IR 05000443/1997002
| ML20140D128 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140D122 | List: |
| References | |
| 50-443-97-02, 50-443-97-2, NUDOCS 9706100255 | |
| Download: ML20140D128 (23) | |
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ENCLOSURE 2 U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-443 License No.: NPF-86 Report No.: 50-443/97-02 Licensee: North Atlantic Energy Service Corporation Facility: Seabrook Generating Station, Unit !
Location: Post Office Box 300 Seabrook, New Hampshire 03874 Dates: March 4,1997 - April 14,1997 Inspectors: John B. Macdonald, Senior Resident inspector i David J. Mannai, Resident inspector ;
Gregory C. Smith, Sr. Security Specialist !
Emergency Preparedness and Safeguards Branch ,
Division of Reactor Safety
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Accompanied by: Javier Brand, Resident inspector Intern
Approved by: Richard J. Conte, Chief, Projects Branch 8, l Division of Reactor Projects l
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9706100255 970530 PDR ADOCK 05000443 0 PDR
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EXECUTIVE SUMMARY Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/97-02 ;
This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspectio Qperations:
- An operator dernonstrated outstanding questioning perspectives that identified that I the main steam line radiation monitors were incorrectly located. Appropriate l immedicte corrective actions were implemented including; entering applicable Technical Specification action statements; initiating alternate monitoring; generating i an adverse condition report; and developing a design change to properly locate the monitors and revise associated calculations. This issue remains unresolved pending j NRC review of the adequacy of the longer term corrective action processes including issuance of a licensee event repor * Several questions remain unresolved regarding the adequacy of administrative controls used to place a temporary heater in the cooling tower pump roo Specifically, the heater was put in place via a heater permit only. The more comprehensive controls established in the procedure that governs the control of temporary equipment were not use * Shift management and operations personnel maintained excellent control and awareness of the status of the installation of a temporary modification that was necessary to support the permanent installation of a third spent fuel pool cooling pump. Additionally, the initial pre-evolution brief and subsequent shift briefings were very comprehensiv * In contrast, shift operations did not initially critically assess the operational impact of planned maintenance on a charging system isolation valve. The licensee reassessed that activity prior to initial implementation, and subsequently enhanced the operational controls of components affected by the maintenanc Maintenance:
- The temporary modification installed to support a permanent third spent fuel pool cooling pump was well developed and effectively supported by a 10 CFR 50.59 safety evaluation. Strong supervisory presence was noted throughout the period during which the temporary modification was being installe * Maintenance personnel effectively inspected the positioners for the feedwater regulating valves and atmospheric steam dump valves in response to recent industry experience. The work was considered a trip avoidance activity, and appropriate controls were note ii
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Executive Summary
- Maintenance personnel effectively replaced a faulted air regulator on a charging system isolation valve. Good supervisory oversight was apparen Enaineerin_gi
- Engineering performed an effective technical evaluation of the thermal and reactivity effects of cycling a closed charging system isolation valve in order to perform corrective maintenance. However, initially the evaluation did not address system operational configuration contro * Engineering developed a scand temporary modification to maintain spent fuel pool cooling while connections were being installed to support operation of a third spent fuel pool cooling pump. The accompanying 10 CFR 50.59 safety evaluation was comprehensiv * Inspection of the preparations for ultrasonic testing (UT) of the pressurizer shell to upper head weld was performed in April,1997, at the EPRI NDE Center in Charlotte, NC. This was to obtain an overview of the method, qualification practice, the UT mockup assembly, performance of the UT equipment, ASME Code inspector (ANil) involvement, and related results. The computer-based UT procedure selected was found to be a high quality method to examine the subject weld zon Plant Suooort:
- The security organization has maintained strong control of temporary trailers and other temporary structures brought onsite to support the upcoming outag * The licensee maintained an effective program. Management support was evident by upgrades in the program. The alarm station operators were knowledgeable of their duties and responsibilities, security training was being performed in accordance with the NRC-approved training and qualification plan and management controls for identifying, resolving, and preventing programmatic problems were effectiv Protected area detection equipment satisfied the NRC-approved Physical Security Plan commitments, security equipment testing was being performed as required in the Plan, and maintenance of security equipment was being performed in a timely manner as evidenced by minimal compensatory posting associated with security equipment repairs. Based on observations and discussions with security officers, the inspectors determined that they possessed the requisite knowledge to carry out their assigned duties and that the training program was effective. As an addition to the inspection, the UFSAR initiative, Section 6.7 of the Plan, titled " Vehicle Access" was reviewed. The inspectors determined, based on discussions with security supervision, procedural reviews, and observations, that vehicles were being searched and controlled prior to entry into the protected area as described in the Plan and applicable procedures. However, vehicles designated as licensea designated vehicles (LDVs) were routinely stored outside the protected area (PA).
