u . _ _ _ _ _ _ _ _ _

NRC Appendin 0513 Part il NRC INCIDENT INVESTIGATION PROGRAM

(

The llT shall prepare and transmit its final report to the Commission and the EDO in about 45 days from activation of the team, unless relief is granted by the EDO.

D. TEAM COMPOSITION AND QUALIFICATIONS The llT will be composed of technical experts selected on the basis of their expertise, potential contributions to the event investigation, and their freedom from significant involvement in the licensing and inspection of the facility in-volved or other activities associated with issues that had a direct impact on the course or consequences of the event. The number of members and areas of technical expertise required for each flT will be determined based on the type of facility and characteristics of the event.

The team leader and expert members should, in general, be selected from ros-ters of candidates who have been certified through formal training in incident investigation. The team leader shall be a senior NRC manager from the Senior Executive Service.

E. DUTIES The llT carries out the single NRC factfinding investigation of tha event and is authorized and responsible to pursue all aspects of an event that are within its scope as defined above. NRC response personnel on site shall provide support as needed to assure the efficient and effective transition to investiga- [ i tion of the event, not to interfere with plant safety. \ l i.

I The following duties are in addition to the duties defined in this chapter and appendix.

1. Executive Director for Operations:
a. Approves the need for, establishes, and provides policy and techni-cal directions to the llT.
b. Determines that the investigation was effectively conducted and con-sistent with the goals of the Incident investigation Program.
c. Assigns followup actions associated with the llT report. ,
2. Director, Office for Analysis and Evaluation of Operational Data:
a. Provides administrative support to the llT by assisting the Team to meet its objectives and schedule. -
b. Provides advice and consultation to llT leader on procedural matters and suggestions regarding completeness of IIT report.
c. Coordinates with Director, Office of Administration, to provide sup--

, port necessary to publish an llT report as a NUREG document.

l i

Approved: August 8,1986 6

- 4 -

s ,

NRC Appendix 0513 NRC INCIDENT INVESTIGATION PROGRAM Part il

3. Regional Administrators;

.a. Provide assistance in briefing and providing background information to the llT when it ~ arrives on site.

b. Provide on-site support for the IIT during its investigation.

~

c. Identify and provide staff to monitor licensee tr'oubleshooting activi-L ties to assess equipment performance.
4. IIT Leader:

a '. . Directs and manages the llT in its investigation and assures that the objectives and schedules are met for the investigation as defined in this chapter and appendix.

b. Identifies, adds and removes equipment from the quarantined list within the constraints of ensuring plant safety and equipment testing and maintenance requirements and of determining causes for equip-ment anomalies.
c. S'erves as principal spokesperson for the llT activities in interacting

. with the licensee, NRC Offices, ACRS, news media, and other or-ganizations on matters involving the investigation.

d. Prepares frequent status reports documenting IIT activities, plans, significant findings, and safety concerns that may require timely re-

-) medial actions, or issuance of Information Notices, Bulletins, or' Orders,

e. Receives direction and supervision from the Executive Director for Operations.
f. Identifies and requests that the EDO provide additional llT resources-(e.g., additional members, consultants, contractor assistance) as needed.
g. Identifies and recommends to the EDO the need for further studies and investigations, such as staff performance in regulc*ory activities prior to the event, when significant concerns could not es thorough-ly evaluated because of time or resource limitations.

F. CONDUCT OF INVESTIGATION

, _ The investigation process is based on the principles of incident investigation provided in llT training programs and described in IIT procedures.

' ,- 1. The team composition of the llT shall be structured and the proce-dures developed to maintain independence and objectivity. Personnel possessing a high degree of independence, ingenuity, and resource .

fulness should be selected to assure that the investigation is con-ducted in a timelv, professional, thorough and coordinated manner.

l 7 Approved: August 8,1986

NRC' Appsndix 0513 P ,rt il NRC INCIDENT INVESTIGATION PROGR AM i

2. Implementing Procedures. Procedures to guide and control the es-tablishment and investigatory activities of an llT are to be included in an investigation manual. At a minimum, the following procedures shall be developed by the Office for Analysis and Evaluation of Op-erational Data:
a. A procedure for activating an llT including responsibilities, coordination, communication, team composition and guidance.
b. A procedure for ilT investigation of an operational event in-ciuding responsibilities, work plan, communication, interfaces, scope, and schedule.
c. A procedure for interviewing personnel.
d. A procedure for collecting and maintaining records, documents, data and other information.
e. A procedure for treatment of quarantined equipment.
f. A procedure for preparation, release, and distribution of the llT report and related documents,
g. A procedure defining administrative support requirements for 'an llT.

f' G. FOLLOWUP ACTIONS Upon receipt of the llT report, the EDO shall identify and assign NRC Office responsibility for generic and plant-specific actions resulting from the investi-gation that are safety significant and warrant additional attention or action.

i j

l Office Directors shall provide a written status report on the disposition of each assigned action as , directed by the EDO.

Followup actions associated with the llT report do not necessarily include all licensee actions, nor do they cover NRC staff activities associated with normal event followup such as authorization for restart, plant inspections, or possi-ble enforcement items. These items are expected to be defined and imple-mented through the normal organizational structure and procedures.

l l

l l

Approved: August 8,1986 8 l

l .__ _-________ _ ________________ -

NRC INCIDENT INVESTIGATION PROGRAM NRC Appendix 0513 PART lil AUGMENTED INSPECTION TEAMS This Part defines the inspection initiative involving a response by an Augment-ed inspection Team (AIT).

A OBJECTIVES OF AUGMENTED INSPECTION TEAM:

Conduct a timely, thorough and systematic inspection related to significant op-erational events at facilities licensed by the NRC.

Assess the safety significance of the event and communicate to Regional and i Headquarters management the facts and safety concerns related to the event such that appropriate followup actions can be taken (e.g., study a generic j concern, issue an Information Notice or Bulletin), t Collect, analyze, and document factual information and evidence sufficient to determine the cause(s), conditions, and circumstances pertaining to the event.

B. SCOPE OF AUGMENTED INSPECTION ,

The AIT response should emphasize fact-finding and determination of probable cause(s) and should be limited to issues directly related to the event.

j, The AIT response should be sufficiently broad and detailed to ensure that the evr nt and related issues are well defined, the relevant facts and circumstances at e identified and collected, and the findings and conclusions are identified and substantiated by the information and evidence associated with the event.

The inspection should consider the adequacy of the licensee actions during the event.

The scope of the inspection shall be defined and revised, as appropriate, by the Regional Administrator directing the AIT inspection. 3 C. SCHEDULE  :

l The AIT shall be activated as soon as practical after the safety significance of the event is determined and should begin its inspection as soon as practicable after the facility has been placed in a safe, secure and stable condition.

I The AIT shall prepare and transmit its report to the Regional Administrator  !

within 30 days from activation, unless relief is granted by the Regional Administrator.

