IR 05000443/1989082

Forwards Augmented Team Insp Rept 50-443/89-82 on 890628-30, Enforcement Conference Issues & Related Regulatory Requirements.W/O Insp Rept

ML20247A566
Person / Time
Site:	Seabrook
Issue date:	08/17/1989
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Ellen Brown PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
EA-89-158, NUDOCS 8909120145
Download: ML20247A566 (13)

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e y AUG 171988 h Docket No. 50-443 License No.'NPF-67:

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K , .Public Service. Company of New Hampshire

. ATTN: Mr1 Edward A. Brown, President

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and Chief: Executive Officer New Hampshire Yankee Division n Post Office. Box 300: ,

- Seabrook,: New Hampshire 0387.4'

o Gentlemen:

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Subject: ~NRC Region'I Augmented Inspection Team (AIT) Inspection (50-443/89-82)

of the Natural Circulation Test at Seabrook Station, Unit'No. 1-This letter refers to the June 28-30, 1939 AIT review'of.the. June 22, 1989 natu-ral circulation. test: at. Seabrook Station, Unit, No. 3. The AIT inspection, led

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by P.: W. Eselgroth of' this office, was a fact finding and causal factor deter -

p mination effort.At tne conclusion of the inspection, an exit interview was held with you and members of your staff to discuss the inspection finding The AIT report is attached as Enclosure l'.

Confirmatory Action Letter. (CAL) 89-11 stated your agreement to review correc-tive actions and post-trip' review results with the NRC staff and to outain the agreement of the Regional Administrator prior to restart'of the-unit. 'You-should he: prepared to discuss the findings and conclusions of- this inspection -

report.and your response to CAL 89-11 at a public meeting planned for Sectem-ber 6,'1989 at the New England Center'at the University of New Hampshire in

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'Ourham, New-Hampshir Following this meeting, elected officials and inter-asted members of the public'will be offered an opportunity to provide comments-to the NRC staff on the results of the AIT inspection and on the adequacy of your corrective action If, after review of the enclosed report, you identify additional corrective actions not discussed in your July 12, 1989 response to CAL 89-11,, please ' provide those in writing 'no later than Augast 25, 198 The expression of concern in Section'5.3.3 of the report for the failure of-cert,ain managers observing the natural circulation test to assure adherence to test. procedure requirements should not be viewed as establishing new expecta-t'ons of performance. NRC encourages licensee managers to tour their

' facilities and observe significant activities and to be alert to conditions

.that could adversely affect safety. In general managers, not on watch, should not direct activities of licensed operators but rather should make their concerns known to shift supervision. However, we remain concerned with the lack' of action by managers in the control room on June 22, 1989, during the five minutes a' test criterion was exceeded, particularly since this condition was identified to licensee u.anagement by-an NRC representativ OFFICIAL RECORD COPY AIT REPORT - SEABROOK - 0001. g9220145epog,7 , 07/07/89 /

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AUG ! 71989

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Public Service of Nev: Hampshire 2 The failure to trip the reactor when required and the failure to promptly re-view and resolve any associated personnel performance implications associated

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with the failure to trip are potential violations of NRC requirements. To dis-I cuss these and other matters identified in Enclesure 2 to this letter, we have scheduled an enforcement conference in the NRC Region I office at 1:00 p.m. on September 7, 1989. At that conference, for each item, please be prepared to l present your assessment of safety significance, root. cause(s), and your interim and final correctiye actions. You will be informed in writing of the NRC deci- !

sion on enforcement action when that decision is reached after the conferenc In accordance with 10 CFR 2 Appendix C, the enforcement conference will not be open for public observatio Your cooperation with us is appreciate

Sincerely, M

William T. Russell  :

Regional Administrator i

Enclosures:

1. NRC Region I Augmented Inspection Team Report No. 50-443/89-82 2. Enforcement Conference Issues and Related Regulatory Requirements

REGION i -

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475 ALLeWDALE ROAD i

, KING of PRug81A,PENMBYLVANIA 19480

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August 17, 1989

, Docket ho. 50-443 License No. NPF-67 i- EA N .

