ML19332E751

Responds to Four Areas That Merit Addl Attention & Discussion,Per SALP Rept 50-443/87-77.Licensee Response to Confirmatory Action Ltr CAL 89-11 Provided Comprehensive Corrective Action Plan Which Addressed 890622 Test Event

ML19332E751
Person / Time
Site:	Seabrook
Issue date:	10/31/1989
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19332E745	List: ML19332E751
References
RTR-NUREG-CR-5151 CAL-89-11, CAL-RI-89-11, NYN-89133, NUDOCS 8912120069
Download: ML19332E751 (5)

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ENCLOSURE 2  ;

HN$w Hampshire- ,,. ,

Senior Vice President and Chief Operating Officer NYN 89133 -

October 31, 1989 United States Nuclear Regulatory Conunission ,

Region I '

475 Allendale Road King of Prussia, PA 19406 Attention: Mr. William T. Russell +

Regional Administrator

References:

a) Facility Operating License NPF-67, Docket No. 50-443 b).USNRC Letter dated September 26, 1989, " Systematic Assessment of Licensee Performance (SALP) Report No. 50-443/87-99",

W. T. Russell to E. A. Brown c) NHY Letter NYN-89130 dated October 27, 1989, ' Power Ascension

' testing Self Assessment" Subjects -Systematic Assessment of Licensee Performance (SALP) Report No. 50-443/87-99 4 Dear Mr. Russell' New Hampshire Yankee (NHY) has reviewed the SALP Report (Roference (b))-

and the comments made by NRC Region I personnel during the October 11, 1989 SALP meeting'. New Hampshire Yankee generally agrees with your conclusions.

.The following comments are provided to address four areas that we believe merit additional attention and discussion.

l. The NHY responses to Confirmatory Action Letter 89-11 provide a comprehensive Corrective Action Plan which addresses the events surrounding the June 22, 1989 Natural Circulation Test. The Corrective Action Plan is

, being reviewed weekly and periodic updates are provided to the NRC. New i Hampshire Yankee believes that implementation of the Corrective Action Plan

{ 4 _ will adequately address the weaknesses identified in the review of the Natural ,

i Circulation Test.

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New Hampshire Yankee is concerned about personnel errors and attention to detail. As part of the Corrective Action Plan a Human Performance Evaluation System (HPES) Program is being implemented. The HPES Program will be utilized jo-- to review the nine Licensee Event Reports submitted during the SALP period

-that were attributed to personnel error to determine if a common cause exists.

lM The results of this review will be utilized to enhance NHY programs as j@- appropriate. The Resident Inspector will be apprised of the results of our

cur review. Furthermore, the training provided to personnel on the enhanced Ei - procedure compliance policy and the Core Values and Work Ethic policy should y$ substantially improve attention to detail.

CO CL 3 New Hampshire Yonkee Division of Public Service Company of New Hampshire P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521

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. 1 United States Nuclear Regulatory Commission October 31, 1989 Attention: Document Control Desk Page 2 l

l New Hampshire Yankee agrees with the NRC that the implementation of the Operational Quality Assurance Program should be revised to provide an appropriate mixture of performance based evaluations in conjunction with the traditional, but still mandatory, compliance based evaluations. We have been shifting the emphasis of the Operational Quality Assurance Program to include the principles and concepts set forth in NUREG/CR-5151, " Performance Based Inspections," and will continue to do so. We have reviewed the Independent Review Team (IRT) Report which analyzed the Operational Quality Assurance Program (0QAP) implementation and effectiveness. Sixteen of the nineteen IRT recommendations have been implemented. The remaining recommendations will be implemented in the near future. We believe that with the completion of the recommendations our Operational Quality Assurance Program implementation will be. enhanced and the weaknesses idantified during the SALP period will be corrected.

The following minor clarification is provided regarding the Nuclear Quality Group as discussed at the SALP meeting. Specifically, the IRT

, analysis did not confirm the NRC observations regarding the quality of audit I findings, the degree to which departmental interfaces were strained, and the l duplication of efforts. Additionally, the IRT analysis concluded that NHY had l been taking action on an engoing basis to improve the OQAP implementation and I l as a result, some weaknesses were either corrected or substantially improved when the IRT review was performed. Nonetheless, NHY does not dispute the NRC conclusions that the Nuclear Quality Group should strive to improve its effectiveness. New Hampshire Yankee will continue to implement the nineteen recommendations from the IRT report as a means of improving overall program l- implementation.

New Hampshire Yankee will be performing a self assessment of the Power Ascension Testing process. A description of the self assessment and commitment to discuss the progress of the Power Ascension-Testing Program prior to exceeding 50% reactor power was provided to the NRC on October 27, 1989, [ Reference (c)).

New Hampshire Yankee will ensure that the lessons learned from the items discussed in the SALP report are clearly and effectively communicated to our personnel and incorporated in our programs. Additionally, NHY will ensure that the appropriate personnel are knowledgeable of the reason behind our operating practices, such as the basis for the 172 trip criterion in the natural circulation test.