D. TEAM COMPOSITION AND QUALIFICATIONS The AIT will be composed of technical experts from the responsible Regional Office, augmented by personnel from Headquarters or other Regions with spe- ,

cial technical qualifications to complement the technical expertise of the Region- l al response. The size of the AIT and the areas of expertise will be 9 Approved : August 8,1986 s

W. m. s

+ ,

'NRb Appendix 0513 Part 111 NRC' INCIDENT INVESTIGATION PROGRAM-4 determined .by the Regional Administrator and coordinated with other NRC \ 'i Offices based on the event and its implications.

The. AIT Leader will normally be selected from the . responsible Regional Office unless. lead is transferred to another NRC Office by' mutual consent through a Task Interface Agreement.

~

E. DUTIES'

.The AIT is authorized and responsible .to pursue lall pertinent aspects of an operational event. The following duties of NRC offices are in addition to those defined in this chapter and appendix.

1. Director, Office of Inspection and Enforcement:
a. Monitors and evaluates the AIT process and products, and as-sures that AIT procedures are properly maintained,
b. Defines, develops, coordinates, approves and maintains the nec- ,

.essary procedures to guide and control AIT activities, i

2. Regional Ad.ninistrators:
a. Staff, c' rect, supervise, coordinate, and approve the perfor-mance of AITs.
b. Ensure Bat the AIT response is initiated, defined and ccnduct-ed in a manner that achieves the objectives.
c. Evaluate if and when the AIT inspection should be upgraded to

(.. an .IIT, and, in consultation with the Directors of NRR or l NMSS, AEOD and IE, recommend to the EDO that an IIT re-I sponse is warranted,

d. Provide administrative support and resources to AlTs in assist-ing the AIT to meet its objectives and schedule.
e. Issue a periodic Daily Staff Note to the EDO when an AIT re- .

sponse is implemented and provide updates as appropriate.

f. Identify and request additional expertise for AIT response from other NRC Offices,
g. The duties defined in this part for a specific AIT may be transferred to another NRC office by mutual consent through a Task Interface Agreement.
3. AIT Leader:
a. Manages the AIT In its inspection and assures that the objec-'

tives and schedules are met for the inspection as defined in tnis cnapter ano appena:x.

' Approved: August 8,1986 10

h NRC Appsndix 0513 NRC INCIDENT INVESTIGATION PROGRAM Part til

b. With the approval of the Regional Administrator, adds and re-moves equipment from a quarantined list (if applicable) within the constraints of ensuring plant safety, determining causes for equipment anomalies, and testing and maintenance considerations,
c. Serves as principal spokesperson for AIT activities in interact-ing with the licensee, NRC Offices, ACRS, news media, and other organizations on matters involving the inspection.
d. Prepares interim status reports documenting AIT activities, plans, and new information. Communicates to NRC offices any significant findings and safety concerns that may require timely remedial actions for issuance of information Notices, Bulletins,
  • Orders.
e. Receives direction and supervision from the Regional Administrator.

t F. AIT IMPLEMENTING PROCEDURES At a minimum, the following AIT implementing procedures shall be prepared by the Office for Inspection and Enforcement and included in the investigation Manual:

1. A procedure for activating an AIT including responsibilities, coordi-nation, communication, and guidance. -

}

2. A procedure for AIT investigation of an operational event including responsibilities, communication, interfaces, scope and schedule.

G. FOLLOWUP Identification, review and approval of licensee corrective actions, licensee ac-tions prior to restart, and NRC enforcement actions shall be through the nor-mal organizational structure and procedures.

Followup actions such as changes in inspection programs or the incident inves-tigation Programs, issuance of Information Notices, Bulletins, or generic letters shall also be through the normal organization structure and procedures.

l l

l

)

I 11 Approved: August 8,1986

-i SSP #881412

,3, ,.v, NQG #88600 New Hampshire Yankee Division INTRA COMPANY BUSINESS MEMO

- Putasc SeMee of New HompaNro Subject SELF ASSESSMENT TEAM RECOMMENDATIONS From - J. J. Warnock District Produc tion Date October 31, 1988

~To- N. A. Pillsbury Reference SAT Letter Dated 10/20/88 Attached is NQ's response and completed action to the SAT recommendations transmitted by the referenced memorandum.

hM

. J. Warnock uclear Quality Manager JJW:bwe Attachment cc: T. C. Feigenbaum RMD File #17.2.2.1 .

-File (2)

i ,1 88 SAT-1021 LOW POWER SELF ASSESSMENT

. TRACKING WORKSHEET L PHASE: 1 EVALUATION OF: Quality Assurance PERFORMANCE OBJECTIVE NO.: 1 CRITERIA: 1.1 L -RECOMMENDAT10N/ ACTION

SUMMARY

The Nuclear Quality Group should obtain the requisite technical and operational expertise to independently review and assess adequate application of the NHY Operational Quality Assurance. Program to the Low Power Test Program.

PRIORITY: Hust be-corrected before:

P. Falman 10/12/88

1) Phase 1 SA Report Is Issued l l "(Prepared By/Date).
2) -Initial Criticality x N. A. Pillsbury 10/19/88
3) Comencing Scheduled Cooldown l l (Approved ly/Date)
4) Phase 2 SA Report Is Issued l l

~5) Other: l l (Date or Milestone)

DISPOSITION: lhis evaluation coment issued by SAT Manager ~ to:

A) J. J. Warnock on 10/19/88 l l (Dept. or Function Group Mgr.) (Date)

B) Management Oversight Comittee on 10/14/88 O (Date)

C) Phase 1 Report Only l l (Phase 1 and/or 2 CLOSE0VT: This Self Assessment Recommendation:

A) Determined To Be Not Valid l I

8) Incorporated During the Low Power Testing !! volution l l

~

C) Being Tracked For Further Action Through System l l (e.g. ICTS, NRC, NSARC, SORC)

D) Incorporated in S.A.T. Phase Report E) Closecut Coments:

(By Functional Manager)

F) G)

Functional Group Manager /Date Neal A. Pillsbury/Date

.I-Tha Stcrtup. Test program procedures were independently reviewed by YNSD (R.

Barry) to assass.the adequzcy and effectiveness of QA/QC involvement. This ,

,. review identified additional hold / witness points that.should be surveilled in '

3- addition'to.those' items previously identified by NQ. No items were deleted.

These. additional hold / witness points have been included in the QC startup test surveillance plans.

Mr.'Barry has extensive operational experience and has held an operator's

-license.- His review provided additional assurance that the involvement by NQ during the startup test program is adequately and effectively planned.

l

QUALITY ASSURANCE SURVEILLANCE CHECKLIST / REPORT llRESPONSIBLE INDIVIDUAL 2l SURVEILLANCE TITLE _ 4l OASR NO.

3.3 .Wvnot,k n, R -n >-no *4 QQ~QObf 3 l INDIV IDU AL( S ) ASSIGNED / INVOLVED IN SURVEILLED ACTIVITY FREQUENCY D . k .COV'. N k .k. bEf rN) gg Y 7. hoSM d REVISION t .t.hnn e ny

%.ATs 5l SCOPE OF SURVEILLANCE - OUALITY ATTRIBUTES - REFERENCE, ETC.

Startup Test Program Implementation ,

Startup Test Program Description, Rev. sl . .

