IR 05000443/1993005
| ML20045D486 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/17/1993 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| References | |
| NUDOCS 9306290058 | |
| Download: ML20045D486 (4) | |
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{{#Wiki_filter:US ' . . JLN I T EB , Docket No. 50-443 Mr. Ted Senior Vice President and Chief Nuclear Officer North Atlantic Energy Service Corporation Post Office Box 300 Seabrook, New Hampshire 03874
Dear Mr. Feigenbaum:
SUBJECT: INSPECTION REPORT NO. 50-443/93-05 This letter refers to your May 24,1993 correspondence, in response to our April 23, 1993 letter.
. Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, e + M % ned Dy A. Randolph Blough, Chief Projects Branch No. 4 Division of Reactor Projects cc w/ encl: B. L. Drawbridge, Executive Director of Nuclear Production W. DiProfio, Station Manager R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts S. Woodhouse, Legislative Assistant T. Rapone, Massachusetts Executive Office of Public Safety D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Scabrook Service L.ist , 9306290058 930617 A PDR ADOCK 05000443 U O PDR i < L\\
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North Atlantic Energy
Service Corporation bec w/ encl: Region i Docket Room (with concurrences) R. Blough, DRP J. Rogge, DRP V. McCree, OEDO A. DeAgazio, PD I-4, NRR J. Stolz, PD I-4, NRR RI:DRP RI:DRP hB R 7e 6/ /93 6/n/93 OFFICIAL RECORD COPY G:\\BR ANCH4\\RSB50-443.05
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... SEABROOK SERVICE LIST Thomas Dignan, Esquire Diane Curran, Esquire John A. Ritscher, Esquire Harmon and Weiss Ropes and Gray _ 2001 S Street, N.W.
i One International Place Suite 430 Boston, Massachusetts - 02110-2624' Washington, D.C.
20009 Mr. J. F. Opeka Regional Administrator, Region I - , Northeast Utilities U.S. Nuclear Regulatory Commission
P. O. Box 270 475 Allendale Road ' Hartford, Connecticut 06141-0270 King of Prussia, Pennsylvania 19406 ' Mr. A. David Rodham, Director John P. Arnold, Attorney General Massachusetts Emergency Management Agency G. Dana Bisbee, Associate Attorney 400 Worchester Road, Box 1496 General. Framingham, Massachusetts' 01701-0134 Attorney General's Office ATI'N: Mr. James B. Muckerheide 25 Capitol Street , State Nuclear Engineer Concord, New Hampshire 03301 ' t Robert Backus, Esquire Mr. R. M. Kacich Backus, Meyer and Solomon Northeast Utilities Service Company. I16 Lowell Street P. O. Box 270 Manchester, New Hampshire 03106 Hartford, Connecticut 06141-0270 , Mr. T. L. Harpster Office of the Attorney General North Atlantic Energy Service Corporation One Ashburton Place Post Office Box 300 20th Floor Seabrook, New Hampshire 03874 Boston, Massachusetts 02108 , Seacoast Anti-Pollution League Town of Exeter 5 Market Street 10 Front Street , Portsmouth, New Hampshire 03801 Exeter, New Hampshire 03823 Mr. David W. Graham Stephen G. Burns, Director Fuel Supply Planning Manager Office of Commission Appellate Massachusetts Municipal Wholesale Adjudication Electric Company U.S. Nuclear Regulatory Commission P. O. Box 426 Washington, D.C.
20555 , Ludlow, Massachusetts 01056 Gerald Garfield, Esquire Board of Selectmen Day, Berry and Howard Town of Amesbury j City Place Town Hall Hartford, Connecticut 06103-3499 Amesbury, Massachusetts 01913 l ' .. -. . . . _ _ .
- . ... . Seabrook Service List
Resident Inspector Mr. Peter Brann U.S. Nuclear Regulatory Commission Assistant Attorney General Seabrook Nuclear Power Station State House, Station #6 Post Office Box 1149 Augusta, Maine 04333 Seabrook, New Hampshire 03874 Jane Spector Adjudicatory File (2) Federal Energy Regulatory Commission Atomic Safety and Licensing Board Panel 825 North Capital Street, N.E.
Docket Room 8105.
U.S. Nuclear Regulatory Commission Washington, D.C.