Pubite Service Company of New Hampshire ATTNs Mr. Edward A. Brown, President and Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampchire 03874 Gentlemen:

$ubjects NRC Region ! Augmented Ir:spection Team (AIT) Inspection (60-443/89-82)

of the Natural Circulation Test at Seabrook $tation Unit N This letter refers to the June 28-30, 1989 AIT. review of the June 22, 1989 natu-ral circulation test at Seabrook Station Unit No. 1. The AIT inspection, led by P. W. Eselgroth of this office, was a, fact finding and causal factor deter-mination effort. At the conclusion of the inspection, an exit interview was

- helet with you and members of your steff to discuss the inspection finding The AIT report is attached as Enclosure Confirmatory Action Letter (CAL) 89-11 stated your agreement to review correc-tive actions and post-trio review results with the NRC staff and to obtain the agreement of the Regional Administrator prior to restart of the unit. You should be prepared to discuss the findings and conclusions of this inspection ,

report and your response to CAL 89-11 at a public meeting planned for Septem-ber 6,1989 at the New England Center at the University of how Hampshire in Durham, hew Hampshire. Following this meet."s, elected officials and inter- i ested sienters of the public will be offered an opportunity to provide connents to the NRC staff on the results of the AIT inspection and on the adequacy of your corrective actions, If, after review of the enclosed report, you identify additional corrective actions not discussed in your July 12,1989 response to CAL 89-11, please provide those in writing no later than August 25,198 The expression of concern in Section 5.3.3 of the report for the failure of certain managers observing the natural circulation test to assure adherer::e to test procedure requirements should not be viewed as establishing new expecta-tions of performance. NRC encourages licensee mar. agers to tour their )

facilities and poserve significant activities and to be alert to conditions that could adversely affect scfety. In general managers, not on watch, should not direct activities of licensed operators but rather should make their concerns known to shift supervision. However, we remain concerned with the '{

lack of action by ennagers in the c -ntrol room on June 22,1989, during the five minutes a test criterion was exceeded, particularly since this condition was identified to licensee management by an NRC representativ '

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Public Service of New Hampshire, In August 17,1989 s

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The ,' allure to trip the reactor when requiren and the failure to promptly re-view and resolve any associated personnel performance implications associated with the is11ure to trip are potential violations of NRC requirements. To dis-cuss these and other matters identified in Enclosure 2 to this letter, ine have scheduled an enforcement conference in the NRC Region 1 office at 1:00 p.m. on September 7, 1989. At that conference, for each item, please be prepared to present your assesseent of safety significance, root cause(s), and your in'.erim and final corrective actions. You will be informed in writing of the NRC deci-sion on enforcement action when that decision is reached after the conferenc In accordance with 10 CFR 2 Appendix C, the enforcement corforence will not be open for public observatio Your cooperation with us is appreciate $1ncerely, 40. 7 /<-~dk William T. Russell Regional Administrator Enclosures:

1. NRC Region 1 Abgmented Inspection Team Report No. 50-443/89-82 2. Er.forcement Conference Issues and Related Regulatory Requirements cc w/encls:

J. C. Duffett, President and Chief Executive Officer, PSNH T. C. Feigenbaum, Senior Vice President and Chief Operating Officer. NHY J. M. Peschel, Operational Programs Manager NHY "

NHY P. W. E. Agnes, Moody,Jr.,Station Manager $ecretary of Public Safety Commonwealth of Assistant Massachusetts Local Public Document Room Public Document Room (PDR) (LPDR) (

Nuclear Safety Information Center NSIC)

NRC Resident Inspector State of New Hampshire Coninenwealth of Massachusetts Seabrook Hearing Service List i

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Public Service of New Hampshire, In '3 August 17, 1989

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N. Perkins, DRMA (w/o enclosures)

J. Wiggins, DRP D. Haverkamp, DRP N. Dudley, $RI - Seabrook (w/ concurrences)

A. Corne, Seabrook J. Joyner, DRSS K. Abraham, PA0 (28) (w/o bec listing)

V. Norses, NRR J. Trapp, DRS R. Wessman, NRR M. Miller, SLD L. Lois, NRR F. Guenther, NRR J. Johnson, DRP B. Boger, DRS R. Gallo, DRS J. Durr, DR$

