IR 05000443/1986009

Insp Rept 50-443/86-09 on 860407-11.No Violation Noted. Major Areas Inspected:General & Sys Operating Procedures & QA Interfaces

ML20198E440
Person / Time
Site:	Seabrook
Issue date:	05/14/1986
From:	Blumberg N, Jerrica Johnson, Denise Wallace NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198E439	List: IR 05000443/1986009 ML20198E433
References
50-443-86-09, 50-443-86-9, NUDOCS 8605280007
Download: ML20198E440 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-09 Docket N License N CPPR-135 Licensee: Public Service of New Hampshire P. O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Station Unit I

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Ins;cection At: Seabrook, New Hampshire Inspection Conducted: April 7-11, 1986 Inspectors: O W 4w I-N-N David Wallace, Reactor Engineer date h y( .5 $~ N

, Norman Blumbj(p, Lead Reacto# Engineer date Approved by: #!

Jon Johnson, Chief, Operational Programs date Section, Operation's Branch, DRS Inspection Summary: Routine, announced inspection conducted on April 7-11, 1986 (Report No. 50-443/86-09).

Areas Inspected: General and system operating procedures and Quality Assurance interfaces. The inspection was performed onsite by two region based inspec-tor Results: No violations were identifie "

8605280007 860516 PDR 0 ADOCK 05000443 PDR

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DETAILS 1.0 Persons Contacted New Hampshire Yankee Personnel Breault, Unit Shift Supervisor, NH Yankee (NHY)

• Grillo, Assistant Operations Manager, NHY

• Guillette, Assistant Construction Quality Assurance (QA)

Manager, NHY Kilby, Unit Shift Supervisor, NHY Kingston, Compliance Manager, NHY

• Lambert, Project Field, Quality Control (QC)

Manager, United Engineers and Constructors Mackensen, Preoperational Test Supervisor, NHY

• Malone, Operations Administration Supervisor, NHY

• March, Startup QC Manager

• Middleton, QA Staff Engineer, Yankee Atomic Energy Company (YAEC)

• Richardson, Training Center Manager, NHY

• Sanchez, Engineer, Licensing, YAEC

• Teffet, Startup Test Department, Project Engineer, NHY US Nuclear Regulatory Commission

• Barkley, Resident Inspector

• Cerne, Senior Resident Inspector

• Holden, Senior Resident Inspector, Maine Yankee

• Ruscitto, Resident Inspector

• Denotes those present at exit meeting conducted on April 11, 198 .0 Operating Procedures 2.1 References / Requirements

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10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants.

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Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation).

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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Seabrook Station, Unit 1, Technical Specifications, DRAFT, March, 1986

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Seabrook Station, Unit 1, Final Safety Analysis Report (FSAR),

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' 3 2.2 Program Review The Seabrook program for preparation of plant operating procedures was reviewed to verify compliance with the requirements referenced in paragraph 2.1, and to determine that Seabrook has established Adminis-trative Controls for:

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Procedure preparation and approvals

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Procedure formats

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Procedure distribution and status control

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Checklist preparation and control

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Program controls for operational surveillance and inservice testing The following program procedures were reviewed:

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Operations Management Manual, Revision 1, February 11, 1986

• Chapter 6 " Orders"

Chapter S " Control of Operator Aids"

OP 9.5, " Alarm Response Guidelines," Revision 0, DRAFT

OP 10.1, " Operation and Control of Locked Valves,"

Revision 0, DRAFT

OP 10.2, " Independent Verification," Revision 0, DRAFT

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Seabrook Station Management Manual, Revision 2, February 5, 1986

• Chapter 5, "SORC"

• Chapter 6, " Master Procedures"

• Appendix C, "SORC Charter"

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Station Test Control Manual, Revision 7, March 28, 1986

Chapter 2, " Program Controls"

Chapter 3, " Inservice Testing and Inspection"

• Appendix C, " Master Surveillance List"

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Computer Control Program Manual, Revision 0, December 24,.1985

Chapter 2, " Computer Control Program Manual"

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Nuclear Production Document Index Reference, Revision 9, March 28, 1986

Chapter 2, " Nuclear Production Manuals Systems"

Chapter 3, " Station Operating Procedures"