20426 Washington, D.C.
20555 Mr. George L. Iverson, Director Mr. Jack Dolan New Hampshire Office of Emergency Federal Emergency Management Agency Management Region 1 State Office Park South J.W. McCormack Post Office and 107 Pleasant Street Counhouse Building, Room 442 Concord, New Hampshire 03301 Boston, Massachusetts 02109 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
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Odii Seab%k?"s03874 "' ' f Telephone (603)474 9521 j hhfih _. m Facsimile (603)474 2987 Energy Service Corporation Ted Senior Vice President and Chief Nuclear Officer ~ NYN-93076 May 24,1993 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Document Control Desk References: (a) Facility Operating License No. NPF-86, Docket No. 50-443 (b) USNRC Letter dated April 23, 1993, " Inspection Report No.
50-443/93-05," A. R. Blough to T. (c) North Atlantic Letter NYN-92125 dated September 25,1992, "Lic ens e e Event Report (LER) 92-013-00: Tornado Design of Plant Doors," T. to USNRC . (d) North Atlantic Letter NYN-92161 dated November 20,1992, " Lice n see Event Report (LER) 92-013 01: Tornado Design of Plant Doors," T. to USNRC (e) North Atlantic ! etter NYN-92146 dated October 23,1992, " Tornado Design of Plant A s," T. to USNRC Subject: Reply to a Notice of Violation Gentlemen: In accordance with the requirements of.the Notice of Violation contained in Reference (b), the North Atlantic Eriergy Service Corporation (North Atlantic) response to the cited violation is provided as Enclosure 1.
Should you have any questions concerning this response, please contact Mr. James M.
Peschel, Regulatory ~ Compliance Manager, at (603) 474-9521, extension 3772.
Very truly yours, Ted TCF:J ES/jes/ tad Enclosure $ , fC ' Qo , DjU - a member of the Northeast Utilities system
- - - , - - 1 .: . ,- -,_ . ' .$ United States Nuclear Regulatory Commission May 24,1993
' Attention: Document Control Desk ' Page two j
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Mr. Albert W. De Agazio, Sr. Project Manager . ' Project Directorate I-4 Division of Reactor Projects -' U.S. Nuclear Regulatory Commission Washington, DC ~ 20555-Mr. Noel Dudley NRC Senior Resident Inspector Sbbrook, 1 03871 . t ' . , _ .... ... -
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REPLY TO A NOTICE OF VIOLATION ' ' ' ' In a letter dated April 23,1993 { Reference (b)), the NRC transmitted to North Atlantic-Energy Service Corporation (North Atlantic) a Notice of Violation for approving a change
to the design basis tornado described in Updated-Final Safety Analysis Report (UFSAR) without first completing the requisite safety evaluation pursuant to ~10 CFR 50.59, and without updating the UFSAR. In accordance with the instructions pro'vided in.the Notice of Violation, the North Atlantic response to this violation is provided below.
A.
Violation The Code of Federal Regulations 10 CFR 50.59 requires that a safety evaluation be written prior to changing the facility as described in the Updated Final. Safety Analysis Report.
Contrary to the above, on June 26,1991 engineers failed to perform a written safety evaluation prior to changing the design basis tornado described in section 3.2.1.2(b)2 of the Updated Final Safety Analysis report.
'{ J This is a Severity Level IV violation (Supplement.I).
. ' B.
Reason for the Violation As stated above, and as described in the letter transmitting this Notice of Violation, there ' ' are three components to this violation that must be specifically addressed': , 1.
Why a safety evaluation was not performed in a timely manner; 2, Why the UFSAR was not updated; and, 3.
Why this nonconforming condition was not immediately reported to the NRC.
North Atlantic does not contest any. portion of this violation. The specific reason's for this l violation are described below.
As stated in Reference (c), North Atlantic originally identified a concern with the design of tornado barriers at. Seabrook Station in late 1990 while developing a consolidated design basis document for plant barriers and while consolidating associated plant drawings. During this review, the Manager of Engineering adopted a site specific tornado as the design basis.
However, at that time, Engineering management did nots formally document a safety evaluation pursuant to 10 CFR 50.59 prior to adopting the new design basis. This was due, in part, to the Manager of Engineering's confidence that an unreviewed safety question and operability concerns did not exist as a result of the acceptance of the' site specific tornado design basis. This confidence was founded on the informal evaluations that were performed , JA related issue. pertaining to why seven nonconforming tornado doors were not included in the United Engineers and Constructors-(UE & C) door. specification as tornado barrier doors, was addressed in both References (c) and (d).
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. , by the Engineering Department, utilizing existing industry guidance.
Based on this 6-confidence, the Manager of Engineering determined that it was appropriate to perform the requisite UFSAR change and its associated safety evaluation upon final completion of the design basis document. However, completion of the design basis document was not timely.
