IR 05000443/1987020

Insp Rept 50-443/87-20 on 870720-24.Violation Noted.Major Areas Inspected:Administrative Controls for Safety Tagging of Sys & Components,Control of Temporary Mods & QA Interfaces W/Operations & Engineering

ML20237H847
Person / Time
Site:	Seabrook
Issue date:	08/11/1987
From:	Blumberg N, Denise Wallace NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237H837	List: IR 05000443/1987020 ML20237H835 ML20237H841
References
50-443-87-20, NUDOCS 8708250172
Download: ML20237H847 (8)

Text

- _ - _ . _-- ,

.

.

U S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-20 Docket N License N NPF-56 Licensee: Public Service of New Hampshire P. O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: July 20-24, 1987 Inspector:/ ./pdFN B- //- 8 7 David Wallace, Reactor Engineer date Approved by e ___6 - //- 8 7 W Norman BTDmberg, CKier, Operational date Programs Section, Operations Branch, DRS Inspection Summary: Routine unannounced inspection conducted on July 20-24, 1987 (Report No. 50-443/87-20)

Areas Inspected: Administrative controls for safety tagging of systems and components, control of temporary modifications, and Quality Assurance inter-faces with Operations and Engineerin The inspection was performed by one region-based inspecto Results: One violation was identified: Failure to implement safety tagging administrative control PDR ADDCK 05000443 Q PDR

-_ _ - - _ - _ _ -

- _ - - - _ _ _ _ _ _ _ _ _ _ _ _

,

.

'

,

1.0 Persons Contacted New Hampshire Yankee Personnel Barraclough, Lead Quality Control Inspector Bec5 ward, Quality Assurance Supervisor Cade, Technical Support Cyl, Maintenance Manager DiProfio, Assistant Station Manager Grillo, Assistant Operations Manager Kenney, System Support Manager (YAEC)

Hickok, Training Support Service Manager

' Laird, Instrumentation and Controls Supervisor Malone, J Operations Administration Supervisor Moynihan, New Hampshire Yankee Perkins, Licensing Pucko, Licensing Tefft, New Hampshire Yankee Temple, Licensing Coordinator Wornack, Nuclear Quality U.S. Nuclear Regulatory Commission Cerne, ' Senior Resident Inspector Ruscitto, Resident Inspector  !

All personnel listed were present at the exit meeting conducted on July 23, 198 .0 Control of Safety Tagging and Temporary Modification for Structures, Systems and Components 2.1 References / Requirements

--

10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plant Regulatory Guide 1.33-1978, Quality Assurance Program Requirement ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plant .2 Review of Plant Safety Tagging Control The Seabrook program for safety tagging of plant systems and components was reviewed in order to verify compliance with the requirements refer-enced in paragraph The following programmatic procedures were reviewed:

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

.

.

--

Maintenance Program Manual, Procedure MA 4.2, Revision 5, Equipment Tagging and Isolation, May 21, 198 Operations Management Manual, Procedure OP 10.2, Revision 4, Independent Verification, 2/3/8 The inspector selected and reviewed approximately 30 active Tagging Orders against applicable requirements in order to verify that the following criteria were met:

• Tagging Orders were properly authorized and verifie * The isolation was documented on the Tagging Order as having been performe *

Tagging Orders contained a description of the equipment or system to be tagge *

Remaining portions of the Tagging Orders were properly complete Independent verification for the restoration of plant components affected by Tagging Orders was reviewed by the inspector. This review was conducted by comparing approximately 30 inactive 1987 Tagging Orders with the independent verification list found in the Operations Management Manual, Procedure OP 10.2, Independent Verifica-tion. The inspector was accompanied by a licensed operator during this portion of the inspection which included a verification of the following attributes:

Restoration sign-offs for all components listed on the Tagging Order were signed for by qualified personne *

Independent verifications were performed on the components speci-fied in the independent verification list of OP 1 * Documentation pages for Independent Verification sign-offs were t attached to Tagging Orders which required such verificatio In addition, approximately 6 active Tagging Orders were reviewed and walked through by the inspector for the following attributes:

• Tagging Order isolation boundaries were sufficient for the work l being conducted.

i

• Danger Tag Holds were implemented where necessar * Tagging Order modifications were controlled properl * Applicable components were positioned as referenced on the ,

Tagging Orde I l

Danger and Caution tags were properly completed and present on l

'

referenced equipmen u ..

-

. .

I

-_

_ _

,

.

.

2.2.1 Findings During an in-depth review of active Tagging Orders, the inspector i determined that work being conducted on Service Water Train "B" was not being controlled in the manner specified in station administrative procedures. The lack of controls over safety tagging apparently consisted of 2 areas: 1) the lack of con-tinuity between separate Tagging Orders being used to isolate components for a single maintenance activity, and 2) the removal of a valve which was itself danger tagge Tagging Orders 87-1754 and 87-1395 were reviewed by the inspector to determine their adequacy for the isolation of the relerenced work. During the comparison of the Tagging Order isolation boundaries against Service Water System PID drawings numbered 1-SW-B20795 and 1-SW-B20794, it was determined that Tagging Order 87-1395 was being used to isolate components to support the removal and reinstallation of valve 1-SW-V-20 under Tagging Order 87-175 In other words, Tagging Ordnr (T.O.) 87-1754 was being used to control the work, but T w. 87-1395 was providing additional tagging boundaries essential to the safe isolation of the work being performed. This condition is currently allowed by administrative procedure, MA 4.2, Revision 5, " Equipment Tagging and Isolation," provided that a " Danger Tag Hold" is placed on the supporting Tagging Order to prevent essential isolation boundaries from being compromised. The " Danger Tag Hold" administratively prevents the additional T.O. from being cleared prior to the completion of work. The inspector observed that no " Danger Tag Hold" had been established on T.O. 87-1395 as required. This condition could conceivably result in the clearance of T.O. 87-1395 prior to the completion of work on valve 1-SW-V-20 and therefore endanger personnel and/or equipmen A second example of this failure to establish a " Danger Tag Hold" was observed between T.O. 87-1620 and T.O. 87-1395 where the premature clearance of T.O. 87-1395 could endanger personnel or equipment involved in the work authorized by T.O.87-162 The inspector subsequently observed a second condition in violation of station administrative controls and regulatory requirement During the walkdown of the isolation specified in T.O. 87-1395, the inspector determined that danger tagged valve 1-SW-V-139 had been physically removed from the Service Water System. The inspector also observed that T.O. 87-1395 had not been modified to allow for the removal of the valve, even though valve 1-SW-V-139 formerly served as an isolation boundary. Operations personnel later demonstrated that due to the service water system design, removal of valve 1-SW-V-139 did not significantly endanger the remaining

