IR 05000443/1997008

Refers to Insp Rept 50-443/97-08 on 971207-980131 & Forwards Nov.Violations Re Failure to Promptly Identify Conditions Adverse to Quality at Facility

ML20217L034
Person / Time
Site:	Seabrook
Issue date:	04/01/1998
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
Shared Package
ML20217L039	List: IR 05000443/1997008 ML20217L063
References
50-443-97-08, 50-443-97-8, EA-98-073, EA-98-73, NUDOCS 9804070358
Download: ML20217L034 (5)

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%*****f. April 1, 1993 EA 98-073 Mr. Ted Executive Vice President and Chief Nuclear Officer Seabrook Station North Atlantic Energy Service Corporation c/o Mr. Terry L. Harpster Post Office Box 300 Seabrook, New Hampshire 03874 SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report No. 50-443/97-08)

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Dear Mr. Feigenbaum:

This letter refers to the. NRC inspection conducted between December 7,1997, and January 31,1998, at the Seabrook station, the results of which were discussed with you during an exit meeting on February 12,1998. During the inspection, apparent violations of NRC requirements were identified, as noted in the inspection report 'ent to you wiLh our htter, dated February 27,1998. On March 24,1998, a Predech@ - Enforcement Conference (conference) was conducted with you and members of yv .+tf to discuss the reh%d violations, their causes, and your corrective actions.

Based on the information developed during the inspection, and the information provided daring the conference, three violations of NRC requirements are being cited and are set forth in the U enclosed Notice of Violation (Notice). All three violations involve the failure to promptly identify and/or correct conditions adverse to quality at the facility. Collectively, these violations represent a significant lack of attention toward licensed responsibilities since opportunities existed, in each case, to correct these adverse conditions sooner; yet appropriate actions were not taken. At the enforcement conference, you acknowledged these concerns, noting that a complacent attitude may have contributed to these failures. You also recognized the need for greater operational focus, and more aggressive follow up, by staff at the station.

In one case, in November 1996, your staff identified potential leakage (in the form of boric acid residue extemal to the fire protection pipe wrap material) from stainless steel piping in the vicinity of the "B" Residual Heat Removal pump suction relief valve (RC-V-89). However, this condition was not promptly corrected, despite opportunities to do so. Specifically, the pipe wrap material was not removed until December 5,1997 to identify the source of the residue, even though several individuals, including engineers, supervisors, and maintenance and health

. physics technicians, had been aware of this condition. In addition, while your staff had made plans to remove insulation and inspect this section of piping during the June 1997 refueling outage, this work activity did not occur. Although a system engineer recognized that the

' piping had not been inspected, on or about June 15,1997, and informed his supervisor, no adverse condition report was generated, and actions were not taken to remove the insulation and inspect the pipe prior to the start-up on June 26,1997.

9804070358 980401 PDR ADOCK 05000443

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North Atlantic Energy Service 2.

Corporation in another case, the control building air conditioning (CBA) compressors, used to cool critical instruments within the control room followbg a postulated accident, were degraded resulting in multiple compressor failures since 1993, including some instances when both subsystems were inoperable at the same time. However, action was not taken until December 1997 to address the root causes for the compressor failures, despite prior opportunities to address this problem. Specifically, your staff completed an engineering evaluation in 1994 (to address a 1993 CBA compressor failure), and that evaluation resulted in development of a design change request to correct the root causes for the compressor failure. Those causes included: loss of bearing lubrication caused by refrigerant contamination of the lubricating oil; and/or refrigerant slugging to the cylinder piston assembly. Although the modification was scheduled to be implemented in the third quarter of 1996, it was delayed several times and not

' implemented until after another CBA compressor failure on December 16,1997. In each of the prior cases when the compressors failed, your corrective actions focused on component ,

replacement rather than correcting the root causes of the failures.