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United States Nuclear Regulatory Commission October 31, 1989 -

Attention: Document Control Desk Page 3 Should you desire additional information regarding NHY's-actions in response to the SALP. report, please contact Mr. James M. Peschel, Regulatory ,

' Compliance Manager, at (603) 474-9521, extension 3772.

Very truly yours, bf Ted C. Feigenbaum f

Enclosure cc: United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Mr. Victor Nerses, Project Manager Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington, DC 20555 Mr. Antone C. Cerne NRC Senior Resident Inspector

'P.O. Box 1149 Seabrook, NH 03874 I

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ENCLOSURE 3 SEABROOK SALP MANAGEMENT MEETING ATTENDEES OCTOBER 11, 1989 1.' New Hampshire Yankee (NHY)

E. A. Brown, President and Chief Executive Of ficer T. C. Feigenbaum, Senior Vice President and Chief Operating Officer B. L. Drawbridge, Executive Director of Nuclear Production R. J. DeLoach, Executive Director of Engineering and Licensing N. A. Pillsbury, Director of Quality Programs G. R. Gram, Executive Director of EP and Community Relations C. W. Roberts, Security and Computer Systems Manager

2. Public Service Company of New Hampshire (PSNH)

B. R. Seymour, Security Department Supervisor J. M. Vargas, Manager of Engineering

3. U.S. Nuclear Regulatory Commission (NRC)

W. T. Russell, Regional Administrator, Region I (RI)

B. A. Boger, Assistant Director for Region I Reactors, Office of Nuclear-Reactor Regulation (NRR)

W. V. Johnston, Deputy Director, Division of Reactor Safety (DRS), RI J. R. Johnson, Chief, Projects Branch No. 3, Division of Reactor Projects (DRP), RI E. C. McCabe, Chief, Reactor Projects Section 3B, DRP, RI D. R. Haverkamp, Chief, Reactor Projects Section 4A, DRP, RI L V. Nerses, Licensing Project Manager, NRR A. C. Cerne, Senior Resident Inspector, RI N. F. Dudley, Project Engineer, DRP, RI

4. Other members of the public, press, and licensee staff attended, but did not_ participate in the meeting.

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n vmiso stans m neout. Atony commmssON Reoeow i ENCLOSURE:4 474 ALLeNDALA ROAD

..DifA.e t No . 50-443 '""**'"U"'""'*V'"'^'"

SEP 2 4 NIS  !

Public Service Company of New Hampshire '

ATTN: Mr. Edward A. Brown i

President and Chief Executive Officer New Hampshire Yankee Division i

Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Repor_t No. 50-443/87-99 ,1 The NRC Region I SALP Board has reviewed and aev'luated the performance of acti-vities at the Seabrook Nuclear Power Plant Unit No. I for the period of August 3,1987 - June 30,1989.

.The results of the assessment conducted on August 23, 1989 are documented in the enclosed initial SALP Report. We will contact you shortly to schedule a meeting to discuss this assessment.

. At the to SALP meeting, you should be prepared to discuss our assessment and your I plans improve performance.

This meeting is intended to be a dialogue where-in any.ccmments you may have regarding our report may be discussed. Addition-  ;

ally, you may provide written comments within 20 days after the meeting.  ;

This report has been placed in the Public Document Room. Following our meeting and receipt of your response, the final SALP Report and your responses will be placed in the Public Document Room.

Your cooperation with us is appreciated.

Sincerely, l

William T. Russell Regional Administrator

Enclosure:

Systematic Assessment of Licensee Performance (SALP) Report No. 50-443/87-99 i

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.. SEP t o INS Pubite Service Company of 2

,' New Hampshire cc w/ enc 1:

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 D. E. Moody,15tation Manager, NHY P. W. Agnes, Jr., Assistant Secretary of Public Safety, Canmonwealth of Massachusetts Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC) i l NRC Resident Inspector

!: State of New Hampshire .

Commonwealth of Massachusetts /

Seabrook Hearing Service List I

Chairman Carr L Comm'issioner Roberts .

L Commissioner Rogers Commissioner Curtiss K. Abraham, PAO, RI (28 copies) l l ,

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5+ab soA ' Service Hearing list l'

Thomas Dignan, Esc E. Tupper Kinger, Esq.

I. John A. Ritscher, Esc. Assistant Attorney General L Ropes and Gray Office of Attorney General 225 Franklin Street. 208 State House Annex Boston, Massachusetts 02110 Concord, New Hampshire 03301 Mr. Bruce Beckley, Project Manager George D. Bisbee, Esquire New Ha'r.cshire YarLee Assistant Attorney General P.O. Box 330 Office of the Attorney General Manchester, New Hampshire 03105 25 Capitol St eet ,.

C,oncord, New Hampshire 03301 Dr. Murray Tye, Presioert Diane Curran, Esquire Sun Valley Associat'.or Harmc-n and Weiss 209 Summer Street 2001 5 Street, N.W.