The NRC regulations and the licensee's NRC-approved security plan require LDVs to iii
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.- i Executive Summary :
l remain inside the PA except for operational, maintenance, repair, security, and ,
emergency purposes. The failure to control LDVs properly was identified as a ,
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' Assurance of Quality I-e . Quality oversight personnel were observed to be present for key work activities throughout the inspection report perio e Good independent quality oversight was evident throughout the spent fuel pool - i temporary modification installatio )
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i TABLE OF CONTENTS l
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Pane EX EC UTIV E S U M M A R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ji !
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T ABLE O F CO NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v i 1. Operations .................................................... 1 01 Conduct of Ope ration s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments .............. ....................... 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1 02.1 Incorrect Main Steam Line Radiation Monitor Location ............. 1 02.2 Cooling Tower Pump Room Temporary Equipment ................ 2 l
07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 0 Industry Operating Experience .............................. 3 j 07.2 Shutdown Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 i 11. Maintenance .................................................. 5
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M1 Conduct of Maintenance ....................................... 5 l M1.1 Spent Fuel Pool Cooling Temporary Modification ................. 5 !
M1.2 Preparations for On-Line Maintenance on Charging System isolation ;
Valve................................................ 6 l Ill . Engin e e ri ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . 7 E Pressurizer Head to Shell Ultrasonic Testing (UT) Preparation, inspection Procedure .................................... 7 I i
l IV. Plant Support ................................................. 8 l l
R1 Radiological Protection and Chemistry Controls ....................... 8 R1.1 General Comments ...................................... 8 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . . . . . . 9 S2 Status of Security Facilities and Equipment .......................... 9 i S Protected Area (PA) Detection Aids . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 S2.2 Alarm Stations and Communications . . . . . . . . . . . . . . . . . . . . . . . . . 10 S2.3 Testing, Maintenance and Compensatory Measures . . . . . . . . . . . . . . 10 l S5 Security and Safeguards Staff Training and Qualification (T&O) . . . . . . . . . . . 11 v I
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= Table of Contents S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 S7 Quality Assurance in Security and Safeguards Activities . . . . . . . . . . . . . . . . 12 S7.1 Ef fectiveness of Management Controls . . . . . . . . . . . . . . . . . . . . . . . 12 X1 Review of Updated Final Safety Analysis Report (UFSAR) . . . . . . . . . . . . . . . 12 ..
. Control of Temporary Refueling Outage Facilities . . . . . . . . . . . . . . . . ... . . . 13
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V. M a nag e m e nt Me eting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 X1 Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
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INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i LIST O F ACRO NYM S U SED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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i Report Details
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Summarv of Plant Status
The facility operated at approximately 100% of rated thermal power throughout the
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i inspection period with routine minor power reductions performed to support instrument calibrations and turbine va!ve testing.
i 1. Operations 01 Conduct of Operations
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01.1 General Comments (71707)
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ongoing plant operations. In general, routine operations were performed in accordance with station procedures and plant evolutions were completed in a i
deliberate manner with clear communications and effective oversight by shift
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- supervision. Control room logs accurately reflected plant activities and observed i shift turnovers were comprehensive and thoroughly addressed questions posed by the oncoming crew. Typically, control room operatore displayed good questioning
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i the case of the originally proposed on-line repair of a charging system isolation
- valve, operators did not critically question the operational aspects of the planned l evolution (additional details in Section M1.2). The inspectors found that operators were knowledgeable of plant and system status.
j O2 Operational Status of Facilities and Equipment 3 Insoection Scone (71707. 62707)
The inspectors routinely conducted independent plant tours and walkdowns of i selected portions of safety-related systems during the inspection report perio I
- Tnese activities consisted of the verification that system configurations, power j supplies, process parameters, support system availability, and current system l operational status were consistent TS requirements and UFSAR description l Additionally, system, component, and general area material conditions and l housekeeping status were note l 02.1 incorrect Main Steam Line Radiation Monitor Location .