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2.3 Implementation Review Selected plant operating procedures were reviewed to determine compli-ance with the requirements referenced in paragraph 2.1 and the admi-nistrative controls detailed in paragraph 2.2. Although most operat-ing procedures have been written, approximately fifty percent had not received their final Station Operations Review Committee (SORC) re-view and station manager approval. For this reason many of the pro-cedures listed below were still in draft form when inspected. Al-though the procedures had not yet received final approval, based on discussions with plant representatives, the inspector determined that procedure development was at a sufficient stage to provide an adequate basis for review. Procedures listed below which have an asterisk were reviewed by a hands-on equipment walk-through with a qualified operator either in the plant or by using the Training Center Control Room Simulator with a simulator instructo Some walk-throughs were accomplished on a sampling basis only. Walk-through inspections included a validation of certain references, pre-requisites, and precautions as well as procedural steps. Procedures were reviewed for the following attributes:

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Proper review and approval

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Correct format

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Conformance to Technical Specifications

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Technical Accuracy

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Inclusion of checkoff lists, where applicable

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Adequacy of prerequisites and precautions

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Stepwise instructions and provision of necessary detail to ensure adequate procedure implementation

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Workability of procedures via system or control room simulator walk-through . .

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The following procedures were reviewed:

Genaral Operating Procedure Note: General Operating Procedure walk-throughs were accom-plished on the Plant Control Room Simulator. These procedure are designated by the asteris *-- OS 1000.02, " Plant Startup From Hot Standby to Minimum Load,"

DRAFT

• -- OS 1000.03, " Plant Shutdown From Minimum Load to Hot Stand-by," DRAFT

• -- OS 1000.05, " Power Increase," DRAFT

• -- OS 1000.07, " Approach to Criticality," DRAFT System Operating Procedures

• -- OS 1005.05, " Safety Injection System Operations," DRAFT

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-- OS 1006.04, " Operation of the Centainment Spray System," DRAFT

-- OS 1008.01, " Chemical and Volume Control System Makeup Operations," DRAFT

• -- OS 1011.01, "NIS Switch Alignment," 0 RAFT

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• -- OS 1026.01, " Operation of D/G 1A," DRAFT, Revision 01

• -- OS 1026.07, " Aligning D/G 1A Controls For Auto Start,"

Revision 0, January 17, 1985

-- OS 1048.01, "125 VDC Vital System Operation," Revision 1, February 27, 1986

• -- OS 1048.02, "125 VDC Battery Charger IA, IB,1C, and 10 Operation," Revision 1, February 27, 1986 Note: The following procedures were reviewed for format onl OS 1013.03, " Residual Heat Removal Train A Startup and Operation," DRAFT

-- OS 1002.02, " Operating of Letdown, Charging and Seal Injection,"'

DRAFT

-- OS 1026.08, "D/G 1A Maintenance Testing," Revision 1, February 27, 1986

-- OS 1036.01, " Aligning the Emergency Feedwater System for Automatic Initiation," DRAFT-

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2.3 Findings 2.3.1 The inspector observed that alarm response procedure (approxi-mately 2450) were in the process of being written. These pro-cedures are to be placed on the Computer Video Access Terminal (VAS) and hard copies (printed from the computer) of-the alarm response procedures are to be maintained in the control roo At the time of this inspection these procedures were not ready for NRC review.

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Licensee representatives stated that there were no plans to have

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the alarm response procedures reviewed by the SORC or approved by the station manager. The inspector informed the licensee that certain safety related alarms were governed by the proce-dure controls specified in Technical Specification (T.S.) 6.7, and Regulatory Guide (R.G.) 1.33, and required the same safety reviews and approvals as other procedures. The licensee stated'

that an evaluation would be made as to which alarms are consi-dered " safety related" and that alarm response procedures for those alarms would receive a SORC review and Station Manager approval. This item is to be completed prior to plant startup and is unresolved pending completion of licensee actions (50-443/86-09-01).

2.3.2 The licensee has not yet written (shift and daily) logs which will be used to verify short interval T.S. surveillance require-ments. Discussions with licensee representatives indicated that they did not consider the logs to be procedures and that there were no plans for SORC review and Station Manager approval. The inspector informed the licensee that R.G.1.33 required that all T.S. surveillance requirements be performed and verified by ap-proved procedures. The licensee stated that a mechanism would be established to assure that T.S. logs will be properly review-ed and approved prior to plant startup. This item is unresolved pending completion of licensee action (50-443/86-09-02).

2.3.3 Plant walk-through inspections were conducted by the inspector accompanied by a qualified plant operator. The inspections in-cluded Alignment Of The Nuclear Instrumentation System (0S 1011.01), Operation of 125 VDC Battery Charger System (OS 1048.02), and Operation Of The (intermediate) Safety Injection System (OS 1005.05). In addition, the inspector accompanied by a training instructor performed walk-through inspections at the control room simulator of certain general operating procedure These procedures included Plant Startus (OS 1000.02), Plant Shut-down (OS 1000.03), Power Increase (OS 1000.05), and Approach To Criticality (OS 1000.07).

