ML20206A104

New Hampshire Yankee Salf Assessment Team 1988 Phase 1 Rept

ML20206A104
Person / Time
Site:	Seabrook
Issue date:	11/04/1988
From:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20206A091	List: ML20206A089 ML20206A104
References
NYN-88146, NUDOCS 8811140417
Download: ML20206A104 (33)

Text

9. .

Enclosure to NYN-88146 NEW HAMPSHIRE YANKEE SELF ASSESSMENT TEAM 1988 PHASE 1 REPORT November 4, 1988 l

l 8911140417 SG1104 PDR ACOCK 0S000443 P s s PDC

Phase 1 Report Table of Contents 1.0 Executive Summary 2.0 Areas o' Evaluation 21 -

desponse To NRC Inspection Items 2.2 --

Generic Correspondence 2.3 --

10 CFR $0.55(e) Reports 2.4 --

10 CFR 21 Reports 2.5 --

Construction Punchlist Items 2.6 --

Testing 2.7 --

Quality Assurance 2.8 --

Engineering and Technical Support 2.9 --

Maintenance and Work Control 2.10 -- Operations 2.11 -- Health Physics and Chemistry 2.12 -- Emergency Preparedness 2.13 -- Management Effectiveness 2.14 -- Security 3.0 Recommendation Index

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1.0 EXECUTIVE

SUMMARY

The purpose of the self assessment is to evaluate the preparation for and the conduct of activities aesociated with the Seabrook Station low power testing evolution in order to assess the operational readiness and effectiveness of per-sonnel, programs, and equipment and to identify areas requiring immediate or long tera management attention.

The low power testing evolution self assessment is being conducted in two phases. This report covers the first phase and provides an assessment of Seabrook StatioT's overall operational readiness to conduct loc power testing activities. Thi; report specifically addresses the following fourteen topics:

1. Responses to NRC Inspection Items

2. Responses to Geaaric Correspondence

3. 10 CFR 50.3)(e) Reports

4. 10 CFR 21 Reports

5. Construction Punchlist Items

6. Startup Testing

7. Quality Assurance

8. Engineering and Technical Support

9. Maintenance and Work Control

10. Operations

11. Health Physics and Chemistry

12. Management Effectiveness

13. Emergency Preparedness

14. Security In order to provide a documented basis for any subsequent conclusions, the Self Assessment Team (SAT) first established performance objectives and detailed criteria to evaluate and analyze each of the topica'l areas. The performance objectives and criteria have been and will continue to be maintained in a con-trolled distribution document.

The SAT personne1 consist of sixteen NHY senior management or staff personnel and one contracted individual representing all of the major functional discipline areas. Personnel assigned to the team have, at a minimum, experience in opera-tions, maintenance, chemistry, health physics, engineering, training, startup or quality assurance. The SAT was organized into three general discipline areas that report to an overall SAT Manager. The SAT, in turn, *eports to a NHY Management Oversight Committee on a periodic basis. The Management Oversight Committee consists of the President and Chief Executive Officer, the Vice President - Nuclear Production, the Vice President - Engineering, Licensing and Quality Programs and the Station Manager.

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1.0 EXECUTIVE

SUMMARY

(Continued)

Between September 22 and October 28, 1988, the SAT expended approximately 2200 manhours in conducting the Phase 1 Assessment and generated a total of ninety (90) recommendations. The SAT recommended that NHY consider forty-one (41) of these recommendations for their applicability to low power testing and operational readiness. The remaining forty-nine (49) recommendations were considered to be enhancements to existing programs, procedures and management controls that may be accomplished on a longer term basis. NHY has completed an evaluation of the forty-one (41) recommendations. The resulting actions, that apply to low power testing or operational readiness, have either been completed or are being tracked as restrictions to mode changes on existing NHY tracking systems. To prevent any confusion or redundancy to standard tracking systems, these are the same systems (Plan-Of-The-Day Schedule, Integrated Commitment Tracking System, Mode Change Checklist) that are used to track items such as work requests, surveillances, and regulatory cor.mitments.

The already commenced Phase 2 self assessment ef fort will in.lude monitoring the completion status of these, and other mode restricting activities, as part of a verbal recommendation to the Management Oversight Committee on criticality readiness. In addition, the second phase of the self assessment involves a comprehensive, detailed, self evaluation of NHY's conduct in specific topical areas. These areas include:

1. Operations

2. Maintenance and Work Control

3. Testing and Surveillance

4. Health Physics and Chemistry

5. Security

6. Training

7. Assurance of Quality

8. Engineering and Technical Support

9. Management Effectiveness Within the above topical areas, the self assessment effort will focus on the following organizational conduct and activities as well as specific design features tested during the low power testing evolutions.

1. Organizational Interfaces and Management Effectiveness

2. Plant Configuration Control

3. Program and Procedural Adequacy and Compliance

4. Communications and Teamwork

5. Operational Quality Assurance Effectiveness

6. Timeliness and Adequacy of Support of Station Activities

7. Training Program Adequacy and Effectiveness

1.0 EXECUTIVE

SUMMARY

(Continued)

8. Timeliness and Adequacy of Corrective Action Reporting and Follow-Through

9. Adequacy of Design Based on Low Power Test Program Specific Tests The Self Assessment Team's Overall Phase 1 evaluation concludes that:

• Open items are documented, prioritized by milestone or mode restriction, assigned responsibility for completion and are controlled in a manner which will ensure their completion prior to declaring readiness to progress to the next scheduled milestone or mode of plant operation.

• Based on the tasks remaining to be accomplished, Seabrook Station will be operational'.y ready to commence heatup by mid November and to start low power testing by the end of November.

• NHY has conducted prepa.atuty activities in an intentionally conservative and thorougn manner.

• Operations oriented management controls and programs have been implemented, improved upon, and effectively demonstrated over the past twenty-four (24) months since the Zero Power License was issued.

The physical plant condition has been brought to a good state of readiness through repeated surveillance tests and preventive maintenance activities.

• The Operations and Startup Groups are properly focused on plant operation  !

and test evolutions.