j Scope On March 14,1997, during operator training walkdowns, an operator identified that the four main steam line radiat;on monitors were installed downstream of the atmospheric steam dump valves. This configuration is contrary to UFSAR Section 11.5.2.1.] which states that the radiation monitors are upstream of the safety relief valves. The inspectors reviewed the licensee immediate corrective actions to this discover i
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2 Observations and Findinos The licensee generated ACR 97-0535 in response to this event. Engineering j personnel developed design coordination report, DCR 97-017, was developed to ~
coordinated the proper repositioning of the monitors and to ensure revision of associated calculations for dose projection models, drawings, and UFSAR references. Additionally, Technical Specification Section, TS 3.3.3.1 was entered and alternate monitoring was initiated in accordance with station procedure, HX 0958.12. The monitors were repositioned and the dose projection models were revised and the system was declared operable on March 20,199 Conclusions i immediate licensee response to this event was effective. The monitors were declared inoperable, appropriate Technical Specification actions were fulfilled, an ACR was generated, and a well coordinated design change to properly relocate the monitors was developed. The inspectors observed portions of the field work end l noted good quality oversight and craftsmanship. The licensee corrective action process was not complete at the conclusion of the inspection report perio Therefore, final NRC staff evaluation of the problem and adequacy of overall licensee causal analysis, corrective actions, and licensee event report remain unresolved. (UNR 50-443/97-02-01) 1 02.2 Cooling Tower Pump Room Temporary Equipment Observations and Findingg On March 26,1997, during a routine tour, the inspectors noted the presence of temporary heaters in the cooling tower pump room. The inspectors subsequently questioned control room supervision regarding the purpose for the heaters and associated controls and documentation supporting the installatio Control room personnel indicated that a temporary heater permit had been issued by 1 site fire protection personnel on December 9,1996. The inspectors questioned if l
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installation of the heaters had been governed by procedure MA 4.8, " Control Of Temporary Equipment." Shift management could not determine if MA 4.8 was applicable to this installation and documented the concern on ACR 97-060 Additionally, the shift manager directed that the heaters be removed promptly. A l low temperature alarm for the cooling tower pump room inputs to the main plant !
computer system (MPCS). Should a low temperature condition be present in the !
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pump room, the associated video alarm system (VAS) computerized response procedure directs that the need for temporary heaters be evaluated.
l Control room personnel could not determine from the documentation available in the l
control room if the heaters had been installed as a result of a valid low temperature I alarm. The system engineer was contacted and indicated the heaters had been
! installed for personnel comfort only and were not being used to maintain room )
temperature for equipment design or operabilit l i
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The inspector reviewed the completed ACR evaluation and noted that it was designated for trend only, with the immediate corrective action of removing the temporary heater Conclusions The inspectors concluded that the licensee did not provide positive control over the installation of the temporary heaters located in the cooling tower pump roo Initially, although it appears that procedure MA 4.8 should control the installation of such temporary equipment in safety-related spaces, the heaters were installed by issuance of a temporary heater permit. Additionally, documentation for the actual technical reason for the temporary heater installation was not available to control i room personnel within a controlled administrative program. This issue remains j unresolved pending completion of licensee action to resolve the related ACR and NRC review of the adequacy of licensee evaluaticns to determine specifically if l appropriate administrative controls were used in the installation of the temporary heaters and generically, if existing controls for the installation of temporary equipment are adequate. (UNR 60-443/97-02-02)
07 Quality Assurance in Operations 07.1 Industry Operating Experience , Insoection Scoce On March 4,1997, the licensee reported receipt of industry experience that identified a deficiency in a retaining clip located in a Baily controls positioner that appeared to have potential generic applicability. The licensee determined that the specific positioners were installed at Seabrook in applications within the feedwater regulating valves (FRV) and the atmospheric steam dump valves (ASDV). A repetitive task sheet, RTS 97R102661608, was developed and on March 28,1997 inspections were performed on the affected positioners. The inspectors reviewed the RTS, attended the pre-evolution briefing, and observed portions of the inspection Observations and Findinas The briefing for the inspections was well attended and proper plant trip avoidance measures were discussed. The inspections were properly conducted with good in-field supervision present and good communications with the control room maintained throughout the inspections. The retaining clip for the cam follower on FRV, FW-FCV-510, was missing. The bearing normally held in place by the retaining clip was observed to have shifted on the positioner cam shaft, such that the cam and bearing contact area hao been decreased. The RTS scope was changed to place the FRV in a gagged or locked position while technicians attempted to reposition the bearing and replace the retaining clip. However, the bearing could not be moved. The licensee concluded that minute fragments of the missing retaining ring became lodged between the bearing and shaft effectively
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I 4 locking the bearing in place. The cam follower roller facing on the remaining FRVs I
were heavily worn and the retaining clips were in place, but their physical condition could not be determined. Similarly, the ASDV retaining clips were in place, but the extent of wear could not be determined. The licensee will continue to inspect positioner condition via the RTS until plant conditions can support component replacement.
