ML20140D128

Insp Rept 50-443/97-02 on 970304-0414.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support

ML20140D128
Person / Time
Site:	Seabrook
Issue date:	05/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140D122	List: ML20140D118 ML20140D124 ML20140D128
References
50-443-97-02, 50-443-97-2, NUDOCS 9706100255
Download: ML20140D128 (23)

See also: IR 05000443/1997002

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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

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Approved by: Richard J. Conte, Chief, Projects Branch 8, l

Division of Reactor Projects

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9706100255 970530

PDR ADOCK 05000443

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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 inspection.

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 report.

• Several questions remain unresolved regarding the adequacy of administrative

controls used to place a temporary heater in the cooling tower pump room.

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 used.

• 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 comprehensive.

• 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 maintenance.

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 installed.

• 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 noted.

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Executive Summary

• Maintenance personnel effectively replaced a faulted air regulator on a charging

system isolation valve. Good supervisory oversight was apparent.

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 control.

• 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

comprehensive.

• 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 zone.

Plant Suooort:

• The security organization has maintained strong control of temporary trailers and

other temporary structures brought onsite to support the upcoming outage.

• 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 effective.

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

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Executive Summary  :

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remain inside the PA except for operational, maintenance, repair, security, and ,

emergency purposes. The failure to control LDVs properly was identified as a ,

violation.

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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 period.

e Good independent quality oversight was evident throughout the spent fuel pool - i

temporary modification installation. )

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TABLE OF CONTENTS

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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

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07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

07.1 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

E2.1 Pressurizer Head to Shell Ultrasonic Testing (UT) Preparation,

inspection Procedure .................................... 7 I

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IV. Plant Support ................................................. 8 l

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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

S2.1 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

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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

X.2

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. 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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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

j. 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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, _ Using inspection Procedure 71707, the inspectors conducted frequent reviews of

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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

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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

. perspectives prior to releasing work activities for field implementation. However, in  ;

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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

j. were knowledgeable of plant and system status.

j O2 Operational Status of Facilities and Equipment

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a. 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 period. 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 descriptions. l

Additionally, system, component, and general area material conditions and l

housekeeping status were noted. l

02.1 incorrect Main Steam Line Radiation Monitor Location .

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a. 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

discovery.

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b. 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 20,1997.

c. 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 period.

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

b. 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 installation.

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 97-0600.

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.

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Control room personnel could not determine from the documentation available in the

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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 operability. 1

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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 heaters.

c. 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 room.

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 ,

a. 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

inspections.

b. 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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locking the bearing in place. The cam follower roller facing on the remaining FRVs

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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.

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c. 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 questions.

07.2 Shutdown Risk Assessment

a. 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 tool.

b. 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 boil.

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 possible.

c. . 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

a. 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 performed.

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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 02. i

b. 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 SORC.

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

restored.

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c. 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 activity.

M1.2 Preparations for On-Line Maintenance on Charging System isolation Valve I

h. 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 opened.

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 personnel.

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

simultaneously.

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 9,1997.

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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 questions.

Ill. Enaineerina

E2 Engineering Support of Facilities and Equipment

E2.1 Pressurizer Head to Shell Ultrasonic Testing (UT) Preparation, inspection Procedure

(73753)

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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, NC.

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 results.

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 cracks.

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 involved.

c. 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 extensive.

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IV. Plant Support

R1 Radiological Protection and Chemlitry Controls

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R1.1 General Comments i

a. 1nmpection

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During the inspection period the inspector toured the radiologically controlled area

(RCA) on several occasions to observe radiological controls practices.

b. Observations and Findinas l

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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 requirements.  !

c. Conclusiong

The inspector determined that Seabrook Station was properly implementing the l

station radiological controls program requirements in the areas inspected. '

Radiological controls personnel were knowledgeable of station procedures and '

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provided good oversight of radiation workers. Department managers were observed

in the field observing and supervising department personnel. I

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S1 Conduct of Security and Safeguards Activities  !

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a. 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 requirements.

b. Observations and Findinag

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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 system.

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 effective.

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 equipment.  !

However, a violation was identified relative to the failure to control licensee i

designated vehicles (LDV) properly. (See Section X2) l

c. 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 LDVs. l

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S2 Status of Security Facilities and Equipment  !

S2.1 Protected Area (PA) Detection Aids

a. 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 commitments.

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b. 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 Plan.

c. Conclusion

The PA IDSs met the Plan commitments.  !

S2.2 Alarm Stations and Communications

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a. Insoection Scoo.g

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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

b. Observations and Findinas l

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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 Plan.

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 Plan.

c. Conclusion

The alarm stations and communications met the Plan commitments and NRC

requirements.

S2.3 Testhg, Maintenance and Compensatory Measures

a. 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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b. Observations and Findinas I

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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 rneasures. '

c. 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,

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S5 Security and Safeguards Staff Training and Qualification (T&Q)

a. Insoection Scope

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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

plan.

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

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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

effective.

S6 Security Organization and Administration

a. Insoection Scoce

Conduct a review of the level of management support for the licensee's physical

security program,

b. 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

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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 system.

The completed specifications for the new access control system were issued to

vendors for bidding on March 5,1997,

c. Conclusions

Management support for the physical security program was determined to be

excellent.

S7 Quality Assurance in Security and Safeguards Activities

S7.1 Effectiveness of Management Controls

a. Insoection Scoce

Conduct a review to determine if the licensee has controls for identifying, resolving

and preventing programmatic problems.

b. 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-assessment.

c. 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 weaknesses.

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 located.

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

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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 ,

activities."  !

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 violation.

(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 cutage.

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 plan.

c. Conclusions

The inspectors concluded that security management established and maintained

strong control of temporary facilities. The inspector had no further questions.

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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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  !

presented. -

The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary inforrnation was

identified.

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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

• attended March 6,1997 security exit meeting

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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

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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 located.

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 room. l

Violation 50-443/97-02-03, Failure to control licensee designated vehicles in accordance

with security plan requirements.

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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

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