The various support groups have well matured programs and detailed implemen-tation procedures plans in effect for normal and unexpected events.

• Management presence and involvement is evident in the preparatory and self assessment response activities.

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2.0 AREAS OF EVALUATION 2.1 Evaluation Of Responses To NRC Inspectior, items Purpose To evaluate the New Hampshire Yankee (NHY) management controls, timeliness, and adequacy of actions taken in responding to NRC Inspection Activities.

Additionally, to evaluate the status of outstanding and in progress inspec-tion related action items for their impact on operational readiness.

Summary Of Findings 3 - Low Power SAT Recommendations 3 - Long Term SAT Recommendations The Regulatory services Department is the primary NHY group responsible for coordinating and tracking NHY responses to NRC inspection related activities.

Under Regulatory Services coordination, NHY has recently completed an inter-disciplinary review of each open inspection item for applicability to opera-tional readiness. Effective October 25, 1988, NHY had 7 open NRC inspection items which must be completed prior to or as part of the Low Power Test Program and 18 items which are required to be complete prior to a Full Power License. Each of these items is assigned to the Plan-Of-The-Day (P0D)

Schedule, assigned a completion tied to a mode change and statused, as appropriate, on a daily basis in the POD Meeting. NHY also has 11 other open NRC inspection related items which have been committed for completion on a longer term basis, i.e. first refueling outage. To be conservative, NHY has conducted an additional review of these items to ensure that the assigned priorities and scheduled completion dates continue to be appropriate.

NHY periodically briefs the NRC on upcoming events.

The SAT made five recommendations in this area of evaluation. Three of the recom-andations (1001, 1002, 1003), which are applicable to low power testing, will be completed per the established POD Schedule. The remaining recommendations (1004, 1005, 1069), will provide enhancements to existing practices and have been scheduled for completion.

Conclusion NHY has an effective and positive set of controls to track and status the NHY actions associated with NRC inspection activities. Furthermore, the existing controls will assure that the completion of NHY activities, for low power associated NRC inspection items, will occur on a schedule consistent with low power testing prerequisite conditions.

l 2.2 Evalunt_fon Of Generic Correspondenco Purpose To evaluate the NHY management controls, timeliness and adequacy of actions taken in responding to NRC Inspection and Enforcement (I&E) Bulletins, Circulars, Notices and Letters. Additionally, to evaluate the status of outstanding and in progress I&E action items for their impact on operational readiness.

Summary Of Findings 0 - Low Power SAT Recommendations 18 - Long Term SAT Recommendations The Regulatory Services Department u. the primary NHY group responsible for coordinating and tracking NHY generic correspondence activities. The SAT conducted a 100% review of the NRC generic correspondence, including the status of all NRC Bulletins issued in 1988, and found that three of the g-neric correspondence open action items require further action prior to the conduct of low power testing. These items are tracked as NRC inspection iteins requiring completion prior to heatup. (See Evaluation Section 2.1 of this report.) The SAT made 18 long term recommendations (1006 - 1016 and 1070 - 1076) which will provide program and documentation enhancements.

Conclusion The self assessment concluded that NHY has adequately responded to each generic correspondence action item that applies to low power testing. The implementation of the SAT identified long term recommendations will provide additional programmatic and documentation enhancements.

2.3 Evaluation Of 10 CFR 50.55(e) Reports Purpose To evaluate the adequacy and completion of activities associated with 10 CFR 50.55(e) identified construction deficiencies.

Summary Of Findings 0 - Low Power SAT Recommendations 6 - Long Term SAT Recommendations The Regulatory Services Department is the primary NHY group respontible for

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2.3* Eva'luation Of 10 CFR 50.55(e) Reports (Continued)

Summary Of Findings (Continued) coordinating the completion and tracking of 10 CFR 50.55(e) reports. Of a total of one hundred and six (106) 10 CFR 50.55(e) reports only three remained open at the outset of the self assessment activities and were being tracked as open NRC inspection items (See Evaluation Section 2.1 of this report). The actions for two of these 10 CFR 50.55(e) deficiencies have been completed. (Replacement of Veritrak/Tobar transmitters with Rosemount transmitters and the hydrogen analyzer control cable.) The remaining open item requires the completion of a mode restricted confirmatory test of the turbine driven emergency feedwater pump. This test is listed on the POD Schedule with appropriate mode restriction and will be conducted as part of the overall low power startup test program. This item is tracked as an NRC inspection activity requiring completion prior to Mode 2. (See Evaluation Section 2.1 of this report.) The SAT conducted a 100% review of the (106) 10 CFR 50.55(e) reports generated daring the history of Seabrook Station and concurs with the NHY documented status of the 50.55(e) deficiency reports.

The SAT made 6 long term recommendations (1066, 1077 - 1051) which provide programmatic cnhancements.

Conclusion The self assessment evaluation of 10 CFR 50.55(e) deficiencies concluded that NHY has taken positive measures to complete the corrective action commitments.

The one remaining open activity will be completed during plant heatup prior to low power criticality testing.

2.4 Evaluation of 10 CFR 21 Reports Purpose To evaluate the NHY programmatic controls, adequacy, and timeliness of actions taken in responding to or initiating 10 CFR 21 reports. Additionally, to evaluate the status of current responses and the status of any remaining completion activities for their impact on operational readiness.

Summary Of Findings 2 - Low Power SAT Recommendations 8 - Long Term SAT Recommendations The Regulatory Services Department is the primary NHY group responsible f r administering and coordinating the erogrammatic aspects of 10 CFR 2' relat d 2.4 Evoluetion Of 10 CFR 21 Reports (Continued)

Summary Of Findings (Continued) activities. NHY Engineering performs the evaluation for determining the reportability of potential 10 CFR 21 reports and other NHY departments participate in the resolutions of 10 CFR 21 reports.