During the above inspections, on a samplina basis, procedure references, precautions, limitations and setpoints, prerequi-sites, valve line-ups, and operations were verifie '

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2.3.3.1 Plant Walk-throughs 2.3.3. During inspection of the NIS alignment procedure (OS 1011.01) the inspector observed the following deficiencies:

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The drawing referenced for NIS Control Power was incorrect as specified in Appendix A of the pro-cedure, in that M-310016 was referenced vice M-31010 In the section entitled " Audio Count Rate Drawer Switch Alignment" step 9, the Scaler Power Toggle Switch is to be verified "0N", but the switch has no ON/0FF labe .3.3. The following deficiencies were observed during inspection of the 125 VDC battery charger procedure (OS 1048.02).

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United Engineers and Constructors drawing F-310041, Rev)sion 5, has a handwritten change on what was charger BC-1C. The print now reads BC-1B which appears to be correct, but because of the hand-written change the inspector questioned the accu-racy of other prints in us Step 6.1.4 of the procedure calls for a 30 VDC-output from the charger. After consulting the appropriate Technical Manual, the inspector determined 30 VDC to be incorrect and that 130 VDC was the correct voltage.

2.3.3. The safety injection (SI) procedure (0S 1005.05)

included instructions for starting and stopping safety injection pumps, changing accumulator water level, and venting or draining accumula-tors. During this review the following defi-ciencies were observed:

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Step 4.8 of the " Limitations and Setpoints" section specified a temperature band for the Refueling Water Storage Tank (RWST) of 40 F to 88 F. This is in accordance with the require-ments of T.S. 3.5.4 which call for a temperature band between 40 F and 100 F, but is in conflict with the requirements specified in T.S. 3.1. which call for a temperature band of 50 F to .<

86*F. Both Technical Specifications, 3.1. i

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(Operating Borated Water Source) and 3.5.'4 (Emergency Core Cooling System RWST) are appli-cable to the SI system operation procedure, but do not agree in regards to the temperature band requirements. In addition, step 4.8 does not specify a minimum volume requirement for the RWST prior to operation of the SI syste Step 6.1.1 of the " Procedure" section requires the RWST level to be greater than 114,000 gallons if the RWST is to be the suction for the SI pumps, but T.S. 3.1.2.6 (Operating Borated Water Source) requires an RWST level of 24,500 gallons for modes 5 and 6 operation, and 479.000 gallons for modes 1 through 4 operation. In addition, the prints of the RWST show its capacity as less than 479,000 gallons, the required volume for modes 1-4 operatio The caution statement on page 5 of the procedure which reads " Ensure Minimum Pump flow whenever pump is started or capable of cold start", is unclear in its instruction Step 6.7.6 of the "0 raining Accumulator (s)"

section of the procedure gives instructions to

" vent accumulator with following valves:

Accumulator 9A, SI-FV-2475 and FV-2476

. Accumulator 98, SI-FV-2482, etc. . . ."

This step does not clearly state the position of the vent valves after initial venting. If the vent valves are closed, the accumulators may not drain properl The " Note" on page 12 of the procedure which reads " Leave RCDT control switch in start" is unclear as written, and could be better under-stood if a specific switch was reference Appendix A of the procedure is a " Safety Injec-tion System Line-up," but this Appendix is not referenced in the procedure and is not required to be performed by the procedur The deficiencies identified in 2.3.3.1.1, 2.3.3. and 2.3.3.1.3 above collectively constitute an unresolved item (50-443/86-09-03). This unre-solved item involves potential corrections to procedures, drawings, plant equipment, and/or the Technical Specifications as applicabl .-

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2.3. Simulator Walk-through During walk-throughs of the general operating procedures, the following discrepancies were observed:

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Procedure OS 1000.02, step 7.1.7 (which is performed with the reactor at 2% power during plant heatup) states

" complete the Technical Specification Mode Change Check List for Mode 1, and obtain USS/SS permission to change from Mode 2 to Mode 1." Since, during a normal startup, changes to Mode I would be expected, the inspector noted that performing the mode change checklist at this step might be inappropriate and this step should be considered as a prerequisite to the procedure. The licensee stated that the location of this step in the procedure would be evaluate Procedure 1000.03, paragraph 10.0 identifies forms to be added to the procedure "later"; however, no forms are identifie Procedure OS 1000.07, " Approach to Criticality," pre-requisite paragraph 5.2, states " Technical Specifica-tion mode change check list for Mode 2 operation is complete." The inspector noted that the existing mode change checklists appeared to be obsolete and were un-approved procedures. The licensee stated that the checklists were currently under review and would be issued with appropriate review and approval OS 1000.07, step 6.2, states "As a minimum, the reactor trip system instrumentation channels and interlocks of