l l Conclusions The licensee operating experience program effectively identified a potential component failure mechanism that was applicable to Seabrook Station. An inspection program was promptly developed and performed that verified that the retainer ring degradation was present in the positioners installed in the FRVs and ASDVs. The inspection plan will be implemented periodically until permanent repairs are performed. The inspector had no further question .2 Shutdown Risk Assessment Insoection Scoce (60705,71707,37551)
The inspector hold discussions with the reliability and safety engineering group concerning the upcoming refueling outage schedule and their review of the schedule using the Outage Risk Assessment and Management (ORAM) management too Observations and Findinas The Seabrook Station Probabilistic Safety Study-Shutdown was used in developing the Seabrook specific model. The model uses key safety functions such as Decay heat removal (DHR), spent fuel pool (SFP) cooling, AC power, inventory control, reactivity control, containment integrity, and time to boi The outage schedule is evaluated using ORAM. The ORAM is a management too!
used to evaluate and minimize shutdown risk throughout all phases of outage operations. Since the Seabrook shutdown probabilistic risk assessment (PRA)
determined that loss of decay heat removal capability is the dominant' contributor (i.e.,85%) to potential core damage frequency, the licensee has placed conservative restrictions on equipment availability beyond that required by plant technical specifications (TS). Additionally, the plant continually maintains a configuration where passive decay heat removalis possibl . Conclusions The inspectors concluded the reliability and safety engineering group implementation l of ORAM was a considerable strength. The reliability and safety engineering l personnel were knowledgeable of the plant systems and the plant-specific PRA.
l The ORAM has been used to assess outage risk in a manner which has led to the development of outage risk management and scheduling strategies focused on
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maintaining maximum margins of safety and defense-in-depth for key safety ,
functions. The inspector had no further questions.
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11. Maintenance j
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M1 Conduct of Maintonance (62707)
M1.1 Spent Fuel Pool Cooling Temporary Modification Scope Seabrook Station routinely performs a full core off load during normal refueling ,
outages. In order to ensure the ability to maintain spent fuel pool (SFP) ;
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temperatures to less than 140 degrees Fahrenheit during a full core off load concurrent with a limiting single active failure, the licensee developed a design change to install a third SFP pump. The design coordination report, DCR 94-005, controls the installation of a third SFP pump that is identical to the existing pumps and that can be powered by either of the two safety-related emergency electrical :
busses. Previously, through DCR 94-045, the licensee had established the ability to !