NHY evaluated two issues (1083, 1086) for 10 CFR 21 reportability during the self assessment period. These issues involved damaged turning vanes in safety related HVAC ducting and defects in soldered connections for the post accident (Cammametries) neutron monitoring system cables which are required for Mode 3, and above operation. Positive actions were taken to correct both issues. The scheduled installation of the manufacturer modified cables and the repair and/or surveillance of the turning vanes are tracked on the POD Schedule. The SAT recommended completing the reportability determinations and requisite actions on these two potential 10 CFR 21 issues prior to commencing low power testing.

NHY has evaluated 22 internal potential 10 CFR 21 conditions for report-ability since receiving a zero power license. Two of these have resulted in determinations that initiated 10 CFR 21 reports (personnel hatch linkage arid inappropriate application of SW-V-15 valve seat material). The actions associated with closing both items have been completed.

In this area of evaluation, the SAT recommended eight actions (1082, 1084, 1085, 1088 - 1092) for long term improvement in programmatic controls and document file maintenance.

Conclusion NHY has an effective program to identify, evaluate, report and correct poten-tial or known 10 CFR 21 items. These controls will ensure resolution of tne two SAT recommendations (turning vanes and Cammametrics) per the committed POD schedule and mode change restriction.

2.5 Evaluation Of Construction Punchlist Items Purpose To evaluate the status of remaining incomplete construction activities and their impact on operational readiness.

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2. 5' Ev$luatien Of Construction Punchlist Ite s (Continued) ,

Summary Of Findings 0 - Low Power SAT Recommendations 1 - Long Term SAT Recommendation NHY evaluated each outstanding, incomplete, or otherwise open construction activity for applicability to low power testing and for potential restrie-tion (s) to mode changes. Each such open item has been closed out based upon  ;

activity completion er has been transferred from the construction tracking system to the appropriate NHY program and tracking system. Although no construction punchlist items will restrain low power testing, applicable ,

assignments have been identified and will be statused in the POD meetings.

These actions implement the one long term SAT recommendation (1017) in this  ;

area of evaluation.

Conclusion l

F"" i taking the appropriate actions to evaluate and control incomplete and uccesolved construction activities, assess their impact on low power testing, and to track their completion status commensurate with low power testing pre-requisites.

2.6 Evstuation Of Testing Purpose To evaluate the readiness of the NHY Startup Test Program, organization, personnel, procedures, and equipment to conduct the identified low power testing activities.

Summary Of Findings, i 5 - Low Power SAT Recommendations 0 - Long Term SAT Recommendations a

To conduct the low power testing schedule of activities, NHY has reconsti-tuted the Startup Test Department with a direct reporting line to the Station Manager. The department is staffed with key personnel retained from the group that conducted startup activities prior to and during 1986. The Startup a Test Department is well integrated with the station operating departments.

In addition to these departments, Yankee Atomic Electric Company (YAEC),

Westinghouse (NSSS Vendor), and SORC have all reviewed and approved the Startup Program and Procedures. The Startup Program and Procedures have 2.6 Evaluntion Of Tasting (Continued)

Summary Of Findings (Continued) been 50.59 reviewed and any changes to these procedures will go through the current :n CFR 50.59 and SORC review process prior to approval for use.

Startup pert ; ' .nel are adequately trained and qualified to perform their assigned responsibilities. The Startup Test Department has provided low power test program training for the appropriate NHY support personnel.

Spesi:) test equipment has been calibrated and tested for operability.

The results of the preoperational testing program that have been completed through 1986, have been fully reviewed. The open items associated with that review have been completed. The twenty-seven (27) items remaining from the startup incomplete items list were reviewed and assigned to specific modes ,

for completion. The solid waste system is the only system tSat has not ,

completed acceptance testing. Portions of the system are functional and the remainder (asphalt) is scheduled for testing in 1989. The system is not i

required to support low power testing, i 4

Each startup test has pre-established acceptance criteria. A SAT recommen-dation (1018) regarding the basis for acceptance criteria in several test procedures was quickly resolved. The SAT recommended (1019) the reinstitu-tion of an integrated mode change checklist. This recommendation has been incorporated in existing NHY programs. Existing mode change restricting action lists will be incorporated on the checklists. The SAT has recommended j (1020) that the startup organization consider using the existing NHY Records

] Management Program and Procedures tor controlled records distribution. The Manageme.1t Oversight Committee specifically reviewed a SAT recommendation

} (1034) regarding the applicability of 50.59 re-reviews for startup procedures, i i The Management Oversight Committee determined that the recommenfation was not t

) necessary based upon prior, valid multi-organizational reviews (SORC, ,

1 Operations, Startup, YAEC, Westinghouse, NRC) and the fact thit the original l design parameters had not changed. Completion of the Low Power Test Program  !

training sessions (1035) conducted for the appropriate NHY support personnel will complete the actions .isociated with these five SAT recommendations.

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Conclusion L

NHY has developed, reviewed, and approved a comprehensive, detailed, low i power test program that will accomplish the FSAR committed startup testing I elements of this evolution in a conserystive and carefully deliberated i manner.

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2.I Evnlu6 tion of Quality Assurance Purpose To evaluate the measures taken to ensure that independent and anpropriately i rigorous quality assessments of operational readiness preparations and con-duct of low power testing activities occurs.

Summary Of Findings 2 - Low Power SAT Recommendations 0 - Long Term SAT Recommendations During the self assessment period the Nuclear Quality Group tock positive steps to correct perceived weaknesses in terms of operational experience and startup testing technical expertis;. Yankee Atomic Electric Company has provided personnel to supplement the Nuclear Quality Group for independently t assessing the specific quality control responsibilities and activities during the low power test programs. Nuclear Quality Group personnel have also received specific low power technical training through the Training Group.

The SAT recommended completion of these two activities (1021, 1022) prior to beginning the low power t> sting evolution. As of October 20, 1988, the i Nuclear Quality Group had completed the activities associated with these two  !

recommendations.

Conclusion i i

The Nuclear Quality Group can adequately assess and apply the Operational '

Quality Assurance Prsgram 011ments to the low power test program.  !

2.8 Evaluation Of Engit e_ering And Technical Support l

Purpose To asssss the adequacy of the design, engineering and technical support reviews and evaluations and preparatory activities ennducted in support of operational readiness.