6l METHOD OF SURVEILLANCE l

Review the applicable Startup Test Procedures to verify they have been-reviewed by the NQG and the appropriate witness points hase been inserted.

f 7l REQUESTED BY DATE 8l APPROVED BY DATE kuhL.Comf3l 10/3118g b ti L.. & 1013I/88' i

DISTRIBUTION: R. COONEY FILE # NYQA FORM 2/10.3A

{ J.'WARNOCK R. M. D Revision 10 Page 1 of 2

- . _ - __.______._..-______..-_.___.._-_-______m___

l RESULT 3 0F SURVEILLANCE 77 60/,64

.rsview of tha sevan primary Startup Test Procedures that would be performed during u 5% power test program was done by Raymond Berry. YAEC Framingham, on Oct. 12, and S. 1988. The review was to determine if the witness points,that NQG had established a tha ST's,were appropriate.

. Barry's review, as per the attached memorandum, determined that there should be Jditional witness points established. The memorandum was forwarded to QC and on
t 28, 1988.1 verified that QC had added,to their preplanned surveillance checklists, 11'the reccomendations except one. Under 1-ST-20 the reference to Step 6.10.3 was cypo error and the actual reference should have been Step 6.11.3.

a our future surveillance during the 5% power testing we will verify that QC performs 11 the identified steps identified on the preplanned surveillance checklists, o findings. This report is closed.

0} SURVEILLANT l DATE 11 EVALUATOR l DATE Qs&QQ )4-3t ~ 8 g k % n. Qh AMT

2) RESPONSE PRIORITY ICTS il PRIORITY FINDING (S) # DUE DATE 1 MR IMMEDIATE ACTION REOUIRED 2 MA 3 N4 NONE REOUIRED

' 31

RESPONSE

Include corrective action and completion date, determination of root l

cause and action to prevent recurrence.)

1 Ch

'14] RESPONSIBLE MANAGER DATE NYQA FORM 2/10/3A Revision 10 Page 2 of 2

Qh5A TT 004$

MEMORANDUM To Dennis L. Covill - Seabrook October 19, 1988 From Ray ond-L. B.e r - Framingham Subject STARTUP TEST 'ROGRAM PROCEDURE REVIEW REFERENCES

1. Seabrook Station Startup Test Procedure 1-ST-16 Revision 2, Initial Criticality
2. Seabrook Station Startup Test Procedure 1-ST-17 Revision 2, Boron Endooint Measurement
3. Seabrook Station Startup Test Procedure 1-ST-18 Revision 2, Isothermal Temperature Coefficient
4. Seabrook Station Startup Test Procedure 1-ST-19 Revision 1, Flux Distribution Measurement at Law Power
5. Seabrook Station Startup Test Procedure 1-ST-20 Revision 2, Control End Worth Measurement
6. Seabbook Station Startup Test Procedure 1-ST-21 Revision 2, Pseudo Rod Eiection Test
7. Seabrook Station Startup Test Procedure 1-ST-22 Revision 1, Naturs1 Circulation Test

~

DISCUSElQH I was requested by the Yankee Atomic Seabrook Project nager to review the referenced startup test procedures to entify where, in my opinion, the Seabrook Station Nuclear ality . Group shculd establish witness points during the startup st program. I reviewed the referenced procedures at Seabrook ation on October 12 and 13, 1988. I was made aware that even

., ugh the Nuclear Quality Group will be providing l aund-the-clock coverage of the startup test program, stinctive witness points need be established. Based on my i view of the procedures the following witness points should be I tablished by the Nuclear Quality Group to assure the startup st program is conducted as planned.

Procedure 1-ST-16u Jnitial Criticality

  • Step 6.1.13 To verify the 1/M plot is performed and the reactor core will not become critical by an additional 114 steps of withdrawal.
  • Step 6.1.25 Same au ubove.
  • Step 6.2.11 To sverify the 1/M plot is performed and the reactor core will not become critical by an additional 60 steps of withdrawal.
  • Step 6.2.19 Same as above.
  • Step 6.3.5 Verify the dilution rate.
  • Step 6.3.20 Verify the blended makeup setting.

Qh% V.-0(4Q Procedure 1-ST-17. Boron Endpoint Measurement

  • Step 6.1.3 Verify the data measured against predicted.
  • Step 6.2.3 Same as above.
  • Step 6.3.3 Same as above.
  • Step 6.4.3 Same as above.
  • Step 6.5.3 Same as above.
  • Step 6.6.3 Same as above.

Proce. dure 1-ST-18. Isothermal Temperature Coefficient Measurement

  • Step 6.1.3 Verify the data measured against predicted.
  • Step 6.2.3 Same as above.
  • Step 6.3.3 Same as above.

Procedure J-ST-19. Flux Distribution Maesurements at Law Power i

  • Step 6.1.4 Verify the data measured against predicted.
  • Step 6.1.5 Verify the limit settings of detectors.
  • Step 6.2.4 Verify the data measured against predicted.
  • Step 6.3.4 Same as above.
  • Step 6.4.4 Same as above.

Procedure 1-ST-20. Control Hnd Worth Measurement

  • Step 6.1. 3 Verify the data measured against predicted.
  • Step 6.2.3 Same as above.
  • Step 6.3.3 Same as above.
  • Step 6.4.3 Same as aneve.
  • Step 6.5.3 Same as above.
  • Step 6.6.1 Verify the correct rod bank position.
  • Step 6.7.4 Verify the boron concentration.
  • Step 6. 7. 7 Verify the data measured against predicted.
  • Step 6.8.4 Same as above.
  • Step 6.9.4 Same as above.
  • Step 6.10.3 Same as above.

Procedure 1-ST-21. E.seudo Rod E.iection Test

  • Ster 6.1 Verify the correct rod bank position.
  • Step 6.5 Verify the flux map data measured.
  • Step 6.6 Same as above.
  • Step 6.12 Verify the data measured against predicted.

.s  %-

DE M O%bl{

Erocedur_g 1-ST-22. Natural Circulation Test

  • Step 6. 2 Verify the data measured.
  • Step 6.3 Same as above.
  • Step 6.10 Verify the expected plant response -

Attachment 9.3.

  • St.ep.6.20 Verify that subcooling is >15 F.
  • Step 6.26 Same as above.
  • Step 6.29 Verify the reactor is suberitical.

4 e

k

88 SAT 1022 LOW POWER SELF ASSESSMENT

, TRACKING WORKSHEET PHASE: 1 EVALUATION OF: Quality Assurance E

P_ERFORMANCE OBJECTIVE NO.: 1 CRITERIA: 1.3 RECOMMENDATION / ACTION

SUMMARY

The Nuclear Quality Manager should ensure that QA and QC personnel assigned to low power testing activities are adequately qualified through past experience and successful completion of additional training specific to low power testing.

PRIORITY: Must be corrected before:

P. Falman 10/12/88

1) Phase 1 SA Report Is Issued 7PreparedBy/0 ate)
2) Initial Criticality X N. A. Pillsbury 10/19/88
3) Comencing Scheduled Cooldown R (Approved By/Date) l
4) Phase 2 SA Report Is Issued R  !