cross-tie the primary component cooling water trains. In order to complete the installation of the third SFP cooling pmp, a temporary modification (TM) was required to ensure a means of long term SFP cooling was available while modifications to suction and discharge piping were performe ,
The inspectors reviewed DCR 94-005, TM 97-02, operating procedure OS 97-1-4,
" Temporary Modification for SFP Cooling," and associated 50.59 safety evaluations. Additionally, the inspectors attended station operations seview committee (SORC) meetings that reviewed and approved various documentation related to the modifications, observed pre-evolution briefings, and observed portions of the installation of TM 97 0 i Observations and Findinas On March 20,1997, the licensee began the installation of TM 97-02. The TM consisted of two temporary pumps, a piping manifold or spool piece, flexible hoses, and instrumentation to support operation of the SFP cooling system in the configuration established by the TM. The TM and associated 50.59 safety evaluation and operating procedure were comprehensively reviewed by the SOR The pre-evolution briefing thoroughly addressed all aspects of the TM. The ,
inspectors observed significant portions of the TM installation and noted excellent i operational and technical staff knowledge of the TM objectives and status. Work group supervision was effective and good independent quality oversight was ;
evident. Additionally, the inspectors noted excellent fore.ign material exclusion control implementation. The TM was properly installed Md effectively supported SFP cooling system modifications. Following completion of portions of DCR 94-005, TM 97-02 was restored and the normal SFP cooling configuration was restore l
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6 Conclusions The licensee developed a comprehensive design change that effectively enhances SFP cooling system performance margins and operational flexibility. Good briefings, field supervision and oversight, and craftsmanship were evident. The inspectors had no questions regarding this activit M1.2 Preparations for On-Line Maintenance on Charging System isolation Valve I Observations and Findinas On April 9,1997, the licensee prepared to perform corrective maintenance on the air supply regulator for the loop No. 4 charging isolation valve, CS-V-177. The -
regulator was leaking causing the supplying air compressor to cycle frequently. CS-V-177 is the isolation valve for one of two normal redundant charging flow paths, j with only one path required for plant operations. In order to minimize thermal transients, the licensee normally alternates the use of the charging flow paths on an ;
operational cycle frequency. During the current operating cycle, normal charging flow has been via charging isolation valve CS-V-180. Therefore, CS-V-177 has 1 remained in the closed position. However, the planned repair or replacement of the regulator required that CS-V-177 be opene The inspectors reviewed the work request, WR 96-002957, and associated on-line maintenance assessment form, UFSAR Section 9.3, operating procedure, OS ;
1002.2, " Operation of Letdown, Charging, and Sealinjection," attended the pre- l evolution briefing, and held discussions with cognizant licensee personne During the course of the pre-evolution briefing, the inspectors questioned several aspects of the planned activity. Specifically, it appeared that several applicable criteria of the on-line maintenance assessment form including " potential to impact the UFSAR, design or regulatory commitments" and " requires entry into a high radiation area or a locked h_igh radiation area" had not been annotated. The inspectors noted that engineering personnel had performed a comprehensive technical evaluation of the thermal cycling and reactivity effects of opening CS-V-177. However, the briefing did not address the appropriateness of maintaining CS-V-180 in the open position during the conduct of maintenance on CS-V-177. This configuration would have resulted in both charging flow paths being in service simultaneousl The licensee terminated the briefing in response to the questions posed by the inspectors. ACR 97-693 was generated to document the concerns. Additionally, the inspectors met with cognizant licensee management to discuss the inspector concerns. The licensee subsequently ensured proper completion of the on-line maintenance assessment form and established configuration controls to ensure that CS V-180 would be closed immediately after CS-V-177 was verified to be in the open position. The work effort was subsequently briefed, the air regulator was I replaced, post maintenance testing was completed, and normal system configurations were restored without consequence later on April 9,199 ]
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, c. Conclusions inspector review of this activity identified several weaknesses. Initially, a lack of j attention to detail was evident in the incomplete status of the on-line maintenance form screening criteria. However, more significantly, the inspectors concluded that the initial engineering evaluation and pre-evolution brief for the work effort did not l effectively focus on operational aspects. Specifically, manipulation of the charging l
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system flow paths should have been considered an operational evolution in which operations and shift management ensure the directed actions are consistent with existing plant procedures and UFSAR descriptions. Rather, it appeared that during l the initial briefing, the system manipulations were considered the initial steps of a maintenance activity controlled by a work request. The inspectors met several times with station and operations management to ensure that proper operational focus was maintained during support of maintenance activities. These issues have been included in the scope of ACR 97-693. Additionally, the licensee implemented immediate actions to ensure proper operational control of plant configuration throughout the maintenance effort. The inspector has no further question Ill. Enaineerina E2 Engineering Support of Facilities and Equipment E Pressurizer Head to Shell Ultrasonic Testing (UT) Preparation, inspection Procedure (73753)
I a. Scope l
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Inspection of the preparations for ultrasonic testing (UT) of the pressurizer shell to upper head weld performed in April 1997, at the EPRI NDE Center in Charlotte, N This was to obtain an overview of method, qualification practice, ASME Code !