Summary of Findings 6 - Low Power SAT Recommendations 4 - Long Term SAT Recommendations The Engineering and Technical Support Groups have reviewed deferred design changes, technical clarification / interpretation requests, NCR's, approved but 2.8' Evaluation Of EngfToering And Technical Support (Continued)

Summary Of Findings (Continued) not yet installed design changes, temporary modifications, corrective action requests, Station Information Reports, spare parts, and vendor correspondence for applicability to low power testing and mode restrictions. The activities associated with the 6 low power SAT recommendations (1023 - 1027, 1030) in these areas of es$1uation have been completed or are listed on the POD schedule for completion. The SAT has recommended four (1028, 1029, IC59, 1067) programmatic enhancements for longer term action. Technical Support and Engineering have also performed specific analyses and evaluations for the Emergency Feedwater (EFW) System, Containment Building Spray System, Coatrol Building Air Handling System, and the Service Water System. With the excep-tion of the turbine driven EFW pump test, (See Evaluation Section 2.3 of this report) these systems pose no restrictions on operational readiness to con-duct low power testing. The desian and modification control programs have been in use for acproxim .ly twe fears. These programmatic controls are well natured, understood pre med and effective. Engineering and Technical Support have assessed the ads .cy of their resources to support the low power test program. Technical Support is the NHY group with primary responsibility for administering 'he Surveillance Program. This program has appropriate controls and tracking mechanisms and is sffectively implemented and executed.

Technics 1 Support has conducted evaluations of these plant systems that were ,

put into ext .aded lavup. These evaluations have indicated no deleterious effect on plant systems. These evaluations have also provided enhancemants in the procedures and the methods to be used for any future extended layup.

Conclusion Ine design changes required to support low power testing have been approved, are keyed to the mode restricted POD schedule, and are statused in POD -

meetings. Engineering and Technical Support are supporting the completion of thewe activities and are prepared to support low power testing.

t 2.9 Evaluation of Maintenance And Work Control Purpose To evaluate the material cor ition of the plant and the operational readiness of the maintenance and work control programs.

2.9 Evaluation Of M11nten nee And Werk Control

, (Cont!nued)

Summary Of Findi.igs 2 - Low Power SAT Recommendations 1 - Long Term SAT Recomrendation The NHY Maintenance Group has recently completed the corrective actions that resulted from a 1987 self initiated and internally conducted assessment of tne maintenance and work control systems. An effective and integrated work control tracking system is used throughout the station. It includes priority assignments and mode relationships for preventative and corrective maintenance activities.

The Maintenance Group has simulated work activities (e.g. RHW pump repair) under Radiation Work Permit and radiological control conditions.

NHY is establishing the RCA on November 7, 1988 to further train and practice good ALARA and radiological work practices prior to initial etiticality.

Maintenance Croup support activities for low power testing have been identi-fled and scheduled on the P0D Schedule. Adequate resources (personnel, spare parts and approved procedures) are in placn to support planned test evolutions and maintenance activities. The work request pre planning and closeout processes ensure that appropriate departments are involved in maintenance activities.

In respon=e to a SAT low power testing recommendation (1031),

the Maintenance and Operations Groups are developing a control board deft-ciency tagging system, which is applicable throughout the station. The SAf evaluated the work planning process and recommended a long term (1032) ano a low power (1033) improvement. Maintenance Group support activities for plant operation are identified through the existing satisfactory control systems. Qualified personnel, procedures, equipment, and spare parts are available to support pla

• operations.

Conclusion The Maintenance Group and the Maintenance and Work Control Programs are adequately prepared to support plant operation and low power testing.

2.10 Evaluation Of Operations Purpose To evaluate the adequacy of Operations Group programs and procedures, their participation in the Startup Test Program preparations. and the plant con-figuration contre'.s. '

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1 2.1'O EvElua t ie n ,0i_0ms tiou (Continued)

Summary Of Findings 14 - Low Power SAT Recoccondations 6 - Long Term SAT Pocommendations The Operations Group has been and continues to be an active leader in the appropriate areas of preparatory activities far low power testing. These activities has.: been concentrated on the Low Power Testing Program controls and organisational interfaces and the associated procedures. Operations personnel readiness has focused specifically on the low power testing evolu-tions and the overall readiness for plant operation. The SAT evaluated procedural compliance including the effectiveness ol the tagging and tem-porary modification and setpoint controls; the conduct of plant operations including shift turnover Operations orders and logkeeping; Control Room activities including adminiss.ac.ve duties; refresher training specifically focused on low pc.er testing; the mode change criteria, control, review and approval process; and the implementation and effectiveness of plant config-uration controls. The Operations Group resolved or completed all activities associated with the SAT low power recommendations (1036, 1037, 1039, 1040, 1042, 1044 - 1049, 1053 - 1055) by either completing activities already in progress during the self assessment, caheaeing the existing programs and practices or by scheduling activities for cocplet ion en the POD Schedule er ICTS with the appropriate mode restriction. Examples of Operations Grcup responses include the addition of an extra Unit Shift Supervisor on each day shift (Monday through Saturday) during low power testing dedicated to administrative activities such as tagging orders and work requests, auxiliary operator shift turnover at watch stations, reinstituting the mode change checklist and recent oper1tions personnel refresher training on reactivity incidents. The SAT also recommended 6 (1038, 1041, 1043, 1050 - 1052) longer term improvements for consideration.

i conclusion Operations programs, procedures and controls are effectively implemented and Operations personnel are prepared for the safe and reliable conduct of f routine plant operations as well as the low power testing activities.

I 2.11 Evaluation of Health Physics And Chemistry l

l Purpose To evaluate the operational readiness of Health Physics and Chemistry personnel, procedures, equipment and eaterial for low power test ing.

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2.11 Ev lue: tion Of un31th Physics And Chenistry (Coqtinued) l l

l Summary of FindJtys, 3 - Low Power chi Meconmendations 1 - Long T4.m SAT kecoamondations The Health Physics De>artment supervision, professional staff, and technician araff aro Ltained and qualified to perform their assigned responsibilities.

