ML20082C318

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Responds to NRC Re Violations Noted in Insp Rept 50-443/91-09 on 910423-0527.Corrective Actions:Review of Operating Procedures for Procedural Inadequacies & Training Conducted
ML20082C318
Person / Time
Site: Seabrook 
Issue date: 07/15/1991
From: Feigenbaum T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-91112, NUDOCS 9107180323
Download: ML20082C318 (4)


Text

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New Hampshire Ted C. Feigenbasm Y3.n e

Presdent and Chief Esecutive Olticer NYN.91112 July 15,1991 United States Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Document Control Desk

References:

(a)

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

USNRC Letter dated June 14, 1991, " Nit C Region i Inspection 50 443/91-09 (04/23/91 05/27/91)," J.C. Linville to T.C. Feigenbaum

Subject:

Reply to a Notice of Violation Gentlemen:

In accordance with the requirements of the Notice of Violation contained in Reference (b), the New Hempshire 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,

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Ted C. Feig nbaum Enclosure TCF: A LL/ssl 9107180323 9107 p l

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100032 New Hampshire Yankee Division of Public Service Company of New Hampshire j j' P.O. Box 300

  • Seabrook, NH 03874
  • Telephone (603) 474-9521

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(Jnited States Nuclear Regulatory Commission July 15,1991

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Attention:

Document Control Desk Page two cc:

Mr. Thomas T. Martin Regional Administrator i

United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prunsia, PA 19406 Mr. Gordon Edison, f. Project Mgr.

Project Directorate 13 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington DC 20555 Mr. Noel Dudley NRC Resident inspector P.O. Box 1149 Seabrook, NH 03874

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1 STATE OF NEW llAMPSHIRE i

. Rockingham, ss.

July 15,1991 I

Then personally appeared before me, the above named Ted C. Feigenbaum, being duly sworn,. did state that he is President & Chief Executive Officer of the New Hampshire Yankee Division of Public Service Company of New Hampshire,. at he is duly authorized to execute and file the foregoing information in the name and on the behalf of New Hampshire Yankee Division of the Public Service Company and that the statements therein are true to the best of his knowledge and belief.

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Tracy A. DeCredico, Notary Public j

My Commission Expires: October 3,1995

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New Harupshire Yankee

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ENCLOSURE TO NYN-91112 1

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1 REPLY TO A NOTICE OF VIOI.ATION a

Violation:

During NRC inspection from April 23 - May 27, 1991, a violation of NRC requirements was identified.

In accord m with the " General Statement of Policy and Procedure for NRC Enforcement Actions, i

'R Part 2, Appendix C, that violation is cited below:

Technical Specification 3.6.3 requires that inoperable containment isolation valves be isolated from each affected penetration by use of at least one deactivated automatic valve which is secured in the isolation position.

Contrary to the above between April 5-16, 1991, Containment isolation Valve SI-V61 wza inoperable but not isolated from each affected penetration by use of at least one deactivated automatic valve secured in the isolation position.

This is a Severity Level IV violation (Supplement I).

Resoonse:

New Hampshite Yankee (NH'J) has determined that the cause of this violation was an inadequate piocedure. Proce dure OS1005.05, S1 System Operation, was inadequate in that it did not identify valve SI-V61 as a normally locked closed valve. A contributing factor to this violation was the failure of the auxiliary operator to notify the control room that the valve being manipulated, SI-V61, was a locked valve. Consequently, on April 5,1991 the control room operator did not recognize that a lacked valve was out of positic.n and therefore failed to verify SI-V61 cload as required by Procedure OS1005.05. He also did not realize that the Limiting Condition for Operation requirements for Technical Specificadon 3f.3, Containment Isolation Valves, were not satisfied.

Upon discovery that SI-V61 was open on April 16, 1991, it was immediately locked closed. New Hampshire Yankee's short term corrective action also included the revision of Procedure OS1005.05 to explicitly identify the requirements to " UNLOCK and OPEN SI-V61" and to " LOCK CLOSED S I-V61."

The explicit identification of these procedural requirements will ensure that NHY's normal practice of notifying the control room operators of the manipulaticn of a locked valve will take place and that such manipulations will be 4

logged. New Hampshire Yankee has also conducted training for its control room personnel regarding proper communication with respect to repositioning locked valves.

New Hampshire Yar.kec's long term corrective actions will include a review of other operating procedures for similar procedural inadequacies. This review and any required procedure revisions will occur during the normal procedure review cycle and will be completed by July 1993.

New H atopshire Yankee will also develop technical guidance addressing the appropriate actions to be taken when manipulating valves (e.g. test, vent and drain valves) within the containment penetration pressure baundary. This action is expected to be completed by July 31, 1991. Additionally, NHY will evaluate the design and location of the pressure instruments downstream of SI-V61 to determine if the locked valve requirement can be eliminated by relocating the instruments or by upgrading their safety classification. This evaluation is being completed during the development of a design change which is expected to be implemented during the second refueling outage.

The actions taken by NHY have resulted in compliance with Technical Specification 3.6.3 on April 16, 1991. Additionally the long term corrective actions described above will ensure continued compliance with this Technical Specification.

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