~

(Date or Milt. stone)

DISPOSITION: This evaluation coment issued by SAT Manager to:

A) J. J. Warnock on 10/19/88 U (Dept. or Function Group Mgr.) (Date)

B) Management Oversight Comittce on 10/14/88 l l (Date)

C) Phase 1 Report Only i I (Phase 1 and/or 2 CLOSE0VT: This Self Assessment Recomenoation:

A) Determined To Be Not Valid R B) Incorporated During the Low Power Testing Evolution l l l

C) Being Tracked For Further Action Through System l I (e.g. ICTS, NRC, NSARC, SORC)

D) Incorporated in S.A.T. Phase Report E) Closecut Coments: '

l (By Functional Manager)

F) G)

Functional Group Manager /Date Neal A. Pillsbury/Date l

l l

t Th2 NQG conducted training specific to low power test evalutions for personnsi involved in scartup tests.

~

. Specifically:

Reactor Physics and Operations training session was conducted by Mr. Paul f Gurny to provide technical information.

s l

l Startup Manager conducted a training session c:. startup test program and procedures.

Simulator Walkthrough conducted to ensure that personnel monitoring the test program were familiar with the location of control room instrumentation and equipment.

Startup Test Procedures were required reading for QC personnel involved in startup test program. Four personnel remaining to complete required reading.

Personnel involved in the test program are qualified in accordance with the NYQA program.

Documentation is attached.

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-:- NQG #88544

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New Hampshire Yankee Division

' INTRA. COMPANY BUSINESS MEMO Pubac SeMee of m Hampstwo Subject SIMULATOR WALKTHROUGH From R.E. CONNOLLY District Date SEPTEMBER 29, 1988 To ASSIGNED-PERSONNEL Reference

'The following assignments are made for Si'nulator Walkthroughs.

Please report to the Training Center 1st floor at 1:15 p.m. on your assigned day.

I will be present each day to coordinate the walkthrough with Training Center personnel.

This walkthrough is open to other personnel who desire to familiarize themselves with the simulator layout.

,TUES, OCT 11, 1988 WED, OCT 12, 1988 THURS, OCT 13, 1986 %Iff'fC(/,

M Muir'zehd / J. Watts / '/ ~

g),ff9yc(/

J. Dolan J. Rickett R. Care 11a / S. Barraclough

/

D. Lynch T. Wheeler 8 m.%st J P aMM t/

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u I) m R. E. CONNOLLY, JR.

Lead QC Inspector - Technical REC /kkk cc: J.J. Warnock A.G. Fralick C.J. Vincent R.C. Bragel D.L. Covill J.M. Grillo ,

S.P. Buchwald M.P. Boyle P.B. Upson C.C. Swinton l V.J. Pascucci File: 17.2.2.1 , I P_MD File (2)

O d

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REQUIRED READING LIST FOR LOW-POWER TESTING  % hO d -

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L j INSPECTOR'S NAME OmaS 2 /M[eefer- SSN N/ 6d M INITIAL /DATE

  • t- i- [ d 8 STPD, Rev. d Startup Test Program Description 50erW ST-1, Rev. 2.

. If329;3.7 Te:chnical Specifications, Section 3/4.10, Special Test Exceptions:

3/4.10, Shutdown Margin 3/4.10. 2, Group Height , Insertion and Power Distribution Limits 3/4.10.3, Physics" rests ,

- 3/4.10.4, Reactor Coolant Loops 3/4.10.5, Position Indication System - Shutdown

, I /Sdeclinical Clarifications (Overview)

Startup Test Procedures-

- Jt% Q ST-16, Rev. f( , Initial Criticality

, [ detTE ST-17, Rev. 2. , Boron Endpoint Measurement a

N &cr22 ST-18, Rev. 2 , Isothermal Temperature Coefficient Measurement N J o d ST-19, Rev. , Flux Distribution Measurements at Low Power

' W JM ST-20, Rev. ./ , Control Rod Worth Measurement Ih di trr$ ST-21, Rev. 2. , Pseudo Rod-Ejection Test doe.M ST-22, Rev. I. , Natural Circulation Test TN ST-41, Rev. d , Radiation Survey ST-42, Rev. l. , Water Chemistry Control M

REVIEWED BY: ,

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DATE:

LQCl - TNCHNICAL '/' '

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IN$rECTION SUPERVISDK '

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. INSPECTOR'S 'NAME ' Mhu b bow AO .SSN @ 810 ~/b INITIAL /DATE .

hD' hofsik STPD, Rev. k Startup Test Program Description .

D 10 L. tf ST-1, Rev. .

3 Jh Jo-Jo@ Technical Specifications, Section 3/4.10, Special Test Esceptions:

3/4.10, Shutdown Margin 3/4.10.2, Group Height, Insertion and Power Distribution Limits 3/4.10.3, Physics " Tests ,.

3/4.10.4, Reactor Coolant Loops

'3/4.10.5, Position. Indication System - Shutdown -

ih lo/x/tr-TechnicalClarifications(Overview) f ,.

Startup Test Procedures h D lof M ST-16, Rev. ) , Initial Criticality b '.se// Pt .. . ST-17,' Rev. c1 , Boron Endpoint Measurement j~ i. 1-h p to/n y ST-18, Rev. d , Isothermal Temperature Coefficient Measurement

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.- Ob ,M3 fit ST-19, Rev. f , Flux Distribution Measurements at Low Power

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1 , Control Rod Worth Ecasurement "

/ fh fo[es/ft ' . SN2d[ 'Rev.'

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h,P.dvs[gf ST-21, Rev.  % , Pseudo Rod-Ejection Test

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h h m[, 9 ST-22, Rev. / , Natural Circulation Test

'"Opb loNey ST-41, Rev. /> , Radiation Survey

f. AI M b is/3/r/ ST-42, Rev.

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/ , Water Chemistry Control V '(

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REVIEWED BY: -

_l DATE: /d LQCI - TECHNICAL

. QC INSPECTION SUPERVISOR

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INSPECTOR'S NAME MA/M m4/rFAO SSN d//"6cb#/787 l ' INITIAL /DATE *

/h/ STFD,'Rev. b Startup Test Program Description

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T-1, Rev. M .

fof1bfD _ Technical Specifications, Section 3/4.10, Special Test Exceptions:

3/4.10, Shutdown Margin 3/4.10.2, Group Height,' Insertion and Power Distribution Limits 3/4.10.3, Physics Tests .