The Health Physics Department is alen in the process of training and qualify-ing twenty-five (25? contracted services Health Physics technicians and four (4) Ho41th Ehysica fecords technicians to augment permanent staff in support of the low power testing evolution. Chemistry Department supervision, professious! staff and technician staff ara also trained and qualified. The augmented staff, is sufficient to support plant operation. The Chemistry Department procedures and lab equipment have been operational since 1982 in eupport of Stnetup Test Department needs. The Chemistry Preventsve Malatenance Program and Laboratory Quality Control Programs are effectively impiccanted. Plant monitoring equipment and procedures are in place for Health Physics and Chemistry.

The planned implementation of the RCA on Novembec /, 1988 will provide adequate lead time to ensure that plant personnel demonstrate good ALARA and radiological work practices prior to initial criticality. The Station Utility Department is completing a scheduled, pre-RCA establishment, plant cleanup that is removing non-essential materials from the RCA.

Plans and procedures for processing and shipping radioactive vaste are complete with the exception of completing the radioactive waste shipping pro-cedure. This procedure (1058) is scheduled for issue in the fourth quarter of 1988. The vaste processing system is functional with the exception of completing the startup testing for the asphalt portion of the system. These scheduled and in progress activities are not restrictions to operational readiness or low power testing.

Health Physics and Chemistry Department personnel are cognigant of the low power test evolutions involving their departments. The actions required to close the SAT low power recommendations (1056, 1057, 1087) have been completed or listed on the POD Schedule for completion with the appropriate mode restriction.

Conclusion The NHY Health Physics and Chemistry Departments are prepared to support low power testing. They are adequately staffed, trained, and qualified and the

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2'.11 Evnluntion Of Henith Physics And Chc71stry (Continued)

Conclusion (Continued) procedures, equipment and materials are effectively implemented. The RCA a vill be implemented three or more weeks in advance of actual need and SAT Phase 2 will continue to evaluate RCA implementation effectiveness.

2.12 Evaluation Of Emergency Preparedness Purpose

. To evaluate the management controls and adequacy of Emergency Preparedness implementation actions to support the change of license and the low power testing evolution.

Summary Of Findings 2 - Low Power SAT Recommendations 0 - Long Term SAT Recommendations The Emergency Preparedness (EP) Group is in the process of integrating several internal commitment and action item tracking systems and completing detailed activity schedules for deferred post exercise and exercise generated action items.

Upon establishing these improved administrative controls, EP will issue integrated intra and inter-organization schedules, action item tracking and commitment lists. NHY inter-organization action items will be placed on the NHY Integrated Commitment Tracking System (ICTS).

> The SAT recommended (1061) that EP conduct an evaluation of emergency prepar-edness commitments and procedures for their impact on operational readiness l for low power testing. This recommendation also suggested an evaluation of 4

the existing organizational clarity for personnel expected to respond should the emergency response organizations be activated. This evaluation and the requisite actions were initiated during the assessment period and will be tracked on ICTS for completion prior to the appropriate mode restriction.

The SAT also recommended (1060) that EP conduct an evaluation of regulatory, licensing and internal commitments to verify that the commitments are reflected in current emergency preparedness procedures. This recommendation will be tracked on ICTS for completion prior to the appropriate mode restrie-t;on. As part of this evaluation the SAT also recommended that EP implement l their protected step program to ensure that commitments are not inadvertently

• . 8 2.12 Evaluetion Of Emergency Preparedn3ss (Continued)

Summary Of Findings (Continued) changed or deleted in future procedure and program revisions. This recommen-dation will be completed with periodic procedure updates and revisions. The SAT also evaluated the methods used to control programmatic changes for their impact on procedures, equipment, personnel, training and facilities. The existing methods provide adequate controls. The organizational readiness estsblished in the preparation and conduct of the June 1988 full scale graded exercise has not been diminished.

Conclusion:

The Emergency Response Organizations are capable of responding, activating and implementing the actions necessary to respond to emergencies classified during low power testing.

2.13 Evaluation Of Management Efiactiveness Purpose To evaluate the adequacy and effectiveness of the NHY management processes l for being notified of or discovering and then analyzing, tracking, trending, correcting and reporting events or deficiencies and the degree of Senior Management involvement in the Startup Test Program conduct as well as the Operational Readiness preparation activities.

Summary Of Findings 2 - Low Power SAT Recommendations 1 - Long Term SAT Recommendation NHY uses several well matured and effectively implemented programs which l

establish positive controls for event notification, response, and closure.

. To improve upon these controls, the SAT recommended (1063) that NHY issue l a Root Cause Analysis and an Incident Evaluation and Reduction Program procedure in advance of the low power testing evolution. These procedures subsequently completed the SORC review process during the self assessment period. The NHY Management Review Committees (Station Operating Review Committee (SORC) and Nuclear Safety Audit and Review Committee (NSARC])

provide extensive, multi-discipline review fun.;tions which mear.ingfully contribute to safe, reliable plant operations and practices. A standing SORC subcommittee provides a multi-discipline technical and administrative review of programs, procedures, design changc$, design installation packages,

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2.13 Evaluation Of M*nagement Effectiveniss (Continued)

Summary of Findings (Continued) and other tasks as assigned by 50RC. The subcommittee is augmented by staff from existing line organization as required. The use of this subcommittee provides effective in-depth reviews and limits the quantity of SORC "walk-ins" which have not gone through the subcommittee.

The SAT recommended (1062) that NSARC evaluate completion of a consistency review of equipment response times and a review of 10 CFR 50.59 safety eva-luations for design changes approved since the zero power license was issued.

The consistency review was completed during the assessment period and of the approximately 700, 10 CFR 50.59 evaluations to be evaluated, 117 have been completed. Of these, fif ty (50) requiced additional information in order to meet the current requirements of NHY Procedure 11210. However, in all cases, the 10 CFR 50.59 determinations were found to be accurate. Both SORC and NSARC issue formal meeting minutes and tracking lists for follow-up actions.

The SAT also recommended (1068) that NSARC complete the activities associated with an improvement in the review of techni:a1 specification reportable events as a long term recommendation.

