ML20058M276

Responds to NRC Re Violations Noted in Insp Rept 50-443/93-13.Corrective Actions:Procedure Ma 4.2,MA 4.3 & Ma 4.5 Will Be Reviewed & Revised as Needed

ML20058M276
Person / Time
Site:	Seabrook
Issue date:	09/30/1993
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-93132, NUDOCS 9310050020
Download: ML20058M276 (7)

Text

j P.O. Box 300 Od' Seabrook, NH 03874 '

Telephone (603)474-9521 Facsimile (603)474-2987 i Energy Service Corporation Ted C. Feigenbaum l Senior Vice President and  !

Chief Nuclear Officer NYN- 93132 ..

I September 30,1993 United States Nuclear Regulatory Commission Washington, D.C. 20555 i Attention: Document Control Desk

References:

(a) Facility Operating License No. NPF-86, Docket No. 50-443 -  !

(b) USNRC Letter dated August 31,1993, " Inspection Report No. 50-443/93-13," A.

R. Blough to T. C. Feigenbaum i

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 Energy 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, 3 Regulatory Compliance Manager, at (603) 474-9521, extension 3772.

Very truly yours, Ted C. Feige aum .

TCF:JES/jes Enclosure L

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.,.,,,.a member of the Northeast Utilities system 9310050020 930930 PDR ADOCK 05000443

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United St tes Nuclear Regulatory Commission September 30,1993 Attention: Document Control Desk Page two cc: Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission -

Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate 1-4 Division of Reactor Projects  ;

U.S. Nuclear Regulatory Commission  ;

Washington, DC 20555 l l

Mr. Noel Dudley ,

NRC Senior Resident Inspector r P.O. Box 1149 j Seabrook, NH 03874 i

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Nonh Atlantic September 30,1993 ENCLOSliRE 1 TO NYN-93132 6

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RF. PLY TO A NOTICE OF VIOLATION In a letter dated August 31,1993 [ Reference (b)], the NRC transmitted to North Atlantic Energy Service Corporation (Nonh Atlantic) a Notice of Violation identified by the resident staff during the inspection period of June 15 through July 26,1993. This violation was issued for two separate examples where station procedures were not implemented as required. In accordance with the instructions provided in the Notice of Violation, the North Atlantic response to this violation is provided below. Note that two levels ofcorrective action are being implemented in response to this violation; those speci6c to the circumstances of the individual occurrences cited in the examples below, and those to address the reduction of personnel errors on a generic basis.

I. Violation Seabrook Station Technical Specification Section 6.7.1 requires that procedures shall be implemented covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A in Regulatory Guide 1.33, Step 1.d specifies that an administrative procedure for procedural adherence be established and implemented. The Seabrook Station Management Manual Section 5.2 specifies that all personnel perfonning work shall comply with written instructions.

The following are two examples where procedures were not implemented as required or delineated in the respective procedure section listed below:

a. Maintenance Procedure MA 3.1, Step 4.1.2 specifies that when the scope of the work request changes after the work has been released, the person making the change shall receive concurrence from the system engineer, the quality control inspector, and the unit shift supervisor.' The changes shall be documented on the work request.

Contrary to the above, when perfonning maintenance on containment isolation valve SB-V-9 on June 17,1993, maintenance workers identified the need for and installed an electrical jumper without performing a work request scope change. Consequently, on June 18, 1993, the valve inadvenently closed during restoration from the work.

b. Maintenance Procedure LS0564.19, Step 8.14.2.4 specifies to increase the torque on the pipe plug until the limit switch leser on main steam isolation valve (MSIV) 88 is tight.

Contrary to the above, on October 22,1992, maintenance workers signed that Step 8.14.2 had been completed when the pipe plug had not been tightened. Consequently, on May 20,1993, MSIV-88 failed its routine operability surveillance test.

This is a Severity Lesel IV siolation (Supplement 1).

11. Response to the First Ihample Cited in the Violation A. Reason for the Violation North Atlantic does not contest any portion of this violation. The reason for this violation is described below.

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Ba'ckuround On June 18,1993, maintenance work had been completed on the limit switch for SB-V-9, which is one of two pneumatically operated Steam Generator Blowdown containment isolation valves for the "A" steam generator. During the restoration sequence, failure to maintain continuity to the valve's solenoid caused SB-V-9 to fail closed. To perform the necessary work on the limit switch for SB-V-9 the valve was danger tagged. The tagging order included tagging the slide links for the limit switch seal-in circuit and tagging the slide links for UL-3 status light indication. Thejumper that was installed to prevent the valve l from going closed was referenced in the tagging order but installed in accordance with procedure MA 4.5,~ j

• Configuration Control During Maintenance and Troubleshooting." Maintaining SB-V-9 in the open position allowed Steam Generator Blowdown to continue and did not inhibit the automatic isolation feature of this valve. Maintaining Steam Generator Blowdown is advantageous since it assists in maintaining i secondary water chemistry by continuously removing and processing water from the steam generators.  ;

After completion of the work, and under the direction of the 1&C supervisor, the I&C technicians l prematurely removed thejumper in accordance with MA 4.5 prior to the restoration of the tagging order. -l The tagging order had been released, but not completed and therefore, the slide links were still open. j When thejumper was removed, SB-V-9 tripped closed, i Root Cause  !

The root cause of this event is personnel error. The I&C supervisor and the system engineer failed to i establish and document a restoration sequence for this valve in the work package. This should have been ,

accomplished via a scope change to the work request.

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B. Occurrence Specine Corrective Actions That Have Been Taken [

Co rective actions that have been taken for this occurrence are listed below.