3/4.10.4, Reactor Coolant Loops 3/4.10.5, Position Indication System - Shutdown

/o/Jo//I Technical Clarifications (overview)

Startup Test Procedures

/4//9b8 ST-16,'Rev. M Initial' Criticality

/e/iG /ff ST-17, Rev. , Boron Eudpoint' Measurement p/fd/8 ST-18, Rev. , Isothermal Temperature Coefficient Measurement

/4ftelJ3 ' ST-19, Rev. / , Flux Distribution Measurements at Low' Power

/6/P ST-20, Rev.  ! , Control Rod Worth Measurement

/4/ ST-21, Rev.~ V ,' Pseudo Rod-Ejection Test

/e/W[8 ST-22, Rev. l , Natural Circulation Test d'/9/dl ST-41, Rev. 8 , Radiation Survey

/th4[d ST-42, Rev. [ , Water Chemistry Control REVIEWED EY: /5'h

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3/4.10.4, Reactor Coolant Loops M/4.10.5, Position Indication System - Shutdown

/E2 Technical Clarifications (Overview)

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INTRA COMPANY BUSINESS MEMO Pubec $oMee of New Hompehke Subject ' SHIFT ASSIGNMENTS From R.E. CONNOLLY, JR. District- Date NOVEMBER 21, 1988.

To ASSIGNED PERSONNEL Reference The following shif t assignments are made for Low Power Testing:

DAYS . SWINGS MIDS Tom Wheeler

  • Ken Muirhead
  • Jamie Watts
  • Jack Rickett John Dolan Dave Lynch Denotes QC Shif t Leader Alternates:

R. Carella S. Barraciough Shift coverage will run until the completion of Low Power Tes*ing, with shift times being provided at a later date.

j h R. E. CONNOLLY, JRLG

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REC /kkk cc: J. Warnock C. Vincent V. Pascucci D. Covill Assigned Personnel G. Kann 02-08

  • J. Crillo 49-0P i RMD (File 2) 17.2.7.1 i 4

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! ,, NUCLEAR REGULATORY COMMISSION WASHINGTON, o. C. 20666,

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\. ~- f N R( .NSPECTION MANUAL Oten INSPECTION PROCEDURE 40500 EVALUATION OF LICENSEE SELF-ASSESSMENT CAPABILITY PROGRAM APPLICABILITY: 2515 and 2525 40500-01 INSPECTION OBJECTIVE The objective of this . inspection is to evaluate the effectiveness of the licensee's self-assesseent programs. The inspection will focus on deter-mining whether the licersee's self-assessment programs contribute to the prevention of problems by monitoring and evaluating plant performance, providing assessments and findings, ano communicating and following up on corrective action recommendations.

40500-02 INSPECTION REQUIREMENTS 02.01 Inspection Preparation

a. Review selected recent licensee event reports (LERs) . 3 nforcement history, operating activities, inspection reports, managenent meeting .

reports, performance indicators, and systematic assessment of licensee performance (SALP) reports to determine current areas of weakness.

b. -Review the 1.icensee'r requirements for oversight activities in the technical specifications and any comitments made in the final safety analysis report (FSAR) or separate correspondence,
c. Review the licensee's site and corporate organization charts to gain an understanding of the organizational relationships. Review the charters or procedures for individual comittees to determine intercomittee relationships and lines of communication.

02.02 Onsite and Offsite Review Committee Activity (or equivalent)

a. Review selected comittee merting minutes for the last year and ensure that the requirements of the technical specifications have been met with respect to the composition, duties, meeting frequency, and responsibilities of the comittees, or their equivalent,
b. Observe at least one onsite and one offsite comittee meeting, if possible, to evaluate the depth of review of overall plant performance.

Issue Date: 09/19/88

+.

the members h3ve expertise and/or experience in all elements of plant }

operations, including engineering activities.

g.

Determine if the ISEG recommendations are tracked until resolution.

I Review the tracking mechanism ana the backlog.

02.04 Other Management Oversight Functions

a. Determine if licensee management and the review comittees effec-  !

tively use all available performance-related data to monitor plant '

performance. Review the performance data ' for anomalies and trends, and discuss with management, if necessary.

b. Determine if there are well-defined corrective action programs with adequate tracking and trending mechanisms. Verify that a program exists that ensures that the findings are forwarded to the appropriate level of management. Determine if recipients of recommendations are held accountable for responses,
c. Determine if periodic third-party or special internal reviews were conducted to assess any areas of weakness identified in item 02.01a and if effective corrective action was taken. If an ISEG is not implemented, determine if the licensee performs periodic independent self-assessments. Review the major third-party or independent reviews performed in the last year and the currective action (s) implemented.

02.05 Sumary of Safety Review Functions

a. On the basis of review of the activities of the oversight groups, determine if management is aggressive in follow-up of the recom-mendations of the groups. Verify that the licensee is meeting their corrective action due dates.
b. Determine if the overall self-assessment program is coordinated to ensure that all major functional areas (e.g., operations and maintenance) are reviewed,
c. On the basis of overall review and observation of the safety review activities, determine if 'all of the following functions are being achieved:

- Review and assessment of the operating experience of the licensee's plant and industry and application of the lessons learned

- In-depth evaluations of plant performance

- Review of significant policies, procedures, and practices that affect safety, and identification and review of unreviewed safety questions

- General assessments and issuance of findings to managenent

- Recommendations for improving plant safety and Clear Communication of and tracking of findin9s 40500 Issue Date: 09/19/88

During review of the minutes, determine if the comittee reviews safety-significant concerns that are not specifically required by technical specifications. '

c. Inspection Requirement 02.025. An onsite comittee meeting preserts a good opportunity for the inspector to observe the interactions of the various site organizations and supervisors. During attendance, note if plant management dominates the conversation, constructive discussion cccurs, the majority of the comittee consistently votes the same as the chaimon, or if the comittee is biased towards  !

operation or safety. Octermine if the offsite comittee meetings are periodically conducted at the site.

In addition, determine if the comittee uses design basis FSAR, ven-dor technical manuals, or similar documents for their determinations in addition to the technical specifications and the judgment of management.

d. Ins pect6 n Requirement 02.02c. Review the qualifications of the mem>ers to verity their experience levels. Ensure that the comittee membership is multidisciplinary. Ensure that a mix of experience is evident at comittee meetings from observation and a review of the -

minutes. Determine if the offsite comittee hos senior management members from other utilities or experienced consultants. Experience has indicated that the inclusion of outside members increases the effectiveness of the comittee , and should be encouraged. The inclusion of outside members, however, is normally not a requirement.

e. Inspection Requirement 02.03. An independent safety engineering group (ISEG) was required for each applicant for an operating license following TMI (TM1 Action Plan, Item !.B.I.2). The ISEG was estab-lished to perform independent reviews of plant operations.

NUREG-0737 states that the principal function of the ISEG is to examine plant operating characteristics, NRC issuances, licensing Information Service advisories, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety. The ISEG is to perform independent reviews and audit:i of plant activities, including maintenance, modifications, operational problems, and operational analysis, and aic in the establishment or programmatic requi rements fer plant activities. Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that they are performed correctly and that human errors are reduced as much as practicable. ISEG should be in a position to I

advise utility management on the overall quality On1 safety of operations.

For those plants that do not have en ISEG, this section can be omitted. If other org6nizations are in place that accomplish some of the functions of an ISEG, the applicable sections may be performed,

f. Inspection Requirement 02.04. Evaluate the licensee's program to <

dnalyZe the available sources of performance data, which may include a set of performance indicators, Cetermine if the comittees have been aggressive in seeking out areas needing improvement, rather than just responding to events and inputs from outside sources.