As of November 2, 1988, NHY was addressing a single remaining open safety related allegation and will complete an evaluation and requisite resolution prior to initiating the low power testing program. NHY has evaluated and implemented applicable third party recommendations. A number of these recommendations have been scheduled for future implementation and are not required in support of operational readiness to conduct low power testing.

NHY executive managemnat as well as senior and plant management have detailed knowledge of the Startup Test Program and preparatory activities. Effective cross discipline interraces occur daily at the POD meeting. An appropriate mixture of regular interface meetings has been established to provite both vertical and horizontal information flow, to prepare for upcoming evenes and to develop joint corrective action programs for potential or identified j deficiencies.

Conclusio,.

Third party assessment reports and recommendations are adequately responded to. Open items in this area do not contain issues relavent to low power testing readiness. As of November 2, 1988, the NHY Employee Allegation Resolution (EAR) Program had etfectively investigated, tracked, and closed all but one allegation. The preliminary engineering determinations indicated 6 l .

2.1'3 Ev31uttion Of M*negement Effectiveness (Continued)

Conclusion (Continued) that this allegation is not substantiated and that the allegation will be closed within one week. The Senior Resident Inspector had been briefed on the substance and the initial determinations made on the alleged issue.

NHY management has implemented effective controls to identify, analyze and respond to management issues of significance. Management is also engaged in numerous Oversight Steering and Review Committees and has a detailed know-ledge and involvement in the preparatory activities for low power testing and plant operational readiness.

2.14 Evaluation of Security Purpose To evaluate the adequacy and effectiveness of the Security Program implemen-tation in support of operational readiness.

Summary Of Findings 0 - Low Power SAT Recommendations 0 - Long Term SAT Recommendations A site security program has been in effect since mid 1976 and the Protected Area Security Program was implemented in phases starting in March of 1986.

The Program, policy, procedures, and physical improvements have been imple-mented, analyzed, and modified as appropriate. In addition to the externally conducted Technical Specification and NSARC required audits, the Sacurity Department conducts periodic internal self assessments and has requested various third party assessments to verify various elements of the Security Program as a means of maintaining high internal standards. The Security Department utilizes the existing action item tracking systems and station programs for corrective actions. A security specific maintenance and sur-veillance program and a trend analysis program are effectively utilized.

The Security Department is responsive in addressing security incidents and in fully apprising NHY management of such iacidents and their evolving status. Management receives a quarterly event summary and analysis including trend analysie. The Security Department has prepared for low power testing and has conducted additional training in anticipation of typical, externally inposed events that may occur during Jtartup.

6 ' .

2.I4 Zvaluation of Security (Continuod) i Conclusion The Security Department is prepared for low power testing and can support operational readiness.

. . _ _ . _ _ . _ _ _ . _m I4

• Enclorure to NYN-8814fi -

RECOMMENDATION INDEX Pace 1 .

1

! I FUNCTIONAL l NUMBER DESCRIPTION AREA 0F EVALUATION S% OTHER MANAGER CLOSE0UT

~

i 1001 183 Mode / Event Restricted NRC Inspection Activities X J. M. Peschel ICTS/POO

{ Activities I

l 1002 5% Inspection Activities NRC Inspection Activities X J. M. Peschel ICTS/ POD i

i j 1003 Evaluate M e Balance Of NRC NRC Inspection Items i

X J. M. Peschel ICTS/ POD Inspection Activities For

} Revised Completion Dates i

4 1004 Apply The Protected Step Process NRC Inspection Activities X J. M. Peschel ICTS

! To Procedures Which Closeout l Inspection Activity Conuittments i

l 1005 Timely Completion Of Assigned NRC Inspection Activities X J. M. Peschel ICTS

] Implementing Activities 1006 Issue The Procedurt To Complete Generic Letters X J. M. Peschel ICTS I.N. 84-50 Actions 1007 Issue The Procedure To Complete Generic Letters X J. N. Pesche1/ ICTS I.N. 85-46 Actions J. Rafakowskt 1008 Apply The Protected Step Program Generic Letters X J. M. Peschel ICTS To I.N. 84-81 Consnitments POD = PLAN-OF-THE-DAY SCHEDULE, ICTS = INTEGRATED COMMITMENT TRACKING SYSTEM, C = CLOSEOUT COMPLETE

RECOMMENDATION INDEX Page 2

• FUNCTIONAL NUMBER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSE0UT 1009 Apply iht Protected Step Program Geraeric Letters X J. M. Pesche1/ ICTS To I.N. 85-12 Commitments G. J. Kline 1010 Tech. Support Review I.N. 84-12 Generic Letters X J. M. Pesche1/ C For Applicability To Seabroot G. J. Kline Station 1011 Engineering Review I.N. 84-12 Generic Letters X J. M. Vargas C For Appitcability To Seabroor Station 1012 Engineering Conduct a Root Cause Generic Letters X J. M. Vargas C Analysis For Program Weakness 1013 Apply Applicable SPDF Restric- Generic Letters X M. Harrington C tions For I.N. 84-12 Commitments 1014 Apply The Protected Step Program Generic Letters X R. E. Cyr ICTS To Maintenance Procedures 1015 Use ICIS To Track And Status Generic Letters X J. M. Peschel ICTS Generic Letter Cmanibnents 1016 Regulatory Services Should Generic Letters X J. M. Peschel ICTS Conduct A Historical Review Of Generic Letter Correspondence  ;

Commitments -

5 - .

o e

RECOMMENDATION TNDEX Page 3 -

FUNCTIONAL

{ NUMBER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSEOUT 1017 Tech. Support Reetew Of The Construction Punch 11st X G. J. Kline C Incomplete Items List l