A ' factor contributing to the failure to formally document a' safety evaluation, and in turn, the root cause for failing to update the UFSAR and to report this issue to the NRC, was the failure to implement tbc North Atlantic Corrective Action Program. Specifically, if the Corrective Action Program had been utilized, a Station Information Report (SIR) would have [ been initiated. The SIR requires a detailed evaluation, determination of the root cause, and l initiation of corrective actions to prevent recurrence. The SIR is reviewed by the Station -
Operation Review Committee (SORC). North Atlantic is confident that if this process was ' utilized, it would have prompted a safety evaluation to be performed. As a minimum, since a likely corrective action would have been to revise the UFSAR to incorporate the site specific tornado design basis, a safety evaluation would have been required to accompany the proposed UFSAR change.
All SIRS are also reviewed for reportability by the Regulatory Compliance Department. A reportability determination is documented and reviewed by the SORC. North Atlantic is
confident that if the Regulatory Compliance Department review had been conducted as part of the SIR process, that this nonconformance would have been reported to the NRC. North' Atlantic recognizes that while SIRS can be utilized for any significant events or potentially ' reportable issues, they are typically utilized for operational events.
This may have . contributed to the lack of recognition that this issue warranted the initiation of an SIR.
.A factor contributing to the failure to implement the aforementioned Corrective Action Program was an inadequate internal Engineering Department corrective action screening procedure. At the time the tornado door issue was first identified, the Engineering Department had an internal screening process in place via Engineering Procedure 34022, , " Engineering Self Assessment Reports." While this procedure provided_a means to document l problems, assign resources to analyze the condition, and identify corrective actions to prevent recurrence, it did not adequately address operability and reportability, and it did not adequately interface with the North Atlantic Corrective Action Program.
These procedural inadequacies are highlighted by the fact that on December 12, 1990, an Engineering Self Assessment Report (ESAR# 90 004) was initiated for the tornado door issue. Th ; ESAR was not resolved in a timely manner. The Engineering corrective action , screening procedure suffered from less than aggressive implementation, and a lack of consistent utilization.
B.
Corrective Actions That'Have Been Taken and the Results Achieved The following corrective actions have been taken: 1.
North Atlantic reported this condition via a one hour verbal notification pursuant to 10 CFR 50.72(b)(1)(ii)(B) on August 27, 1992.
2.
North Atlantic followed up the one hour notification with a Licensee Event Report (LER 92 013-00) [ Reference (c)], on September 25, 1992 pursuant to 10 CFR 50.73(a)(2)(ii)(B).
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North' Atlantic supplemented this Licensee Event Report with ' LER 92-013 01 , [ Reference (d)), on November 20,1992.
Plant Barriers have been consolidated into a single design basis document. Inclu ded. in this document is a list of the barrier drawings that clearly identify the barriers which must maintain their integrity against air, water, pressure, weather, fire, or a , t combination th~ereof. Responsibility for the these barriers has been clearly assigned.
5.
North Atlantic completed a comprehensive reevaluation of plant design features-relative to tornado design criteria. This reevaluation verified that the existing plant - design, with the exception of the six doors, met the tornado design criteria specified
in the UFSAR prior to its revision. These doors have been verified to be capable of ' withstanding the worst case site specific tornado, or the affected plant areas were
verified to be capable of withstanding the corresponding depressurization.
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North Atlantic confirmed the tornado barrier envelope by a thorough inspection of the existing plant barrier drawings with subsequent confirmation by plant walkdowns.
7.
North Atlantic revised the UFSAR to include the site specific tornado' design basis.
[ . 8.
Engineering Procedure 30070, " Engineering Self Assessment Reports" (formerly Procedure 34022), has been revised to clarify responsibilities, reviews, and applicability of the procedure.
The revised procedure provides a. method for . reporting discrepancies and nonconformances, and assures that timely evaluation, and corrective and follow-up actions are taken. The vehicle utilized by this procedure to document issues, or potential issues, is the Engineering Self Assessment Report (ESAR). The ESAR is a method by which potentialissues are screened for inclusion into corrective action documents, such as the Station Information Report (SIR), or the Operational Informational Report (OIR), Procedure 30070 allows for an ESAR to be initiated for any concerns, even those that appear to be below the threshold requirements for inclusion in the North Atlantic Corrective Action Program. Irrespective of this, an ESAR need not be utilized if the-i ' issue clearly falls into the jurisdiction of the Corrective Action Program. As stated in Procedure 30070, examples of issues that may initiate an ESAR include: l ] Discovery of an as built condition that deviates or appears to deviate from the i . design basis of the plant as identified in the UFSAR.