40500 Issue Date: 09/19/88

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f. '40500-04 INSPECTION RESOURCES 1 c
  • This^ 9nspection procedure 'is.. expected to take approximately 60 direct inspection hours on site by the resident inspectors per SALP cycle. -Portions 4^' of the procedure may also be performed by region-based or NRR inspectors. )

Actual: inspections at a. specific plant may require substantially more or less '

-time, depending on the circumstances.

.l7 ,

40500-05 REFERENCES ~

KUREG-0737, Item I.B.I.2, " Independent Safety Engineering Group"

. NUREG-0800, Standard Review Plan, Chapter 13.4, " Operational Review" -

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Standard Technical Specifications, Section 6.0 ANSI N18.7-1976, " Quality Assurance for the Operational Phase of Nuclear.

Power Plants' ANSI /ANS 3.2-1982, " Administrative Controls and Quality Assurance for the.

Operational Phase of Nuclear Power Plants" Regulatory), Guide _1.33, " Quality Assurance Program Requirements.-

(Operation " February 1978. Revision 2 '

Memorandum of February 14, 1986, from J. M. Taylor to regional administrators  ?

entitled "NRC Use of INPO Evaluation Reports (DCS 6628/200)." l END ,

1 t.

l 40500 !ssue !1 ate: 09/19/88

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  • ,/ 4 UNITED STATES

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. NR'C INSPECTION MANUAL toA8 i Inspection Procedure 35502 i

Evaluation of Licensee Quality Assurance  !

Program Implementation f

PROGRMi APPLICABILITY: 2515 35502-01 INSPECTION OPJECTIVE To evaluate the effectiveness of the licensee's implementation of its quality assurance program,'and to determine if, based on this evaluation, a foi w-up regional inspection is. warranted.

35502-02 INSPECTION RE00lREMENTS 02.01 Regional Management will evaluate the effectiveness of the licensee's-

-QA program implementation by conducting an in-office evaluation of the

.following:

a.  : Inspection reports for the past 12 months.
b. SALP reports for the past 2 years.

c Outstanding Regional Open Items List.

d. Licensee corrective actions for NRC inspection findings.

.e. Licensee Event Reports for the Past 12 months.  : ,

+

02.0E Based on the results of the evaluation performed in- section 02.01,

. determine it negative trends in performance were identified in one or more

' functional disciplines which would indicate problems in licensee QA program implementation. If negative performance trends in one or more disciplines are . identified from .the evaluation, a determination will be made by Regional if no H. Management regarding the need for additional regional inspection, follow up inspection is required, a detailed internal memorandum discussing the results -of the evaluation performed in section 02.01 above, will be P prepared for' use at the next SALP evaluation with a surranary of the results of f .

the. evaluation documented in the. next appropriate routine inspection report.

m If a1 follow-up inspection is required, the basis for that decision should be summarily documented along with the results of the follow-up inspection in a at

" routine inspection report.

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Issue Date: 08/29/88 s

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. b. 3 fnspection Requirement 02.02.,- -

Usirg the identified problems and g%

weaknesses, the facility's recent operating history, and input from i '

' thel inspection staff, _the Reofonal Management should look for and i

develop comm:9 interdisciplinary issues that indicate shortcomings in the licenseeis CA program: implementation (performance issues).

Examples _ of typical issues which cLuld be developed include weaknesses in - management, leadership and . communications, planning processes, priority setting, and management information systems.

..lf sufficient bases exist to warrant further inspection, Regional

>s

  • . Management shall develop and implement - a custom. inspection plan to ensure that the issues are properly addressed. In such: cases, the-Region should ;also corrunicate the results- of their evaluation with the DLPQ/LOAB and their p1ans- for additional follow-up inspections.

The LDAB should 'also be solicited for recommendations relative to the planned follow-up.

The' inspection plan will necessarily be conditioned by the 0A program performance issues identified by Recicnal Management. A problem that encompasses many functional areas, or the entire organization (i.e.,

ineffective safety significant equipment / system failures) may require a specific plan to determine rhether the root cause is. plant or corp-orate management attitude.'

35502-04 INSPECTION RESOURCES

-The evaluation _ required by tHs inspection is to be made approximately midway in each SALP ' period. The evniuation is expected to require abcut 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of

. direct inspection effort each SALP period.

35502-05 REFERENCES i

ANSI N 45.2.10-1973, " Quality Assurance Terms and Definitions."

ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the i

Operational Phase of Nuclear Power Plants."

NRC Manual Chapter NRC-051_6, " Systematic Assessment of Licensee Performance "

' June 6, 1980.

' NUREG/CR-5151, " Performance-Based Inspections," June 1988.

END l

l 35502 Issue Date: 08/29/88 1

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MEMORANDUM FOR: J. T..Wiggins,: Chief Reactor Projects Branch 3, Division of Reactor Projects, Region I .

FROM: D. R. Haverkamp, Chief Reactor Projects Section No. 3C, Division of Reactor Projects, Region I 1

SUBJECT:

SEABROOK READINESS ASSESSMENT TEAM OPERATING PIAN Enclosed is the final draft Operation Plan' for-the seabrook Re&diness Assessment Team Inspection (RATI).

administrative and technical guidance for Thethe ' plan RATI.provides the primary and preparation Detailed planning for the functional area inspections is the responsibility of the individual inspectors. Team assignments remain tentative date.

based on the uncertainty of the low power licanse issuance D. R. Haverkamp, Chief Reactor Projects Section No. 3C, j Division of Reactor Projects, Region I

Enclosure:

As stated cc-w/ encl:

J. Durr, DRS -

C. Anderson, DRS J. Strosnider, DRS P. Eapen, DRS -

R. Gallo, DRS  !

N. Blumberg, DRS P. . Eselgroth, DRS R. Bellamy, DRSS '

W. Pa$ak, DRSS M. Shanbaky, DRS L. Settenhausen, DRP C. Cowgill, DRP ,

E. McCabe, DRP E. Wanzingar, DRP P. Svetland, DRP J. Johnson, DRP '

l- L. Tripp, DRP R. Wessman, NRR/PDl-3 C. Berlinger, NRR/OECS RATI Members i

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L Final Draft ENCIDSURE OPERATING PLAN FOR TEM SEABROCE READINESS ASSE88 KENT TEAM INSPECTION

1. . Introduction The Seabrook facility was issued a zero power . license in October.

1986, . permitting . initial fuel load and. vessel assembl y.

Subsequently the licensee performed hot functional testing of-plant systems. The last plant heat-up evolution.was. completed in=-

March 1987. . At the request of . the NRC . the licensee recently initiated a self assessment program to evaluate their : readiness -

for issuance of a five percent power license.. During the week of October 31, 1988 Region I performed a team inspection to evaluate the quality of the self assessment program. The licensee's results from Phase I of the self assessment were submitted to the NRC for review on November 4, 1988. The NRC inspection team's evaluation combined with the licensee's submittal formed, in

' part, the basis for the conclusion that plant ~ systems and staff are currently ready for license issuance. The licensee's-schedule includes a two-week heat-up and precritical testing period' followed by two weeks of low power testing. The Seabrook

. Readiness Assessment Team Inspection (RATI) .will be conducted during the two week heat-up and precritical testing period.