1018 Document The Source Of Test Testing X D. E. Moody / C Acceptance Criteria Listed In G. A. Kann One Procedure 1019 Reinstitute The Mode Change Testing X DEMoody/GAKann ICTS Checklist /JMGr1110 IC20 Consider Using The NHY Records Testing X D. E. Moody / C Management Controlled Distribu- G. A. Kann tion Program 1021 Obtain Technical And Operational Quality Assurance X J. J. Warnock C Expertise To Independently Apply The NHY 00AP To Low Power Testing 1022 Complete OA Personnel Low Power Quality Assurance X J. J. Warnock C Specific ' raining 1023 Evaluate Installed Plant Engineering & Technical Support X J. M. Peschel ICTS/ POD Equipment NCR's for Mode Applicability i

i l 1024 Complete The ECA Review Engineering & Technical Support X G. J. Kline/ C l J. M. Vargas i

I 4

- - - . - - - . - -- . _ . _ - . = - . -_- . . ._ .. - . .-

l

'i RECOMMENDATION INDEX Page 4 -

FUNCTIONAL MUMBEk DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSE0UT' 102S Develop An Integrated NHY Third Engineering & Technical Support X J. M. Peschel ICTS Party Design Input Program 1026 Complete DCR 88-124 Engineering & Technical Support X G. J. Kline/ POD J. M. Vargas 1027 Revise RES 87-1348 To Closeos:' Engineering & Technical Support X J. M. Vargas ICTS Q.A. Surveillance RA ^';76 1028 Issue The Design Control Manual Engineering & Technical Support X J. M. Vargas ICTS Revision 1029 Revise The Procurement Manual To Engineering & Technics 1 Support X J. M. Vargas/ ICTS Reflect Dedication Of Conenercial M. Harrington Grade Items i

1030 Review Material Substitutions Engineering & Technical Support X J. M. Vargas/ C M. Harrington 1031 Develop A Main Control Board Naintenance/ Work Control X R. E. Cyr/ ICTS Out Of Service Tagging System J. M. Grilla l 1032 Increase Planning Department Maintenance / Work Control X W. A. DiProfic ICTS Resources j

t. . . . _ _ _ _ _ _ _ _ _ - - . _ _ . . __ - . . . _ _ _ . . _ _ _ . . _ _ . _ _ - - _ ._. . _ . . _ _. .__ _ . . _ .

I ,

a RECOMMENDATION INDEX Page S +

FUNCT10NAL 3 NUMBER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSE0UT i

1033 sstablish A Special Planning Maintenance / Work Control X W. A. D1Proflo C

Group To Process Work Requests During Low Power Testing I

j 10?4 Startup Test Procedure Form Testing X D. E. Moody / C l Revistor. To Include The 50.59 G. A. Kann Review Information

, 1035 Provide The Balance of The Low Testing X D. E. Moody / C

, Power Test Program Trainin'1 G. A. Kann j Sessions I

i 1036 A.O. Training (Fill & Vent Of Operations X PMRichardson ICTS

{ Systems Potentially Containing l Radioactive Materials) i l 1037 A.O. Training (H.P. Detector Operations X PMkichardson ICTS j Use) 4 l

l

! 1038 Revise MA 4.2 To Reference OPpm ' Operations X R. E. Cyr C i 10.2 and 10.4 i

i

) 1039 Standardize Vaive Controls In Operations X J. M. Grillo/ C F.P. System J. M. Vargas 1040 Review P&ID Annotations On Operations X jJ. M. Grillo/ ICTS Locked Valves J. M. Vargas 8 i

. - _ - - . - . - , - - - - . - - . . , _ _ , _ - - . . - . . _ , - - _ . . - . _ - - - . - - - - - . _ - - , _ - . - _ . - - - - . . - . - - . , - . - - ~ , . . . . _ - - _ . ~ , . . _ _ , _ . - - . ,. -

--- - --- . - . = . . -

i- *

^

4 6

• l RECOMMENOATIOed INDEX Page 6

• I FUNCTI0 seal

{ MUISER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSEOUT i

i f 1041 Clarify ne Policy On The Type Operations X 'J. M. Grillo C j Of Locks Used For Various j Applications i

{ 1042 Temporary Modificilons Tagging Operations X l G. J. Kline/ ICTS

Review. Installation and Nemoval J. M. Grillo 1

i s

1043 VAS Procedure Mode Specific Operations X J. M. Crillo C App 11cability l;

i '

l.

- I  ;

s

1044 Revise OP 9.2 Coerations i X J. M. Grillo C i

1045 Review The Locked Valve Program Operations X J. M. Grillo C 1046 Establish A SORC Policy Operations X J. M. Grillo ICTS Regarding Annunciator Procedure Review Renutrements 1047 A.O. Shift Turnover At niatch Operations X J. M. Grillo C Station s

• 1048 Enhance The Existing Procedure Operations X J. M. Grillo C Change List To Include A Change Sunenary

+

RECOMMENDATION INDEX Page 7

• FUNCT10NAL NUMBER DESCRIPTION AREA 0F EVALUATION 51 OTHER MANAGER CLOSEOUT 1049 Conduct A D.G. Fire Protection Operations X J. M. Grillo ICTS Header Waltdown 1050 Complete The Spec. Appraisal Operations X J. M. Grillo ICTS System Training 1051 Complete The Costponent Labelling Operations X J. M. Grillo/ ICTS Program J. M. Vargas 1052 Review The Need For U.S.S. Operations X J. M. Grillo C Control Room Operator Aids 1053 Provide Additional Personnel Operations X J. M. Grillo C For Control Room Admin. Support 1054 Remove Startup Tags Still Hung Operations X M. Anderson ICTS In The Station 1055 Issue OP 10.1 Operations X J. M. Grt110 C 1056 Complete Surveillance Tests Health Physics & Chemistry X W. B. Leland ICTS/POO On RAD Monitoring Equipment