In the third case, in November 1997, the NRC observed that a caution tag on the control switch for the Positive Displacement Charging Pump indicated that the pump could trip after starting due to an oil leak from the pump's sensing line. Although this leak challenged the

. reliability of the pump, a component important to safety, your plans did not include repair of the leak until after installation of a modification to relocate the pressure switch. However, in October 1997, the plans for the modification were canceled without resolving this adverse condition.

Failure to correct these conditions sooner indicates a decline in your performance with respect to analysis of root causes of problems, as well as implementation of appropriate corrective action. This concern was previously highlighted in my January 23,1998, letter transmitting the latest SALP report to you. In that report, the NRC noted that operators and engineering personnel did not aggressively pursue resolution of degraded conditions on equipment important to safety. Given the number of examples of this problem, despite opportunities to correct the conditions, the violations represent a significant regulatory concern. Therefore, these violations have been classified in the aggregate as a Severity Level 111 problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000is considered for a Severity Level lil problem. Your facility has not been the subject of escalated enforcement actions within the last 2 years. Therefore, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty. Credit is warranted for corrective action because, at the time of the enforcement conference, the actions taken to improve the corrective action process were considered prompt and comprehensive. Your corrective actions included, but were not limited to:(1) creation of a multi-disciplined team to look for problems at the facility; (2) retention of a contractor to address the broader issues of i improved root cause analysis and corrective actions; (3) conduct of meetings with all employees to communicate management expectations regarding these issues and the need for improved operational focus; (4) addition of.an engineer to each shift to assist with ensuring appropriate configuration control; (5)' retraining of staff; (6) lowering of the threshold for

. classifying equipment as degraded.

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North Atlantic Energy Service 3 Corporation Therefore, in view of these corrective actions, I have been authorized, after consultation with the Director, Office of Enforcement, to not propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

In addition to these three violations, the inspection report identified another apparent violation related to your opening of the safety injection test header return isolation valve SI-V-131 (between August 6 and 8,1997, and between October 21,1997 and December 6,1997) for the purpose of redirecting reactor coolant isolation check valve leakage to the primary drain tank to prevent the undesired boron dilution of the Si accumulators. The NRC previously issued to you a Notice of Violation on September 23,1997, for deviation from procedural requirements, without proper approval as required by the technical specifications. Since your subsequent analysis indicated that this action did not render the 'A' Safety injection pump inoperable, no further violation is being cited.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, and its enclosure will be placed in the NRC Public Document Room (PDR).

Sincerely, Hu ert J. Miller f, Regional Administrator Docket No. 50-443 License No. NPF-86 Enclosure: Notice of Violation

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North Atlantic Energy Service - 4 Corporation cc w/ encl:

B. Kenyon, President - Nuclear Group J. Streeter, Recovery Officer - Nuclear Oversight W. DiProfio, Station Director - Seabrook Station R. Hickok, Nuclear Training Manager - Seabrook Station D. Carriere, Director, Production Services L. Cuoco, Senior Nuclear Counsel W. Fogg, Director, New Hampshire Office of Emergency Management D. McElhinney, RAC Chairman, FEMA Rl, Boston, Mass R. Backus, Esquire, Backus, Meyer and Solomon, New Hampshire D. Brown-Couture, Director, Nuclear Safety, Massachusetts Emergency Management Agency F. W. Getman, Jr., Vice President and General Counsel - Great Bay Power Corporation R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts Seacoast Anti-Pollution League D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire S. Comley, Executive Director, We the People of the United States

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W. Meinert, Nuclear Engineer

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a North Atlantic Energy Service Corporation

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DISTRIBUTION:

PUBLIC SECY CA LCallan, EDO AThadani, DEDE -

JLieberman, OE HMiller, RI '

FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators Rl, Ril, Rlli, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP HBell,- OlG TMartin, AEOD OE:Chron OE:EA DCS-NUDOCS DScrenci, PAO NSheehan, PAO Nuclear Safety Information Center (NSIC)

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