NRC inspection activity at the site during the past 25 months has been minimal. Inspections have not yet been completed-in several SALP functional areas during this assessment period. As: such the .

results of this RATI will form a significant portion of the basis.

for the next SALP report.

2. Obiective The team operations (shift) inspectors are scheduled-% arrive onsite after issuance of the 5% power license and roughly coincident with the licensee's commencement of plant heat-up.

Other team members will arrive onsite about four days later. Tse ove 1 of the taas is to . assess the conduct of lic - associated with plant heat-ep to confirm r '- feuP nummmerw *=ent, of the lent power test progras.

Speci colly the team will:

a) Perform programmatic assessments in the areas of maintenance, surveillance, radiation protection, effluent monitoring, o safety assessment / quality verification, perations,and startup testing to be used in preparation of the Seabrook SALP report; V

a _ . - _ _ - _ _ _ _ _ - _ _ _ _ _ -

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b) To evaluate the readiness of plant equipment and staff c) for initial criticality and low power testing; j To evaluate the ef festiveness of the licensee's ongoing *

(Phase II) self assessment program d) To integrate the recently revised operations phase inspection program (2515) with the ongoing startup test inspection program (2514).

While review of programmatic controls is inDortant. RATI members should heavily weight their inspection activities to observation

' and evaluation of evolutions in the field.

3. Areas To Be Examined 3.1 The RATI will focus on the following functional areas:

- operations,

- Management Effectiveness / Assurance of Quality,

- Maintenance / Surveillance,

- Engineering / Technical Support,

- Radiation Protection,

-- Radwaste/Chemistr Startup Testing. y/ Effluents, 3.2 The following attributes are to be considered in each functional area:

Development and promulgation of management goals / objectives and how they are understood /im at various levels of the organization;plemented Planning /contro)'ing routine activities along with effective progrue implementation; Level of understanding by workers / supervisors of the potential impact of day-to-day actions on nucles:e safety; Involvement by senior management in day-to-day operation of the plant (including visibility of senior site and corporate management);

Effectiveness of training, guidance, and supervision by first-line supervisors; Role of QA/QC in monitoring activities and how their reports are used by plant management:

Adequacy of staffing in light of the change in plant status and planned activities:

t

' Effectiveness of safety review committees;

-Communications / problem solving process.

3.3 For the Seabrook RATI, in addition- to the planned programmatic reviews inspectors should examine those issues which have been identified by the licensee as remaining open at the time of startup. The following specific areas should, also receive-special emphasis:

PLANT OPERATIONS:

Adequacy of valve lineup procedures, Locked open Disposition /of closed valve Station controls, Reports Information

-Licensee interpretation of Technical Specification action statements, Temporary modifications control, Independent verification program.

MAINTENANCE / SURVEILLANCE:

Adequacy of the surveillance schedule (Specification

. Appraisal system),

Control / interpretation of the Technical Requirements Manual, Surveillance procedure consistency, Calibration of instruments used for data collection during surveillance testing.

ENGINEERING AND TECHNICAL SUPPORT:

Adequacy of lo crR 50.59 evaluations, Adequacy change, of the control building air handling system design Licensee corrective action in response to the RER motor bearing design problem.

STARTUP TESTING:

HFT retest of the EFW system CHEMISTRY AND EFFLUENTS:

L Waste gas system design change, Inspection report 86-36 open items.

RADICI4GICAL CONTROLS:

Establishment of the RCA, Restart of the dosimetry program, HP department staf fing Training of station staff in radiological control practices.

~l i

. MANAGEMENT, ASSURANCE OF QUALITY, SAFETY VERIFICATION:

Quality of the ongoing self assessment process (Phase II),.

Quality Assurance problem and audit report status and disposition.

4. Team Organization and Basic Operation The team will consist of a team leader, assistant team leader, and functional area inspectors ( Attachment A) . The team leader will be responsible for all activities of the and will function as the point of contact for all outsideteam, inqu iries and requests. Reporting to the team leader will be the assistant team leader who will be responsible for coordinating shift inspection schedules and results, and integrating them with functional area inspections. The Seabrook Senior Resident Inspector (SRI) will function as a technical advisor to the team leader during the course of the inspection. During the team inspection period the routine resident inspection program will be minimized as appropriate, based on team performance of equivalent inspection activities. The SRI will observe ongoing licensee and team activities and provide input to the team leader. The functional area inspectors will be responsible for the detailed inspection planning within their area using the attributes noted above, and for follow-up of shift inspector observations relevant to their area of interest as assigned by the assistant ten leader. All inspectors should keep in mind that the functiem L areas of management effectiveness, training, A1 ARA initiatives and assurance of quality span all areas.
5. Mode of Operations /Information Flow The inspection will be conducted in two segments. Shortly after I issuance of the low power license the assigned operations (shift) inspectors will arrive onsite for orientation and commencement of shift inspections. Shift inspection will continue in this manner ,

t for three to five days. The functional area inspectors will I arrive onsite at th,e completion of tnis initial shift inspection effort and will be briefed on the observations pertinent to their area. shift inspectors will be used to assist in performing functional area inspections during this second segment. This schedule will allow coverage of a two week period of licensee activities with a minime.m commitment of manpower, and will assist in providing focus to the functional area inspections.

Many of the inspection and monitoring activities during this I inspection will be windows of opportunity (e.g. shift turnovers, l

ongoing plant. testing and operational evolutions, ongoing maintenance and surveillance follow-up of any plant events). For such activitiesactivities, general inspection planning and guidelines apply. As observations start to come in and are processed for follow-up they become the priority for review.

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Inspectors are expected. to focus - their activit'ies so as to ' be -

able to meet the inspection objectives as discussed- above.

In-field 7 inspection should be: essentially complete b y .- n o o n . o n -

Thursday Decenber .15

  • to allow thorough follow-u discussion and integration of. fin, dings. As the inspection is.p, conducted Ghe inspectors should -keep in. mind and refer to the intent oL the .

programmatic . inspection procedures. (IP) listed - in Attachners 8.

The inspector - will ' be asked to provide. inspection time agaihst each appropriate IP at the conclusion of the inspection.- The IPs are for reference onl completion be achieved. y and it is not intended that- 100%~

Any safety concerns, apparent or potential L violations, or items of significance will be after the matter has. been promptly identifiedconveyed . to : the team to Me appropriate leader:

licensee representative (shift supervisor or other licensee manager of~

this level or above .

approximately 9-hour ) days.Each team member is expected to work .

Team members.will meet-daily between 7:00 and 7:30and activities,-

a.m. 'to discuss observations and sheduled licensee to adjust- inspection schedules as' needed.'

Individual team member' debriefs will be conducted near the close of the work day to' provide timely information to the team leader.

