ML20044A663

Responds to NRC 900524 Ltr Re Violations Noted in Insp Rept 50-443/90-10.Corrective Actions:Maint Group Instruction Issued Describing Valve Verification When Valves Not Covered by Procedure & Procedures Written Re Monitoring Skids

ML20044A663
Person / Time
Site:	Seabrook
Issue date:	06/25/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-90130, NUDOCS 9007020027
Download: ML20044A663 (5)

Text

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~ New Hampshire Ted C. Feigenboum .  !

Yan Senior Vice President and Chief OperatinDOfficer NYN- 90130 -

June 25, 1990 i

United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk'

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References:

(a) Facility Operating License No. NPF-86, Docket No. 50-443 l (b) USNRC Letter _ dated May 24, 1990 " Inspection Report 50-443/90-10,' J.R. Johnson to E.A. Brown

Subject:

Reply to a Notice of Violation' )

Centlemens  !

i In accordance with_the requirements of the' Notice'of Violation contained in Reference (b), the New Hampshire Yankee response to the cited violation-is provided as Enclosure 1.

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.Should you have any questions-concerning our response, please contact s Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474-9521,- l extension 3772. I i

Very truly yours, i

l',h &

Ted C. Fei enbaum I l

TCP/CLB:jt/ )

Enclosure ,j

cci Mr. Thomas T. Martin I l

Regional Administrator i United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

, i i Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box 1149 Seabrook,:NH 03874  ;

9007020027 900625 9 [

PDR ADOCK 05000443 ,

Q PDC .i yf g_

i p,vfg New Hampshire Yankee Division of Public Service Company of New Hampshire P.O. Box 300

• SeabrookiNH 03874

• Telephone (603) 474 9520  !

a

New Hampshire Yankee June 25. 1990

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i ENCLOSURE .1. TO NYN-90130 h REPLY TO A NOTICE OF VIOLATION r

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a New Hampshire Yankee' June 25, 1990 Ren1v to a Notice of Violation Violation -t During an NRC inspection from Apr11.10 - May 13, 1990, a violation of'NRC requirements was identified in accordance with the "Ceneral Statement of Policy.

and Procedure for NRC Enforcement Actions," 10 CFR, Part 2, Appendix C. That  ;

violation is listed below:

Technical Specification 6.7.1.a requires that the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2 February 1978, be established and implemented. Regulatory Guide 1.33 Revision 2,1 February 1978, Appendix A specifies procedures for energizing,'startup, operation, shutdown, and changing modes of operation of PWR (pressurized water reactor) nmin steam systems (Section 3.1), for PWR stack and ventilation air moni-toring (Section 7.c), and for maintenance that can affect the performance of safety-related equipment (Section 9.a).

Contrary to the above, as of April 3, 1990,-no procedure had been ,

established for operation of an isolation valve for turbine i first stage pressure instrument PT-506, which provides an input signal to the Reactor Protection System. ' Closure of the isola- i tion valve rendered PT-506 inoperable when its operability was required.

Contrary to the above, as of January 1, 1990, no procedure had been established covering tho' required position'for. purge-isolation valves for.the wide range gas monitor in the? station-ventilation et.ack system. .Mispositioned purge isolation valves rendered the monitor inoperable when it was required to be operable.

Contrary to the above, about April 4, 1990, improper implemen-tation of procedure steps for restoring the main turbine to proper operating line-up af ter maintenance resulted in a turbine trip during turbine startup.

Response

Each of the cited examples of this violation were related to configuration-  !

control. However, each event had a unique root cause. The root cause of the violation's first cited example was determined to be the failure to identify and.

control a second instrument isolation valve by either procedure or valve line.

up. After the incident, a complete walkdown of all'the vendor-supplied. rack--

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New Hampshire Yankee June 2S, 1990 mounted instruments was performed. Corrective actions implemented or planned to preclude recurrence include: 1ssuance of a Maintenance Group Instruction ,

(MGI) for required reading which describes valve verification when the valves are not covered by a procedures discussion of the same topic at department.

meetings: changing all calibration procedures to include verification of the-second process isolation valve where applicable; changing Rep-titive Task Sheets (RTSs) involving technical specification protection instrument valve:line-ups to include all valves associated with the instruments and lock-wiring open all second process isolation valves. 'The last of these actions, the calibration-procedures, is scheduled to be completed by September '28,1990.

The second cited example, involving the Wide Range Gas Monitor .was due to the.

inability to accurately determine the required position of purge air line valves. In response to this event, the valves involved were added to Procedure OS1090.05, " Component Configuration Control," and additional requirements for i determining the required position of equipment during tagging order restoration were added to procedure MA 4.2, " Equipment Tagging and Isolation."

The root cause of the third event, involving a turbine trip, was determined'to be improper action and lack of attention in the performance of a-system readi-ness review. As discussed in reference (b), corrective actions were identified and tracked on the Integrated Commitment Tracking System. Short. term corrective actions were completed and included the removal of system test engineers as Test Directors for testing of systems under their cognizance Station Manager's approval for restarting major equipment with troubleshooting in progressi management's presence onsite for starting major equipments additional management review of open work packages increased formality of maintenance technician turnovers: dissemination of lessons learned to plant personnels and revisions to the work control program. Long term actions include revising the Operations Management Manual and the Station Management Manual to provide additional guidance regarding the restart of activities when troubleshooting has not determined the cause and to provide additional control of contractors in troubleshooting. These actions are scheduled to be completed by September 1, 1

1990.

Due to our concerns regarding configuration control as a. result of these events,. .

other' improvements were considered. The radiation monitoring skids were iden- i tified as an area requiring further enhancements. Therefore, procedures are being developed to address each radiation monitoring skid as a single unit.

This will require the individual involved to consider the-entire radiation  !

monitoring skid and all associated components when completing a restoration valve line-up. This action is expected to be completed by August 3, 1990.

We will be conducting an evaluation of our total Work Control Program for configuration control considerations. Input from our Power Ascension Test Program Self Assessment Team will be used as part of this evaluation. One of i

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New Hampshire Yankee June 25, 1990 ,

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'I our employees, who is currently on loan to the Institute of Nuclear Power l Operations, has had extensive maintenance evaluation experience. He will be I returning to New Hampshiro Yankee at the end of the month. He will be a member of the team that will review our Configuration Control Program and should bring a valuable industry insight to this review. We expect to complete this review.

by July 30, 1990.

The walkdowns conducted in response to the first cited example, which was the most recently occurring event,-ensured full compliance and verified that the valves within the scope of the' review are positioned correctly. New Hampshire Yankee believes that with the actions discussed herein, configuration control.at Seabrook Station is effective.