} isolation established on the system. The licensee did however, concur with the inspector that the removal or operation of any valve with a Danger Tag attached is not permitted by station administrative control .

--

.

.

Prior to this inspection, increased management attention had been directed toward the area of plant tagging. This attention, to some extent, has been due to a recent problem with plant tagging that resulted in spilling approximately 20,000 gall ns of borated

- !

water from the RWST (Reference, Public Service of New Hampshire SIR 87-060). This management attention has included a proposed change to procedure MA 4.2 which would require each Tagging Order to be a stand-alone document, and 2 memos from L. A. Walsh to Shift Superintendents, Unit Shif t Superintendents, and other personnel performing the tagging operations which directed, in part, that each Tagging Order must be a stand-alone documen Although these actions were to be initiated, it was nevertheless apparent that the discrepancies identified in this section are in violation of station administrative controls. The failure to implement administrative procedure MA 4.2, " Equipment Ta;ging and Isolation," is considered a violation (50-443/87-20-01).

2.3 Review of Temporary Modifications The inspector reviewed Maintenance Program Manual, Procedure MA 4.3, Revision 6, " Temporary Modifications," in order to compare the site administrative controls to the requirements referenced in paragraph The inspector then chose a sample of 14 safety-related Temporary Modi-fications from the temporary modification logbook for revie The Temporary Modifications reviewed are listed in Appendix Temporary Modifications chosen by the inspector were reviewed for the following attributes:

• Description and Reason for Change portions of the Temporary Modification (TM) Request form were completed adequatel = 10 CFR 50.59 review of TM was performed adequately, with doce-mentation attached to TM Reques * TM Request was approved by designated personnel and SORC, prior to performance of wor * Performance of work was verified by personnel other than those initially performing the work, a Testing requirements for TM restoration was designated and conducte * Safety Evaluations were adequate where require Environmental Impact Evaluations were performe * TM Reevaluations were conducted in accordance with station administrative procedures.

I l

.__ ____ _ - -

_ _ _ _

---

,-----__----_.--- - - - - - - - - _ -- - - - - - - - - - - - - - - _ - _ - - - _ _ .--_ ---- -

.

.

i 2 -. 3 .1 Findings The inspector observed the following discrepancies during the review of Temporary Modifications:

-- Reevaluations of outstanding Temporary Modifications were generally overdue by 1 to 2 month Several TMs were documented as having been completed prior to Station Manager and SORC approva TM was not reviewed by SORC until approximately 3 months after implementatio The inspector subsequently became aware of the Seabrook Quality Assurance (QA) Surveillance Report, No. 87-00424, and the Seabrook QA Audit Report, No. 86-A07-1, " Equipment Control."

In these reports, QA had previously identified the discrepancies listed above, and had initiated corrective action for the problem The inspector reviewed the corrective action and verified through his review that the discrepancies appeared to be adequately addressed, in that recent examples of the problems i were not found., This corrective action consisted, in part, of the following programmatic changes and short term actions:

Temporary Modifications were reviewed for proper documentation and technical adequac * Transfer of the tracking and administration of TMs from Operations to the Engineering Departmen * Designating personnel to initiate reevaluations of TMs in accordance with administrative directive The inspector determined that the corrective action instituted was adequate to address his concerns. Continued improvement in the handling of Temporary Modifications is expected since programmatic changes have been in effect a relatively short time (approximately 1 months).

No violations or deviations were observe .0 QA/QC The inspector held discussions with QA/QC personnel and reviewed QA Audit and Surveillance reports to ascertain Quality Assurance's role in the areas of Safety Tagging and Temporary Modifications. The QA program appears to be effective in identifying problems and initiating corrective actio During the inspection, the inspector was made aware of QA's involvement in both areas, with their effectiveness clearly seen in the Temporary Modification

_ - _ _ _ _ . I

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

,

..

.,

area as discussed in Section 2.2.1 of this report. QA has also been placing more emphasis on the area of Safety Tagging. A review of past QA Audit and Surveillance Reports has not indicated to the inspector that the problems discussed in Section 2.1.1 of this report had been previously identified l

by QA.'

No violations or deviations were identifie .0 Management Meetings-Licensee management was informed of the scope and purpose of the inspection-at an entrance interview conducted on July 21, 1987. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on July 23, 1987 (see paragraph I for attendees) at which time the findings of the inspection were presente At.no time during this inspection was written material provided to the licensee by the inspecto l

.

l l

I

_ _ _ _ -- _ - - - - - - - - _ - - - - - - - - - - - - - - - - -- a

- -___ ___ .__ . _ . ., .

..

.

APPENDIX 1 Temporary Modifications Reviewed 86-026 86-078 86-027 86-100 ,86-028 86-114 i 86-029 87-035-86-066 87-038 86-070 87-045 86-073 87-046

_