6. Schedule and Shift Coverage The onsite shift inspection will begin on December 5. Functional area . inspectors should plan to arrive onsite at 7:00 p.m. on' December 11, and will remain through the - inspection exit- meeting on' December 16. Ali team members are expected.to be available.in the Region I office December 19-23, _ as needed,- to complete.

inspection report . documentation. Although the -licensee shifts-are 0700-1500, 1500-2300, and 2300-0700 hours, shift turnover -is typically conducted one hour before shift change. Therefore,.to-provide for review of plant conditions before shift change, NRC.

shifts will be 0600-1545, and 2200-0745. This.

provides a nominal nine-hoar work 1400-2345, day' w ith a forty-five minute-meal break. Licensee plant staf f hours are ' 0700-1530,- and the licensee engineering staf f , hours are 0800-1630. A Plan of the.

, Day meeting is conducted by the plant staff each morning at 0830-onsite. -Team members other than the- shift inspectors will-generally work from 0700-1645 to correspond to station staff hours.

  • Dates shown in bold face are tentative based on the uncertainty associated with the issuance of the low power operating license.

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7. Inspection Documentation

' Each shift and functional area inspector should place significant -

observations including:

and activities witnessed in the common log provided, Significant events that occur durin and important observations thereof; g the inspector's shift Significant information exchanges, including source (person (s));

concerns identified, including bases, along with the-identification of facts versus perceptions; Routine observations.

It is important to note positive, as well as negative, observations.

At the conclusion of the inspection the inspector assigned . as lead for each functional area vill be responsible for" preparation of the draft input for that area. Inputs will be submitted to the assistant team leader for incorporation into the final inspection report. Again positive along with negative observations are needed for proper perspective. The format and content of the input should conform with the outline shown in Attachment C. Each section should include; 1) criteria and scope of review, 2) findings and conclusions, and 3) an. overall summary.

8. Administrative

- Travel Orders (Inspection Report 50-443/88-80).

- Hotel. accommodations: Hampton Falls Motor Inn.

- Telephone numbers: Hotel: 603-926-9545 Site: 603-474-9521 SRI (Site): 603-474-3589/3580, x2045 (Home): 603-433-3094

- Badging will be arranged as follows.

Shift Inspectors:

Tunctional Area InspectorsetT/iN 12/3/ W

- Briefing including books containing a list of licensee general contacts, site information,ided will be prov by the licensee.

- Specific instructions for completeion of RITS and 766 forms will be provided.

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[; ' ' ' Attachments

' Attachment A:.Seabrook RATI Roster p

' Attachment B: Reference Inspection Procedures

(' Attachment C: Inspection Report Format i .,

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ATTACIDGNT A i

!. ' SEABROOK RATI ROSTER Team Leadar: Re-Cont'Er' SRI: @- RMci-tte- A/. Su M '~.*

Assistant Team Leader: J. Lyash

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Functional Area Inspectors:

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, Operations: Lyash/Gibson/ Resident l Inspector /DRP Inspector

  • Maintenance and Surveillance: Oliveira ,

Engineering and Technical Support: Prividy i g

i Chemistry and Effluents: ERPS Representative Radiation Protection: Weadock 1

Startup Testing: Wen or PWR Section Rep. l Management, A of Q, and Safety Verification: Nerses (.4c n.hNWC)  !

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Tentative assignments that are subject to change as a result of l potential revision of the inspection period and inspector availability, are in bold face.

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ATTACIDGNT 3 a

Reference Inspection Procedures

  • ALL AREAS
  • 30703 Management Meetings (Entrance / Exit) 42700 Procedures 137703 Tests and Experiments Program 39701- Records Program 39702 Document Control program PLANT OPERATIONS

'*71707 Operational Safety Verification.

71710 EST System'Walkdown

  • 71715 Sustained Control Roca Observation MAINTENANCE / SURVEILLANCE
  • 62700 Maintenance Program - Implementation 62702 Maintenance Program
  • 62703 Monthly Maintenance Observation 62704 -Instrument Maintenance 62705 Electrical Maintenance
  • 61726 Monthly Surveillance Observation
  • 61700 Surveillance Procedures and Records 61701 Complex' Surveillance 56700' Calibration ENGINEERING AND TECHNICAL SUPPORT
  • 37700 Design, Design Changes and Modifications 37701 Facility Modifications 37702 Design Changes and-Modification Program 38701 Procurement Control 38702 Receipt, Storage and Handling of Equipment Program 37828 Installation and Testing of Modifications
  • 72701 . Modification Testing STARTUP TESTING 72300 startup Test Procedure Review 72301 Startup Test Results Evaluation
  • 72302 Startup Test Witnessing Specific startup test inspection modules will be used as. determined by the licensee's testing activities during the inspection period.

RADIATION PROTECTION 883521 Startup Radiation Protection 83750 Occupational Exposure, Shipping and Transportation

  • Indicates those primary inspection modules which are to be used for time accounting purposes.

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s RADWASTE, CHEMISTRY AND EFFLUENTS -

  • 84521.

s Startup Radwasta 84750 Radioactive Waste Systems; Water Chemistry; confirmatory Measurements and Radiological Environmental Monitoring i MANAGEMENT, A$SURANCE OF QUALITY, AND SAFETY ASSESSEMENT

  • 40500 Evaluation of Licensee Self-Assessment Capabilities-40501 Risk Focused Operational Readiness Assessment 40702 Audit Program 40703 Off-site Support Staff 40704 Audit Program - Implementation 35502- Evaluation of-Licencee QA. Program Implementation 35702 Inspection of Quality Verification Function
  • 92720 Corrective Action 9

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ATTACEXENT C Inspection Report Format COVER MATERIAL:

Cover Letter Team Leader Notice of Violation Individual Inspector Report Summary Team Leader Table of contents Assistant Team Leader DETAILS :

1. Overview Assistant Team I4ader 3.1 Licensee Activities 1.2 NRC Staff Organization / Activities 1.3 Persons Contacted X* Function Area Inspections Individual Inspectors
  • X.1 Criteria and Scope of Review (1) In general terms, provide a statement of the criteria you used in judging this a r e,a . A detailed listing is not warranted, but a general reference to a particular ANSI Standard or TS is appropriate.

(2) Provide a description of the bases upon which you formed your judgements in the area. For example a general statement regarding interview of cognizant personnel is appropriate, with Section 1.1 listing key members who provided you with significant information.

X.2 Findings and Conclusions.

(1) Provide a description of your significant observations and findings. It is important to present positive as well as negative findings.

! The subparagraphs listed in item (2) below can be I used for guidance in preparing this section. You should start with X.2.1 aceneral Observations",

highlighting overall program elements. Not all of the subparagraphs listed need be addressed.

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r _ (2) X.2.1 General observations X.2.2 Quality of Work / Activities X.2.3 Interface / Communications-X.2.4 Engineering Support X.2.5 Training X.2.6 Safety X.2.7 Self-Review Assessment. / Corrective Actions X.-3 Summary

" (1) Provide a SALP type assessment of the licensee's program staffin of your, review. g and performance within the scope .

Sections listed in Attachment will be numbered A to thesequentially plan. Functional by functional area as are -1*o listed in Attachment A. area assignme-ts b

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