IR 05000443/1990015

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-443/90-15

ML20062B109
Person / Time
Site:	Seabrook
Issue date:	10/02/1990
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#490-10913 OL, NUDOCS 9010240047
Download: ML20062B109 (3)

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007 0 2 1990 I h'

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Docket No. 50443 l i

l Public Service Company of New Hampshire ATTN: Mr. Ted. J. Feigenbaum, President

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and Chief Executive Officer New Hampshire Yankee Division

. Post Office Box 300

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Scabrook, New Hampshire 03874  :

Gentlemen: Subject: Inspection 50-443/90-15 This refers to your September 14,1990 response to our letter dated August 16, 199 Thank you for informing us of the corrective and preventive actions documented in your letter. We consider those actions acceptable and will examine their implementation during a ;

future inspectio ,

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Thank you for your cooperatio

Sincerely, ORIGINAt. SIGNED BY:

JON R. JOHNSON ,

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L' Jon R. Johnson, Chief ,

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u Projects Branch No. 3

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Division of Reactor Projects  !

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^90102-40047 NO$ dh PDR ADOCK 05000443 j-CFIIcit,t y;7ccRD c0Py Sj PDC . ~ . . . _ j g t 5 4 , .

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OCT 0 21990 Public Service Company of 2

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New Hampshire cc: ,

L. E. Maglathlin, Jr., President and Chief Executive Officer, PSNH Senior Vice President and Chief Operating Officer, NHY J. M. Peschel, Regulatory Compliance, NHY R. M. Kacich, Manager of Generation Facilities Licensing, NUSCO J. F. Opeka, Executive Vice President, NU G. Garfield, Esquire D.~ E. Moody, Station Manager, NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts S. Woodhouse, Legislative Assistant Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector (w/cy of Licensee's Reply letter)

State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Seabrook Hearing Service List (w/cy of Licensee's Reply Letter) .

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Public Service Company of- 3 OCT 0 21990 L

- New Hampshire bec w/cy of Licensee's Reply letter:

i Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl) L R. Bellamy, DRSS E. McCabe, DRP J. Johnson, DRP N. Dudley, SRI - Seabrook (w/ concurrences) i

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K. Abraham, PAO (2) All Inspection Reports J.~ Caldwell, EDO

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McCabe/meo don 10/2/90 [

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OFFICIAL RECORD COPY

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New Hampshire TedC.lf; ' -

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Senior Vice President onci Chief Operating Officer liYN.90171 Sq:tmber 14, 1990 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk References: (a) Facility Operating License No. NPi 86, Docket No. 50 443 (b) USNRC Letter dated August 16,1990,'NRC Region I Inspection Report 50 443/90 15,* J.R. Johnson to E.A. Brown Subject: Reply to a Notice of Violation Gentlemen:

In accordance with the requirements of the Notice of Violation contained in Referrace (b), the New Hampshire Yankee response to the cited violation is provided as Enclor;.ne Should you have any questions concerning our response, please contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474 9521, utension 377 Very truly yours, N

Ted C. Feigenbaum Enclosure TCP:CLB/ssl fbQQJ4015 ,

c ONew Hempshire Yonkee Division of Public Service Company of New Hampshire P.O. Ikm 300 * Seabrook, NH 03874 o Telephone (603) 474 9521

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United States Nuclear Regulatory Corsmission September 14, 1990 Attention: Document Control Desk Page two cc: Mr. Thomas T. Martin Regional Administrator Unite <! States Nuclear Regulatory Commission Rer, ion I 415 Allendale Road King of Prussia, PA 19406 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874

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New Hampshire Yankee

, September 14, 1990 e

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ENCLOSURE 1 TO NYN 90171 REPLY TO A NOTICE OF VIOLATION

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New Hampshire Yankee

September 14, 1990 Renly to a Notice of Violation Violation

During an NRC inspection from June 't July 29,1990, a violation of NRC tequirements was identified in accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR, Part 2, Appendix C. That violation is listed below:

Technical Specification 3.8.4.1 requires that circuit breakers feeding containment power distribution panels 1 ED PP 7A and 7B shall be padlocked OPEN during Mode 1 operation (to protect the containment penetrations from an electrical fault) except for breaker closure for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> under the control of an operating procedur Contrary to the above, on July 21,1990, the circuit breakers feeding power distribution panels 1-ED PP 7A and 7B were found to have been in the SHUT position for 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> during Mode 1 operatio Response:

New Hampshire Yankee concurs with the violation as written. That event related to this violation was discovered by New Hampshire Yankee and was reported to the NRC in LER 90 019 0 In preparation for a containment entry on July 21, 1990, it was discovered that circuit breakers 1 ED PP 7A and 1 ED PP 7B were closed. Investigation showed these circuit breakers had been closed since 2:10 a.m. on July 18, 1990. Seabrook Station Technical Specification (T.S.) 3.8. states that circuit breakers feeding certain listed loads inside primary containment shall be padlocked in the open position. However, there is an exception such that these circuit breakers may be closed for 'brief durations (not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) during plant operation ... provided this change in breaker position becomes part of the applicable operating procedure used for work inside containment". 1 On this occasion, the circuit breakers 1 ED PP 7A and 1 ED PP 7B were closed six hours and fifty minutes longer than allowed by T.S. 3.8.4.1. They were closed at 2:10 a.m. on July 18,1990, to allow use of receptacles powered by these circuit breakers. At that time, Operations Department Procedure OP10.6, " Action Statement Tracking", did not require entering such an action into the Action Stawment Status Log when the action was expected to be cleared by the end of the shif The Operatars on shift that morning expected to open the circuit breakers before the next shift and therefore, it was not entered into this lo ,

Shortly after the breakers were closed, a personnel injury was reported inside the turbine building and Emergency Response Procedure ER 4.4, 'Onsite Medical Emergency", was entered. The attention of shift personnel was directed to the medical emergency and the information concerning the action statement of T.S. 3.8.4.1 was not included on the shift turnover sheet (Control Room Relief Checklist), or the Action Statement Status Log. As a result, the oncoming shift was not j

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aware that the circuit breakers were close ,

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New Hampshire Yankee !

September 14, 1990 !

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Twice the next day the procedure OX1460.01, ' Air Lock Door Seal 72 Hour Air Rate Test',

was performed. This is part of the containment close out section of procedure ON1090.04,

' Containment Entry' and the containment exit section of procedure OS1058.01, ' Operating the Containment Personnel Hatches'. Both of these sections in these procedures also direct ,

1 ED PP 7A and 1 ED PP 7B to be opene F Upon discovery of the closed circuit breakers, they were immediately opened and the length of time they had been closed was determined. The circuit breakers were then closed again to allow another containment entry in which they were neede A Root Cause Analysis and Human Performance Enhancement System evaluation have been performed. The root cause of this event has been attributed to failure to follow procedures as the primary cause. Incomplete communications, inadequate policy and difficulty in following procedures were identified as contributing factors. Although operators on the shift ,

following that which entered T.S.3.8.4.1 were unaware that the circuit breakers were closed, ,

the procedures involved, ON1090.04, ' Containment Entry' and OS1058.01, ' Operating the Containment Personnel Hatches', both address T.S. 3.8.4.1 and direct the circuit breakers to be opene In addition, the lack of communication between shifts contributed greatly to this evest. The *

oncoming shift knew there were people in containment but did not realize these circuit ;

breakers were closed because this information was not in the Action Statement Status Log

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or on the shift turnover sheets. Few entries into containment, other than for Health Physics surveys, require these circuit breakers to be close As corrective action to prevent recurrence of this event, Procedure ON1090.04 was revised to require that whenever a containment entry is made, it be entered into the Action Statement Status Log and to require that form ON1090.04A, ' Containment Closcout Form" be completed. This form is a checklist which includes the requirements of T.S. 3.8.4.1 as ,

well as other required actions upon containment exit. Also, this procedure now has minimum time requirements that these circuit breakers must remain open prior to being reclose q l

'In addition, the importance of completeness in the Control Room shift turnover process I

was stressed by the Operations Manager in individual meetings with Shift Superintendent Discussions were also held with the operators regarding the basis for the Technical Specification requirement that these breakers be locked open. The results of these discussions. Indicated that operators were in fact aware that the purpose of locking these breakers open is to ensure the integrity of the associated containment penetration l The feasibility of a design change to preclude recurrene of :'as type of event is being evaluate This evaluation is expected to be completed by October 30, 1990. The ,

requirements that all containment entries be entered into the Action Statement Status Log will ensure that adequate configuration control exists regarding the position of these breakers. Additionally, the requirement that the breakers remain open for a minimum period prior to being reclosed will provide increased assurance of compliance with the intent of this Technical Specification and will provide an added control for the position of these breakers, i

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