ML20059K522

Responds to NRC Re Violations Noted in Insp Rept 50-443/90-15.Corrective Actions:Procedure ON1090.04 Revised to Require That Whenever Containment Entry Made,Entry Logged in Action Statement Status Log

ML20059K522
Person / Time
Site:	Seabrook
Issue date:	09/14/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-90171, NUDOCS 9009240045
Download: ML20059K522 (5)

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L Mew Hampshire ,,,..m Senior Vic"o President o.id 1

Chief Operating Officer -

l-NYN.90171 September 14, 1990 United States Nuclear Regulatory Commission Washington, DL 20555 Attention: Document Control Desk

References:

(a) Facility Operating License No. NPF.86, Docket No. 50 443 (b) USNRC Letter dated August 16,1990, 'NRC Region 1 Inspection Report 50 443/90 15, J.R. Johnson to E.A. Brown

Subject:

Reply to a Notice of Violation Gentlemen:

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.

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

Very truly yours, hYk Ted C. Pelgenbaum Enclosure -

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TCP:CLB/ss!

9009240045 900914 PDR ADOCK 05000443 Q- s PDC New Hampshire Yonkee Division of Public Service Company of New Hampshire P.O. Box 300 e Seabrook, NH 03874 e Telephone (603) 474 9521 g g/ ,

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LUnited States Nuclear Regulatory Commission September 14, 1990 Attention: Document Control Desk Page two ec: Mr. Thomas T. MarQ Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Nost Dudley L NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH ' 03874 5 ,

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~ September 14, 1990  !

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ENCLOSURE 1 TO NYN 90171 REPLY TO A NOTICE OF VIOLATION e P

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New Hampshire Yankee  !

, September 14, 1990 Reolv to a Notice of Violation Violation:

During an NRC inspection from June 25 July 29,1990, a violation of NRC requirements was  ;

identified in accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR, Part 2, Appendix C. That violation is listed below: ,

Technical Specification 3.8.4.1 requires that circuit breakers feeding containmen'. power ,

distribution panels 1 ED PP 7A and 7B shall be padlocked OPEN during Mode 1 rperation (to protect the containment penetrations from an electrical fault) except for breaker closure for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> under the control of an operating procedure.

Contrary to the above, on July 21,1990, the circuit breakers feeding power distribution panels 1 ED PP 7A and 7B were found to have been in the SHUT position for 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> during  ;

Mode 1 operation.

• Resoonse: ,

New Hampshire Yankee concurs with the violation as written. That event related to this violation -

was discovered by New Hampshire Yankee and was reported to the NRC in LER 90-019 00.

In preparation for a containment entry on July 21, 1990, it was discovered that circuit breakerc 1-

• ED PP-7A and 1 ED PP 7B were closed. Investigation showed these circuit breakers had been '

closed since 2:10 a.m. on July 18, 1990. Seabrook Station Tutaical Specification (T.S.) 3.8.4.1 states that circuit breakers feeding certain listed loads inside primary containment shall be padlocked in the open position. However, there is an exception such that these circuit breakers l

may be closed for 'brief durations (not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) during plant operation ... provided this change in breaker position becomes part of the applicable operating procedure used for work inside containment'.

On this occasion, the circuit breakers 1 ED PP 7A and 1.ED-PP 7B were closed six hours and fifty minutes longer than allowed by T.S. 3.8.4.1. They were closed at 2:10 a.m. on July 18,1990, to I allow use of receptacles powered by these circuit breakers. At that time, Operations Department Procedure OP10.6, " Action Statement Tracking', did not require entering such an action into the Action Statement Status Log when the action was expected to be cleared by the end of the shift.

The Operators on shift that morning expected to open the circuit breakers before the next shift and therefore, it was not entered into this log.

Shortly after the breakers were closed, a personnel injury was reported insid the turbine building and Emergency Response Procedure ER 4.4, "Onsite Medical Emergency", was entered. The attention of shift personnel was directed to the medical emergency and the information concerning the action statement of T.S. 3.8.4.1 was not included on the shift turnover sheet (Control Room Relief Checklist), or the Action Statement Status Log. As a result, the oncoming shift was not aware that the circuit breakers were closed.

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L New Hampshire Yankee J September 14, 1990 i

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Twice the next day the procedure OX1460.01, ' Air Lock Door Seal 72 Hour Air Rate Test',

was performed. This is part of the containment close out section of procedure ON1090.04,

' Containment Entry

• and the containment exit section of procedure OS1058.01, ' Operating the Centainment Personnel Hatches". Both of these sections in these procedures also direct 1.ED PP-7A and 1.ED PP 7B to be opened.

Upon discovery of the closed circuit breakers, they were immediately opened and the length of time they had been closed was deterrained. The circuit breakers were then closed again to allow another containment entry in which they were needed.

A Root Cause Analysis and Human Performance Enhancement System evaluation have been [

perforrned. The root cause of this event has been attributed to failure to follow procedures as the primary cause. Incomplete communications, inadequate policy and difficulty in following procedures were identified as contributing factors. Although operators on the shift ,

following that which entered T.S.3.8.4.1 were unaware that the circuit breakers were closed, the procedures involved, ON1090.04, ' Containment Entry" and OS1058.01, ' Operating the Containment Personn:1 Hatches', both address T.S. 3.8.4.1 and direct the circuit breakers to be opened.

in addition, the lack of communication between shifts contributed greatly to this event. The oncoming shift knew there were people in containment but did not realize these circuit breakers were closed because this information was not in the Action Statement Status Log or on the shift turnover sheets. Few entries into containment, other than for Health Physics surveys, require these circuit breakers to be closed.

As corrective action to prevent recurrence of this event, Procedure ON1090.04 was revised to require that whenever a containment entry is made, it be entered into the Action Statement Status Log atd to require that form ON1090.04A, ' Containment Closcoui Form" be completed. This form is a checklist which includes the requirements of T.S. 3.8.4.1 as well as other required actions upon containment exit. Also, this procedure now has minimum ,

time requirements that these circuit breakers must remain open prior to being reclosed.

In addition, the importance of completeness in the Control Room shift turnover process I was stresserl by the Operations Manager in individual meetings with Shift Superintendents.

Discussions were also held with the operators regarding the basis for the Technical i Specification requirement that these breakers be locked open. The results of these I discussions indicated that operators were in fact aware that the purpose of locking these L breakers open is to ensure the integrity of the associated containment penetrations.

l The feasibility of a design change to picclude recurrence of this type of event is being evaluated. This _ evaluation is expected to be completed by October 30, 1990. The requirements that all containment entries be entered into the Action Statement Status Log will ensure that adequate configuration control exists regarding the position of these breakers. Additionally, the requirement that the breakers remain open for a minimum period prior to being reclosed will provide increased assurance of compliance with the intent of this Technical Specification and will provide an added control for the position of these breakers.

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