Inservice inspector (ANil) involvement, observation of the UT mockup assembly and to view the performance of the UT equipment and related result b. Findinos Ultrasonic testing of the pressurizer to upper head weld is an examination required by the ASME Code Section XI during the first 10-year inspection interval. The weld has an access limitation of 31/2 ir.ches due to a concrete wall around the pressurizer. Because of this limitation, the licensee evaluated potential volumetric examination options and selected a computer-based " Time of Flight" (TOF) UT technique supplemented by a 60 refracted longitudinal (RL) wave and a 70 degree RL near surface creeping wave examination to obtain full coverage of the weld volume. A welded calibration mockup using the materials of pressurizer construction, approximately 24" x 39" with ID and OD notches, side drilled holes and built-in longitudinal and transverse cracks was prepared for use in the UT procedure setup and demonstration. Additionally, a set of Performance Demonstration Initiative (PDl) welded assemblies with built-in defects were examined using the UT procedure essential variables, personnel and equipment to
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verify the effectiveness of the technique. The calibration mockup was radiographed to confirm the weld quality and location of notches, holes and crack The inspector reviewed the plans for conducting the pressurizer to upper head weld UT, examined the mockup and related drawings, observed the UT equipment during use, reviewed the UT system performance demonstration plan and discussed the ;
effort with those involve ; Conclusions The computer-based UT pro::edure selected was found to be a high quality method to examine the subject weld zone. The effort in planning and confirmation that the selected UT method would provide for adequate volumetric examination of the pressurizer upper head to shell weld was extensiv !
IV. Plant Support R1 Radiological Protection and Chemlitry Controls i
R1.1 General Comments i nmpection r Scoce i During the inspection period the inspector toured the radiologically controlled area (RCA) on several occasions to observe radiological controls practice Observations and Findinas l i
The Seabrook Station radiological controls technicians at the RCA checkpoint were i attentive and provided assistance to radiation workers to assure proper work practices were used when radiation workers signed in and out of the RCA. The inspector determined that radiation area postings were proper and well marked and survey results were current and posted properly. All personnel observed were properly wearing dosimetry while in the RCA. A sampling of high radiation area l doors identified no discrepancies with locking or posting requirement ! Conclusiong The inspector determined that Seabrook Station was properly implementing the l station radiological controls program requirements in the areas inspecte '
Radiological controls personnel were knowledgeable of station procedures and '
l provided good oversight of radiation workers. Department managers were observed in the field observing and supervising department personne I
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S1 Conduct of Security and Safeguards Activities !
i Insoection Scooe
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The inspectors reviewed the security program during the period of March 3-6,1997. Areas inspected included: effectiveness of management controls; management support; protected area (PA) detection equipment; alarm stations and communications; testing, maintenance and compensatory measures; training and qualification; and control of vehicles. The purpose of this inspection was to determine whether the licensee's security program, as implemented, met the licensee's :ommitments in the NRC-approved security plan (the Plan) and NRC regulatory requirement Observations and Findinag i
Management support was evident by the upgrades to the security communications system, weapons armory, and intrusion detection system, the issuance of non-lethal weapons to security force members and the completion of the specifications for a new access control syste Alarm station operators were knowledgeable of their duties and responsibilities and security training was being performed in accordance with the NRC-approved training and qualification (T&O) plan. Management controls for identifying, resolving, and preventing programmatic problems were generally effectiv The PA detection equipment satisfied the P.lan commitments and security equipment testing was being performed as required by the Plan. Maintenance of security equipment was being performed in a timely manner as evidenced by minimal compensatory posting associated with non functioning security equipmen !
However, a violation was identified relative to the failure to control licensee i designated vehicles (LDV) properly. (See Section X2) l Conclusions The inspectors determined that the licensee was conducting its security and j safeguards activities in a manner that protected public health and safety, except for '
the proper control of LDV l
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S2 Status of Security Facilities and Equipment !
S2.1 Protected Area (PA) Detection Aids Insoection Scope
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Conduct a physical inspection of the PA intrusion detection systems (IDSs) to verify that the systems are functional, effective, and meet the Plan commitment .
J 10 Observations and Findinas On March 4,1997, the inspectors determined by observation of selected testing that the IDSs were functional and effective, and were installed and maintained as described in the Pla Conclusion
The PA IDSs met the Plan commitment !