Ha,erhill, Massachusetts 02:35 Washington, D.C. 20009 Robert A. Backus, Esosire D. Pierre G. Cameron, Jr. , Esquire Backus, Meyer anc Sele :- General Counsel 116 Lowell Street Public Service Company of P. O. Box 516 New Hampshire Manchester, New Hampsnire 03106 Manchester, New Hampshire 03105 Phillip Ahren, Esco rt. Mr. Alfred Sargent, Chairman {

Assistant Attorney General Board of Selectmen 1 Office of the Attorney General Town of Salisbury, MA 01950 State House Station #6 Augusta, Maine 04333 l Steven Oleskey, Esquire Senator Gordon J. Humphrey l

. Office of the Attorney General ATTN: Mr. Thomas Burack ',

One Asburton Place U. S. Senate >

P. O. Box 330 531 Hart Senate Office Building Boston, Massachusetts 02108 Washington, D.C. 20510 l Ms.' Diana P. Randall Mr. Calvin A. Canney, City Manager 70 Collins Street City Hall Seabrook, New Hampshire 03874 126 Daniel Street Portsmouth, New Hampshire 03801 Richard Hampe, Esquire j New Hampshire Civil Defense Agency  !

107 Pleasant Street' '

Concord, New Hampshire 03874 l

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i Board of Selectmen Mr. Owen B. Durgin, Chairman itFD Dalten Roac Darnan. Board of Selectmen Brentwooc, New Hampshire 03833 Town of Durham Durham, New Hampshire 03824 Ms. Suzanne Breiseth Administrative Judge Town of Hampton Falls Jerry Harbour Drinkwater Road Atomic Safety and Licensing Board Hampton Falls, New Hampshire 03844 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Guy Chichester, Chairman Chairman, Board of Selectmen Rye Nuclear Intervention Committ.ee Town Hall clo Rye Town Hall South Hampton, New Hampshire 03827 10 Central Road Rye, New Hampshire 03870 Me , Angie Hachiros. Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Comm.

for the Town of Newbury 825 North Capitol Street, N.E.

25 High Poad Room 8105 '

Newbury, Massachusetts 01950 Washington, D.C. 20426 Ms. Rosemary Cashman, Chairman Mr. R. Sweeney Boaro of Selectmen New Hamp; hire Yankee Division Towa, of A esbury Public Service Company of ,

Town Hall New Hampshire l Amesbury, Massachusetts 01913 Suite 610, Three Metro Center l Bethesda, Maryland 20814 Honorable Peter J. Matthews Mayor, City of Newburyport City Hall

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Newburyport, Massachusetts 01950 Administrative Judge Administrative Judge Alan 5.-Rosenthal, Chairman Thomas S. Moore, Esquire l Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal l

' Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Howard A. Wilber. Emmeth A. Luebke '

Atomic Safety and Lici,nsing Appeal Atoalc' $afety and Licensing Board

, Board U.S. Nuclear Regulatory Commission i U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D.C. 20555 l

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Edwin J. Reis, Esquire H. Joseph Flynn Esc.

Office of the Gene al Counsel . Assistant General Counsel U.S. Nu: lear Regulatory Commission Washington,-D.C. 20555 Federal Emergency Management Agency 500 C. Street, S.W.

Washington, D.C. 20472 Edward A. Thomas Carol 5. Sneider, Esq.

Federal Emergency Management Agency Assistant Attorney General 442 J. W. McCormack (POCH) Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place, 19th Floor Boston, Massachusetts 02106 Paul McEachern, Esq. Richard A. Haaps, Esq Shatnes and McEachern Haaps and McNicholas 25 Maplewood Avenue Portsmouth, New Hampshire 03801 35 Pleasant Street Concord, New Hampshire 03301 J. P. Nadeau Allen t.ampert Boarc o.f Selectmen Civil Defense Director  !

10 Central Street Town of Brentwood Rye, New Hampshire 03870 20 Franklin Street Exeter, New Hampshire 03833 William Armstrong Sandra Gavutis, Chairman Civil Defense Director Board of Selectmen Town of Exeter RFD #1, Box 1154 10 Front Street Kensington, New Hampshire 03827 Exeter, New Hampshire 03833 Anne Goodman, Chairman Jerard A. Croteau, Constacle Board of selectmen 82 Beach Road 13-15 Newmarket Road P. O. Box 5501 Durham, New Hampshire 03824 Salisbury, Massachusetts 01950 Stanley W. fnowles, Chairman Judith H. Mitzner

Board of Selectmen Silverglate, Gertner, Baker Fine, P. O. Box-710 Good, and Mitzner

' North Hampton, New Hampshire 03862 88 Broad Street l Boston, Massachusetts 02110 Norman C. Kantner Gary W. Holmes, Esq.

t Superintendent of Schools Holmes and Ellis School Administrative Unit No. 21 47 Winnacunnet Road A1uani Drive .

Hampton, New Hampshire 03842 Hampton, New Hampshire 03842 l l

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Charles-P.. Graham, Escuire Mr. . Robert Carrigg, Chairman McKay, Murphy.anc Grenam Board of Selectmen 100 Main Street Town Office-DAmesbury, Massachusetts 019;3 Atlantic Avenue North Hampton,'New Hampshire 03870 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801 -

i Adjudicatory File 1

.~ Atomic' Safety and Licensing Board Panel-Docket ,

U.S. Nuclear Regulatory Commission Washington, DC 20555 r

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