P. Espen DR$

R. Conte, DRS P. Eselproth. DR$

T. Martin, RI W. Kane, DRP 5. Collins, DRP K. Perkins, NRR J. Roe NRR - ..

T.Murley,NRR J. Dyer, EDO D. Holody, RI J. Lieberman, DE J. Goldbers, DEC J. Partlow, NRR M. Callahan, CA

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ENCLDSURE 2 Enforcement Conference issues and Related Regulatory Requirements The following activities appear to be contrary to: 10 CFR 50 A '

CriterionV,requiringadherencetoappropriateprocedures;toIbpendixB, CFR 50 Appendix B Criterion 11 recuiring adnerence to test procedures; to Final Safety Analysis Report (FSAR) Section 14.2 specifying that 1) the initial startup program be administered in accordance with an approved startup procedure, and 2) that $tartup Test Direction persornel will perform startup test coordination and direction functions; and to Natural Circu-lation Startup Test Procedure 1 $T-2 During the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, pressurizer level reached the 175 criterion requiring l a reactor trip in accordance with Attachsent 9.3 to the procedure, l and the reactor was not trippeo by the operating shift as required

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(ReportDetails 5.1.4,5.1.5). Startup Test 1-ST-22 prerequisite 3.6.7 confirming the availability .

of s.ain steam dump valve MS-0Y-3011 was signed off despite the valve net being properly ready to support the test because work order WRB7W005592, requiring a stroke test at r.ormal operating temperature andpressure,wasstillopen(RepcetDetail4.3.3).-Thefailureof MS-PV-3011 during performance of 1-$T-22 initiated the June 22,1989, test transien Startup Test 1-$T-22 pre-test briefings were not conducted as required, in that the Test Step 3.2 provisions for personnel involved wie. pro- ..

cedure performance to be briefed on procedure conduct and test per-fonnance was not accomplished for one of the two control board ope ators assigned to assist the. shift crew (Report Detail 5.2.4). Fur-ther, the briefings which were conducted were not appropriate because they were conducted for individuals in a fragmented and abbreviated manner and not for the operators as a group (Report Details 5.2.4, 5.2.6),becausetheshiftsupervisor'sawarenessandknowledgew:s not consnensurate with the significance and complexity of the test '

(Report Detail 5.1.5), and because the operators acceptad violation of a test procedure trip requirement (Report Detail 5,,1.5). These conditions were evaluated as contributors to the June 22 ure to trip the plant as required by Startup Test 1.$T-2I.1989 fail-In addition, inasmuch as simulator trainir.g on the startup test program was conducted in April and May of 1986 and classroom training on low power testing was last conducted in September and Detober of 1988 (Report Details 5.1.2,5.1.5), a lack of recent training was a potential additional contributor to the June 22, 1989 failure to trip the plant as require *

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-Enclosure 2 2

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l D:: ring performance of Startup Test 1 ST-22 on June 22, 1989, the Startup Manager, Shif t Test Director, and Test Director were present in the control room. No interruption or termination action was in-itiated by the Startup Organization when the 17t pressurizer level reactor trip criterion of Startup Test 1-ST-22 was reached nor was the operating staff counselled by the Startup Organigstion that a reactor trip was required under the caisting conditions (Report De-tails 5.2.5, 5.2.6). The following appear to be contrary to: 10 CFR 50, Appendix B, Criterion XVI which requires that measures be estabitshed to assure that conditions -

adverts to quality be promptly identified and corrected, and to assure that the cause for each significant condition adverse to quality and the corrective action taken be reported to appropriate levels of unagement; and to the FSAR Chapter 13.1.2.2 operating shif t management provisions:

and to the assignment of responsibilities for implementation of these pro-visions in accordance with the Operations Management Manual, Subsequent to the June 22,1989 failure to effect a plant trip during conduct of Startup Test 1-$1-22, licensee managesent failed to promptlyresolveassociatedpersonnelperformncefailures(Report Detail 5.3.3). During performance of Startup Test 1-57-22 on June 22, 1989, managers present in the control room included the Operations Manager, who is responsible for the operation of the unit's equipment in accordance with approved station procedures, and the Ass 15 tant nperatinne Nanager, who directs the activities of the shift superintendents. Both of "

these sLnagers have the authority to order a reactor shutdown and were observing startup Test 1-57-22 performance in the control board area (Reportvetail5.3.2). Neither of these unagers affectively implemented his oversight responsibility during the tes *

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