RECOMMENDATION INDEX Page 8

• FUNCTIONAL NUMBER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSEOUT 1057 Complete The Engineering Review Health Physics & Chemistry X J. M. Vargas POD /ICTS Of The R.C.S. Sample System Isolation Valves 1058 Issue The Radwaste Shipping Health Physics & Chemistry X WBSturgeon/ ICTS Procedures JDKwasnik 1059 Iglement Recomendations From Engineering & Technical Support X G. J. Kline ICTS The Plant Layup Evaluation 1060 E.P. Application Of The Emergency Preparedness X P. J. Stroup ICTS Protected Step Program 1061 Low Power Impact On The E.P. Emergency Preparedness X P. J. Stroup ICTS Program And The Response Organization 1062 Complete The DCR Safety Management Effectiveness X J. J. Warnock C Evaluation TP-14 Review And TP-14 Consistency Review 1063 Issue Root Cause and Incident Management Effectiveness X J. H. Moody / C Evaluation Procedures D. E. Moody 1064 NOT ISSUED - SAT EVALUATION COMPLETED PRIOR TO ISSUE 3

a RECOMMENDATION INDEX Page 9 '

) FUNCTIONAL i NUMBER DESCRIPTION AREA 0F EVALUATION 5% OTHER MANAGER CLOSEOUT I

t

! 1065 NOT ISSUED -- SAT EVALUATION j COMPLETED PRIOR TO ISSUE j

\,

l 1066 Complete 10 CFR 50.55(e) 10 CFR 50.55(e) X J. M. Peschel ICTS Closeout Documentation 1067 Clarify The Snubber Test Engineering & Technical Support X J. M. Vargas/ C Acceptance Criteria G. J. Kline i

l 1068 Include Regulatory Services In Management Effectiveness X J. M. Peschel ICTS j The Tech. Spec. Violation Review i,

l 1069 IN?O SOER Review NRC Inspection Activities X G. J. Kline/ ICTS j J. M. Vargas i

1 I

1070 Review Letter 85-06 Closecut Generic Letters X J. M. Peschel ICTS 4

Status i

I 1071 Engineering Should Review Generic Letters X J. M. Pesche1/ ICTS

]

Maintenance Precedures Which J. M. Vargas i Implement IE Notice 87-51 Consnitments f or Protected Steps l

4

]

1072 Review The Existing Procedure Generic Letters X J. M. Peschel/ ICTS 4 To Ensure IE Notice 04-92 R. E. Cyr Consnitments Are Covered By i Protected Steps i

i

, - . - - , . - - - - . - - - - . . . ~ , , , - - , - - - ~ ~ - - - , - - ~ , , - - - - - , - - - - - - , - - - - - - - ~ - - , - - , - ,. - ,- . - - - -- - - , - - .--

o RECOMMENDATION INDEX Page 10

• FUNCTIONAL NUMBER DESCRIPTION AREA 0F EVALUATION 5% UTHER MANAGER CLOSE00T 1073 1.E. Notice 84-028 Documentation Generic Letters X J. M. Peschel ICTS Closcout 1074 1.E. Notice 86-23 Documentation Generic Letters X J. M. Pesche1/ ICTS Closcout And Protected Step Review 1075 1.E. Circular 78-10 Documenta- Generic Letters X 'J. M. Pesche1/ ICTS tion Closcout And Protected J. M. Grilla Step Review 1076 1.E. Notice 86-43 Protected Generic Letters X J. M. Pesche1/ ICTS Step Completion R. E. Cyr 1077 List All 50.55(e)'s On ICTS 10 CFR 50.55(e) X J. M. Peschel ICTS 1078 50.55(e) Documentation Closecut 10 CFR 50.55(e) X J. M. Peschel ICTS 1079 Forward 50.55(e) Files To R.M.D. 10 CFR 50.55(e) X J. M. Peschel ICTS for Record Archiving 1080 50.55(e) Documentation Closecut 10 CFR 50.55(e) X J. M. Peschel ICTS I

i.* -

l 3 I

RECOseIENDATION INDEX Page 11 '

~; .

FUNCTIONAL DESCRIPTION AREA 0F EVALUATION 51 OTHER MANAGER CLOSE0UT 1

) fl Protected Step Application And 10 CFk 50.55(e) X .L M. Peschel ICTS j 50.55(e) Closecut 4

1082 Root Cause Analysis On Timely 10 CFR 21 Reports X J. M. Vargas/ ICTS j

Part 21 Closecut Activity J. M. Peschel Complet1on 1

l 1083 Complete The Turning Vane 10 CFR 21 kcports X J. M. Vargas ICTS

, Potential 10 CFR Part 21 j Evaluation 3

) 1084 List All Part 21 Reports On 10 CFR 21 Reports X J. M. Peschel ICTS i ICTS I

1085 List The amma=*trics r Potential 10 CFR 21 Reports X J. M. Peschel ICTS j Part 21 On ICTS i

l i

i 1086 Complete The .asuma=*trics r 10 CFR 21 Reports X J. M. Vargas/ ICTS Potential Part 21 Evaluation J. M. Peschel 1087 RDMS Surve111ances Health Physics & Chemistry X R. E. Cyr ICTS/POO 1088 Apply Protected Steps To 10 CTR 21 Reports X R. E. Cyr/ ICTS MS 0539.14 J. M. Peschel k

. - - _ . - _ , , _ . _ , - . - - _ _ _ . - - _ _ , . . _ . , - ~ . , - - . - - , _ . _ _ . . -

A o

ei RECOMMENDATION INDEX '

Page 12 FUNCTIONAL q NUISER DESCRIPTION AREA 0F EVALUATION 5% OTER MANAGER CLOSEGUT 1089 Revise Reg. Svcs. Procedures To 10 CFR 21 Reports X J. M. Peschel ICTS Ensure Protected Step Application As Part Of Closeout 1090 List NYN-87091 Consnitments On 10 CFR 21 Reports X J. M. Peschel ICTS ICTS 1091 Reterence NRC Documents On ICTS 10 CFR 21 Reports X J. M. Peschel ICTS -

Which Closecut 10 CFR 21 Reports 1092 Vertfy Part 21/ CAR 0023 Closcout 10 CFR 21 Reports X J. M. Peschel ICTS Activities Are Comple' ,

i l

d i

i

'- - , . - . - . - _ _ - - . . _ . _ , _ - - _ , , - - - - - _ _ - - . - , . . . _ - - _ _ . - . - . - - - . . . - - . , _ - , _ _ - _ _ _ . . - _ _ . - - - -