[T.S Table] 3.3-1 shall be operable with response times as shown in [T.S. Table] 3.3-2." However, no checklist was available to assure this would be correctly verifie The licensee stated that a mechanism was being developed to ensure that applicable T.S. surveillances had been accomplishe OS 1000.07, initial condition step 6.7 states "Pressur-izer level is being controlled in the normal operating range, 25%." However, no range is given for the operato OS 1000.07, procedure step 7.2, states "If desired, commence a 1/M plot..." The inspector questioned the licensee as to whether a 1/M plot should be optional ;

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The deficiencies identified in paragraph 2.3. collectively constitute an unresolved item (50-443/86-09-04).

2.3.4 The " limitations" or " prerequisite" sections of many procedures include references to applicable sections of the Technical Speci-fication (T.S.). These references sometimes only give a section number or section number and title. The inspector in-formed the licensee that this mechanism of referencing the may be inadequate in that it did not give adequate information to the personnel performing the procedure as to the actual ob-

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jective of the limitation or precaution. While it may not be necessary (or desirable) to transfer the complete T.S. require-

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ment to the procedure, the desired objective of the T.S. should be stated. This deficiency was noted in the following system operating procedures:

05 1005.05 OS 1026.07 OS 1013.03 05 1006.04 OS 1011.01 OS 1002.02 OS 1008.01 OS 1048.01 05 1026.08 OS 1026.01 OS 1048.02 OS 1036.01 In contrast, the general operating procedures indicated adequate reference to T.S. requirements. The licensee stated that proce-dures identified in this inspection would be revised to correct

the above deficiency before reactor startup. In addition, a pro-gram would be established to correct similar deficiencies in other operating procedures within nine months of this inspectio This item is unresolved pending completion of licensee action (50-443/86-09-05).

2.3.5 Certain procedure prerequisites refer to electrical or mechanical system alignments which are referenced by other systems' operat-ing procedures. In some instances the prerequisite did not re-fer to the procedure which would have performed the actual align-ment. The inspector informed the licensee that the prerequisite steps should refer to specific procedures which should have been performed to implement the prerequisite. This discrepancy was observed in the following procedures and is applicable to both l electrical and valve alignments:

OS 1006.04, Paragraph 5. OS 1002.02, Paragraph 5.1.7

. OS 1026.01, Paragraph '

OS 1026.07, Pargaph 5.6, 5.7, and OS 1026.08, Paragraph OS 1036.02, Paragraph OS 1036.01, Paragraph OS 1048.01, Paragraph . _ - - - . _ _

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The inspectors noted that most prerequisite paragraphs reviewed during this inspection make the correct reference to other procedure The licensee stated that those procedures identified during this inspection would be corrected. In addition, a program would be established to correct remaining procedures within nine months of this inspection. This item is unresolved pending completion of license action (50-443/86-09-06).

2.3.6 Procedure OP 10.2 has been written in draft form and specifies those systems whose valve lineups require independent verifi-cation. In reviewing procedures for the core spray and safety injection systems, the inspector observed that the valve lineups in these procedures had not been designated for independent verificatio The licensee stated that they were aware of this problem and that procedure valve lineups for safety systems identified in OP 10.2 as needing independent verification would be revised prior to plant startup to assure that independent verification is specified on the lineup. This item is unre-solved pending licensee corrective action (50-443/86-09-07).

3.0 Quality Assurance Interfaces The station operating procedure cover sheet specifies a quality assurance (QA) review. Quality Assurance must review those procedures related to plant safety. All issued procedures which were reviewed during this inspection had received a QA review. In addition, the licensee provided documentation that most other operating procedures were currently receiv-ing or were designated to receive a QA review. The inspector had no further questions at this tim .0 Independent Inspector Verifications On a sampling basis, the inspector performed independent verification of valve lineups, switch alignments, and expected procedure parameters via independent walk-throughs on actual plant equipment or at the control room simulator. This scope includes procedures identified above in para-graph >

i 5.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance interview conducted on April 7, 198 The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on April 11, l 1986 (see paragraph 1 for attendees) at which time the findings of the in- 1 spection were presente '

At no time during this inspection was written material provided to the licensee by the inspectors.