S2.2 Alarm Stations and Communications
! Insoection Sco l Determine whether the Central Alarm Station (CAS) and Secondary Alarm Station ;
(SAS) are: 1) equipped with appropriate alarm, surveillance and communication '
capability, 2) continuously manned by operators, and that 3) the systems are ,
independent and diverse so that no single act can remove the capability of detecting I a threat and calling for assistance, or otherwise responding to the threat, as required by NRC regulations, i Observations and Findinas l I
Observations of CAS and SAS operations verified that the alarm stations were equipped with the appropriate alarm, surveillance and communications capabilities, as described in the Pla Interviews with CAS and SAS operators found them knowledgeable of their duties and responsibilities. The inspectors also verified through observations and interviews that the CAS and SAS operators were not required to engage in activities that would interfere with their assessment and response functions, and that the licensee had exercised communications methods with the locallaw enforcement agencies as committed to in the Pla Conclusion The alarm stations and communications met the Plan commitments and NRC requirement S2.3 Testhg, Maintenance and Compensatory Measures Inspection Scope Determine whether programs are implemented that will ensure the reliability of security-related equipment, including proper installation, testing and maintenance to replace defective or marginally effective equipment. Additionally, determine that when security related equipment fails, the compensatory measures put in place are comparable to the effectiveness of the security system that existed prior to the failure,
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Review of testing and maintenance records for security-related equipment confirmed that the records were on file, and that the licensee was testing and maintaining l systems and equipment as committed to in the Plan. A priority status was assigned ;
to each work request and repairs were normally being completed in a timely mariner ;
for all work necessitating compensatory rneasure ' Conclusions Security equipment repairs were timely. The use of compensatory measures was found to be appropriate and minimal. The maintenance and testing being implemented were reasonable to ensure equipenent reliability, j
S5 Security and Safeguards Staff Training and Qualification (T&Q)
a. Insoection Scope i
i Determine whether members of the security organization are trained and qualified to perform each assigned security-related job task or duty in accordance with the T&Q pla b. Observations and Findinos On March 4,1997, the inspectors met with the security training staff and discussed I the on-shift training requalification program and its effectiveness. Additionally, the inspectors interviewed a number of supervisors and officers to determine if they possessed the requisite knowledge and ability to carry out their assigned duties, c. Conclusions i
The inspectors determined that training had been conducted in accordance with the l
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T&Q plan. Based on the supervisors' and officers' responses to the inspectors'
questions, the training provided by the security training staff was considered effectiv S6 Security Organization and Administration a. Insoection Scoce Conduct a review of the level of management support for the licensee's physical security program, Observations and Findinas The inspectors reviewed various program enhancements made since the last program inspection, which was conducted in March 1996, and discussed them with security management. These enhancements included upgrades to the security
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communications system, e.g., increase in the wattage of the radios to improve l
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clarity and minimize any areas of radio transmission interference, upgrades in the weapons armoty and upgrades to the intrusion detection system to facilitate maintenance. The licensee also issued non-lethai weapons to members of the security force and completed the specifications for a new access control syste The completed specifications for the new access control system were issued to vendors for bidding on March 5,1997, Conclusions Management support for the physical security program was determined to be excellen S7 Quality Assurance in Security and Safeguards Activities S7.1 Effectiveness of Management Controls Insoection Scoce Conduct a review to determine if the licensee has controls for identifying, resolving and preventing programmatic problem Observations and Findinns The inspectors reviewed the licensee's controls for identifying, resolving and preventing security program problems. These controls included the performance of the required annual quality assurance (QA) audits, an ongoing self-assessment program and ongoing security shift supervisor oversight. The licensee was also using industry data, such as violations of regulatory requirements identified by the NRC at other facilities, as a criterion for self-assessmen Conclusions A review of the licensee controls, including results, indicated that performance errors were being minimized and that controls were effectively implemented to identify and resolve potential weaknesse X1 Review of Updated Final Safety Analysis Report (UFSAR)
A recent discovery of a licensee operMing its facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures, and parameters to the UFSAR description. Since the UFSAR does not specifically include security program requirements, the inspector compared licensee activities to the NRC-approved physical security plan, which is the applicable document. While performing the inspection discussed in this report, the inspectors reviewed Section 6.7 of the Plan titled, " Vehicle Access." Based on direct observations, discussions with security supervision and procedural reviews, the inspectors determined that all vehicles were being properly searched prior to