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1. North Atlantic completed a Station Information Report (SIR) to evaluate this condition and develep corrective actions.

2. The North Atlantic I&C supervisor involved with this occurrence completed a Stop, Think, Act, ,

Review (STAR) self verification worksheet. i l

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3. The North Atlantic Operations Department discussed this occurrence with Control Room personnel. Similarly, the Maintenance, and System Support Departments have discussed this ,

occurrence with maintenance personnel, and System Support Engineers, respectively.

C. Occurrence Speci6c Corrective Actions That Will Be Taken to Prevent Recurrence The following corrective actions will be taken:

1. Procedure M A 4.2, " Equipment Tagging and Isolation," M A 4.3, " Temporary Modi 0 cations," and M A 4.5, " Con 0guration Control During Maintenance and Troubleshooting," will be reviewed and revised, as necessary, to ensure adequate control ofjumpers during maintenance activities. It is anticipated that this review will be completed by December 31,1993.

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'l a l lif. Response to the Second Examnie Cited in the Violation ,

A. Reason for the Violation - l North Atlantic does not contest any ponion of this violation. The reason for this violation is described i below. i Background  ;

North Atlantic replaced the MSIV limit switches during the second refueling outage using two Repetitive .;

Task Sheets. Prior to the start of the work, the non-applicable steps of the procedure were marked "Not Applicable." This inadvertently included step 8.14.2 for torquing the limit switch lever aim pipe plugs. l During the replacement of the switches, each switch was match marked by the technicians, removed, and replaced with new switches. The lever arms were assembled to the new switches with the understanding  !

that the final torque of the pipe plugs would be perfonned after perfonning the stroke test of the valve. .

Step 8.14.2 was signed off based on the general sign off &scription rather than reviewing the actual  :

detailed step which included tightening of the pipe plug. As a result, the pipe plugs were never properly  !

torqued. Subsequently, on May 20, 1993, while perfonning OX1430.02, "MSIV Quanerly Test  !

Procedure," on MSIV-88 train A test, the 10% closed position indication did not extinguish when the ,

valve returned to the open position. ,

Root Cause f Six causes were identified to have contributed to this occurrence.

1. Technicians signed procedure steps based on the general sign off description rather than reviewing the actual detailed step which included tightening of the pipe plug.

2. The work procedures did not reflect the sequence of steps needed to complete the job.

3. Involvement of many workers including contract workers lead to a lack ofjob continuity. .

4. The multiple procedures necessary to complete the job did not easily transition from one to another, and back again.

5. The procedure step to torque the limit switch lever arm pipe plugs was inadvertently marked as  !

not applicable before the work began. l 1

6. The procedures for limit switch replacement did not contain adequate instructions. j B. Occurrence Snecific Corrective Actions That flave Been Taken l Corrective actions that have been taken for this occurrence included the following:

1. North Atlantic completed an Operational Information Report (OIR) to evaluate this condition and develop corrective actions. j l

2. All MSIV limit switch pipe plugs and lever arm adjustment screws were inspected for adequate tightness. Those pipe plugs that were found to be loose were tightened per the torque l requirements.

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l C. Occurrence Specific Corrective Actions That Will Be Taken to Prevent Recurrence l

1. An MSIV procedure will be developed to encompass all the individual procedures involved with this occurrence. It is anticipated that this procedure will be developed by December 31,1993.

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2. The NAMCO limit switch procedure will be enhanced to include switch removal, replacement, and retest sections. It is anticipated that this procedure revision will be developed by October 15, l

1993.

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3. Other I&C Department procedures will be reviewed to determine if an all inclusive procedure is necessary. It is anticipated that the review will be completed by October 15, 1993, and any i required procedures will be developed by February 15, 1994.

4. North Atlantic will review this event with I&C personnel at the next continuing training session.  ;

11 is anticipated that this will be completed by October 31,1993.

i IV. Additional Corrective Actions to Address Personnel Errors A. Personnel Error Response Team In response to an unacceptably high frequency of personnel error during 1993, the Station Manager requested a special committee to determine the root cause of the errors and to develop recommendations ..

to address the causes. In response to this request, a five member Personnel Error Response Team (PERT) l was formed. The team members represented various departments, which provided a cross disciplinary I approach to ensure a broad perspective in defining issues.

The team applied both quantitative and qualitative analysis in considering incidents involving personnel i error. The quantitative approach consisted of using North Atlantic's Methodology for Event Reduction l Evaluation to analyze five incidents involving personnel error The analyses led to the identification of  ;

eight issues. Each issue was identified as belonging to one of three categories identified as cultural,  !

programmatic, and management oversight. The team developed a total of twenty recommendations relative to the eight issues. North Atlantic is currently in the process of developing corrective actions to - ,

address these recommendations. The details of the corrective actions and the schedule for completion will i be provided in a Management Meeting between Region I and Nonh Atlantic management as addressed  ;

in the cover letter to inspection Report No. 50-443/93-13 [ Reference (b)].  ;

13. Procedure Compliance Traininn Prior to the events cited in the violation, North Atlantic had developed and initiated supplemental training '

on procedure compliance. This training emphasizes management's expectations with regard to procedure compliance and addresses the processes to be followed if procedures are found to require correction or  ;

revision. This training has been provided to the majority of the station personnel. It is anticipated that l this training will be completed by the October 31,1993.  !

V. Date When Full Compliance Will Be Achieved l

Nonh Atlantic is currently in full compliance with all regulatory requirements cited in this Notice of Violation.  ?

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