Determination that there is a disagreement, or possible disagreement, between . . different sections of the UFSAR or other documents that define the design i basis of the plant.
- ' A design change that fails to perform its intended function after the design . change is operable.
Discovery of errors in approved engineering documents that are not addressed . or capable of being resolved by other engineering processes.
Determination that an assumption in a calculation is not appropriate.
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Determination that an engineering procedure is incorrect, provides conflicting - ' . requirements to other procedures, or provides inadequate direction.
Engineering Procedure 30070 has also been revised to include a review by the Regulatory Compliance Department if questions arise regarding reportability or applicability to corrective action documents.
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9.
The Engineering Department has conducted trdning sessions for appropriate-
department personnel (e.g., engineers, designers, managers) on'the revised Procedure __ - ! 30070.
This training explained the use of Procedure 30070, and stressed its importance for promptly identifying all engineering discrepancies to appropriate Engineering and Licensing management to ensure adequate corrective actions are taken. This training also addressed the threshold and applicability for utilizing an ES AR, and how this process related to the North Atlantic Corrective Action Program.
Additionally, this training reviewed the tornado door issue and discussed the reportability and the need to perform 10 CFR 50.59 evaluations. It should be noted that this training will be conducted in the near future for any individuals that_were unable to attend the previous training sessions.
The ESAR process has been subsequently utilized on fourteen separate occasions.
This increase in utilization attests to the acceptance of the process and the effectiveness of the training.
, . 10.
As part of incorporating guidance from Generic Letter 9118, North Atlantic previously revised the Station Operating Experience Manual (SSOE) to explicitly clarify the applicability of an #1R for nonconforming or degraded conditions. This
ensures that an SIR will be initiated for situations such as: ' A failure of a system, structure or component to conform to one of more
. applicable codes, standards, or commitments specified in the UFSAR; . As-built or as modified systems, structures or components that do not meet - UFSAR design requirements;
Operating experience or engineering reviews that demonstrate a design . inadequacy in a system, structure or component; , t Documentation required to verify that systems, structures or components . conform to NRC requirements is deficient or not available; and, A suspected error in any analyses, calculations, or testing that could affect the . ability of a system, structure or component to perform its safety or support l function.
, The aforementioned clarification of SIR applicability provides additional assurance that nonconforming conditions, such as the tornado door issue, will be fully evaluated and screened for reportability.
11.
The Manager of Engineering has been counseled by Executive Management on the need to consider the reportability aspects of nonconforming conditions.
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Corrective Actions That Will Be Taken to Prevent Recurrence - ' The following corrective actions' will be taken:
1.
In order to standardize design requirements, North Atlantic is currently implementing l a design change for the two doors (EF-400 and P-900) that were identified as not being capable'of withstanding a differential pressure of at least 1.5 psid.~ This design , change is partially implemented and these doors are currently functional as tornado - barriers.. This design change will be fully implemented in the near future.when ' additional door hardware is received. The pending work does not affect functionality .; of these doors as tornado barriers, ij 2.
Independent of the above events, North Atlantic is developing a new procedure that-l will enhance the Corrective Action Program by consolidating deficiency reporting methods and standardizing the problem evaluation and resolution' process; It is-anticipated that this procedure will utilize three corrective action vehicles, the _ l existing SIR and OIR, and a new North Atlantic Problem. Report (NAPR). The ! _ - NAPR would serve as a centralized corrective action document. It is anticipated that j North Atlantic will approve and begin implementing this revised corrective action ] procedure by June 30,1993.
! The Manager of Engineering has also requested the ESAR process be factored into the overall enhancement of the Corrective Action Program.
. 3.
A task force has been convened to review a random sample of engineering activities to identify if any other engineering issues _ exist that are required to be reported to. the NRCc This task force will be comprised of personnel from both Engineering and-l other independent non-engineering departments. It is anticipated that this review will , be completed by July 15,.1993.
! P 4.
The Engineering Department will evaluate the results of the Nuclear Safety Audit > Review Committee (NSARC) reviews of' safety evaluations to determine if there'are { any specific trends that may assist in identifying unique areas / activities that would require additional review by the Engineering Department. The first review is l scheduled to be completed by July 15, 1993.
I E.
Date When Full Compliance Will Be Achieved , North Atlantic is currently in full compliance with all regulatory requirements cited in this i Notice of Violation.
This compliance was achieved when the subject nonconforming condition was reported to the NRC, and when it was included in the UFSAR after having_ performed the requisite safety evaluation.
The corrective actions that. have been ~, implemented to-date ensure that North Atlantic's current corrective action program ist capable of preventing recurrence.
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