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entry into the PA and controlled while in the PA, as described in the Plan and applicable procedures. However, the inspectors' review of the licensee designated vehicle (LDV) list disclosed 53 vehicles identified as LDVs. Further review disclosed that on March 5,1997, there were 5 LDVs in the protected area,35 LDVs onsite, '
but outside the protected area, and 18 LDVs that could not be locate Additionally, a review of the log for vehicles that entered and exited the protected i area for the 5-day period prior to March 5,1997 disclosed that only between 5 and 10 vehicles on the LDV list actually entered the PA on a daily basis, i i
The licensee's NRC-approved security plan, Section 6.7, Vehicle Access, states, in part, " Licensee designated vehicles... remain in the protected area except for operational, maintenance, repair, security and emergency purposes...After initial entry, these vehicles only leave the protected area for the purpose of servicing, repairs, emergencies, moving supplies from the warehouse or other directly related ,
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The 35 vehicles on the LDV list that were identified onsite, but outside the PA, were in general use and did not leave the PA for the purposes specified in the Plan for LDVs. The failure to control LDVs in accordance with the Plan is a violatio (VIO 50 443/97-02-03)
X.2 Control of Temporary Refueling Outage Facilities a. Scope At various times during the inspection report period, the inspectors toured the protected area to assess the effectiveness of licensee security control of temporary office trailers and equipment staging and storage facilities being brought onsite to support the upcoming refueling cutag b. Observations and Findinas The inspectors observed in detail the installation of several temporary trailers that were brought into the protected area to support switchyard, diesel generator, and primary component cooling water heat exchanger replacement. The temporary facilities were observed to be properly illuminated as required by the security pla c. Conclusions The inspectors concluded that security management established and maintained strong control of temporary facilities. The inspector had no further question V. Manaaement Meetinos X1 Exit Meeting Summary The security inspectors met with the licensee representatives at the conclusion of l the inspection on March 6,1997. The resident inspectors presented the inspection
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i results to members of licensee managernent, following the conclusion of the I
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inspection period, on April 23,1997. The licensee acknowledged the findings !
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The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary inforrnation was
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15 PARTIAL LIST OF PERSONS CONTACTED Licensee W. Diprofio, Unit Director l G. Kline, Technical Support Manager R. White, Design Engineering Manager J. Peterson, Maintenance Manager * l J. Grillo, Oversight Manager B. Seymour, Security Manager *
W. Leland, Chemistry and Health Physics Manager S. Buchwald, QA Supervisor *
A. Callendrella, Licensing Manager *
J. Marchi, Audit Manager *
R. Messina, Security Supervisor * i G. St. Pierre, Operations Manager * '
Contractor C. Goodnow, Chief of Security, Green Mountain Security Services *
NRC Albert W. DeAgazio, Project Manager
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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems
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IP 61726: Surveillance Observation IP 62'707: Maintenance Observation IP 64704: Fire Protection Program IP 71707: Plant Operations IP 71750: Plant Support Activities IP 73051: Inservice Inspection - Review of Program IP 73753: Inservice inspection IP 83729: Occupational Exposure During Extended Outages IP 83750: Occupational Exposure
IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor l Facilities IP 92902: Followup - Engineering IP 92903: Followup - Maintenance IP 93702: Prompt Onsite Responte to Events at Operating Power Reactors i
ITEMS OPENED, CLOSED, AND DISCUSSED t Ooened Unresolved item 50-443/97-02-01, Adequacy of licensee causal analysis, corrective actions, and licensee event report in response to the identification that the main steam line radiation monitors were incorrectly locate Unresolved item 50-443/97-02 02, Determine if appropriate controls were used for the temporary installation of portable heaters in the cooling tower pump roo l Violation 50-443/97-02-03, Failure to control licensee designated vehicles in accordance with security plan requirement !
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i 17 LIST OF ACRONYMS USED
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ACR Adverse Condition Report ASME American Society of Mechanical Engineers CAS Central Alarm Station CBS containment building spray i EDG Emergency Diesel Generator )
EFW Emergency Feedwater FME Foreign Material Exclusion gpd gallons per day !
gpm gallons per minute LCO Limiting Condition for Operation MOV motor operated valve i MPCS Main Plant Computer System 1 NSARC Nuclear Safety and Audit Review Committee l NSARC OS NSARC Operations Subcommittee j psig pounds per square inch gauge !
-QC Quality Control RHR Residual Heat Removal SG steam genera :or ;
SIR Station Inforniation Report l SORC Station Operations Review Committee '
SUFP Startup Feedwater Pump SW Service Water TDEFW Turbine Driven Emegency Feedwater Pump TS Technical Specifications UFSAR Updated Final Safety Analysis Report WR Work Request l
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