ML20091F454
| ML20091F454 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/27/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91188, NUDOCS 9112060217 | |
| Download: ML20091F454 (5) | |
Text
e New Hampshire ankee fed C. Feigenboom C hief I sewti,e OHicer NYN 91188 Nosember 27, 1991 United States nuclear llegulatory Commission Washington, D.C.
20555 Attention:
Document Control Desk it e f e r e n ce s:
(a) l'acility Ope rating 1.icense No. NI'l' 86, Docket No. 50 443 s
(b)
USNltC 1 etter dated Nmember 1,
1991, " Nit C lle gio n i Inspection 50 443/91 29 (9/10/91 10/14/91f J. C. Linsille to T. C. I cigenbaum S ubje ct:
ltesponse to a Notice of Yinlation Gentlemen:
In accordance with the requirements of the Notice of Violation contained in Iteference (b), the New llampshire Yankee response to the cited violation is provided as IInclosure 1.
should you have any questions (oncerning tLis response, please contact hir. Ja.ncs hi.
Peschel, llegulatory Compliance hianager at (603) 474 9521, extension 3772 Yery truly yours, fg&/
./A Ted C.1:cifenbaum STATE 017 NiiW ll Ah1PSillitti "ockingham, ss.
November 27, 1991 Then personally appeared before me, the above named Ted C. l'eigenbaum, being duly r,w or n, did state that he is President & Chief IIxecutive Officer of the New llampshire Yankee Division of l'ulitie Service Company of New llampshire, that he is duly authoriicd to exceute and file the foregoing information in the name and on the behalf of New llampshire 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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'M5 New Hz..pshire Yonkee Division of Public Service Company of New Hampshire
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g o o cs p.o. p,ox 300. Seabrook, NH 03874 e Telephone (603) 474 9521
United States Nuclear Regulatory Commitsion November 27, 1991 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. Gordon IL Edison, St. Project Manager Project Directorate 1+3 Division of Reactor Projects U.S. Nuclear llegulatory Commission Washington, DC 20555
. Mr. Noel Dudley -
NRC Senior Resident inspector P.O. liox-1149 Scabronk, NH 03874
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O New llampshire Yankee
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November 27, 1991 MD.OSUI(!! TO NYN.41133 i
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Rl!Pl.Y TO A NOTICli OF VIOLATION Violation During NRC inspection from September 10 - October 14, 1991, 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 6.7.1.a requires that the procedures recomrnended in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978, be established, implernented, and maintained. Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, Section 1.c specifies in part that procedures be established for equipment control (e.g., locking rod tagging). New liampshire Yankee procedure M A4.2, Equipment Tagging and Isolation, Section 4.9 requires that tagging order boundary components be restored to their proper positions. Procedure ON1055.01, Revision 4 (Change 20), Pill and Vent of Demineralized Water Systera, specified the normal por,ition of DM.V301 as closed.
Contrary to the above, on about September 30, 1091, demineralized water system valve DM V301 was aligned in the open position during system restoration following completion of maintenance on the letdown line radiation monitor resulting in contamination of the demineralized water system.
This is a Severity Level IV violation (Supplement 1).
Reason for the Violation New llampshire Yankee (NilY) has determined that the root cause of the Demineralized Water System contamination was personnel error.
The personnel completing a tagging restoration sheet utilized valve position data from a computerized tagging database which was in the development phase, instead of using a system valve lineup procedure.
On September 18, 1991, Demineralized Water Splem manual isolation valve, DM V301, was opened in accordance with an incorrect tagging restoration sheet. The tagging restoration
,vas perform-d following maintenance on the Chemical and Volume Control System (CVCS) letdown line radiation monitor.
The tagging restoration sheet was completed solely by reference to valve position information contained in a computerized tagging database. At this time the databate was under development, and not intended to be used to determine system restoration valve position. The appropriate valve lineup procedure should have been used to determine correct valve position.
The mispositioning of DM V301 did not become evident until September 30, 1991. On that date, an inadvertent flow path from the Reactor Coolant System (RCS) to the Demineralized Water (DM) System was established. This occurred while the steam generators where being fille d.
The dernand for DM reduced the pressure in the DM System below the pressure in the CVCS letdown line to the radiation monitor. The reduction in the DM System pressure allowed a sa enoid operated valve, RV-6520-02, to come off its seat enabling RCS flow into the DM System through the mispositioned valve DM-V301.
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Cit!1IIllyt_MllER Upon discovery of the Dh1 Sys em contamination, a radiation survey of the Dh1 System was performed to determine the e act point of contamination.
The contamination path was identified to be through Dhi V 01 and the valve was immediately closed.
New llampshire Yankee's immediate correctiu actions included the following:
1)
The Dht System Lineup procedure (ON1055.01) was reviewed to ensure that the Dhi valves which are required to be closed are included on the blaintained Closed Valve 1.ist.
2)
A complete salve lineup of the Dh1 System was performed to verify that no additional valves were mispositioned. All valves were dete: mined to be properly positioned.
3)
A review of the tagging restorations produced by the tagging computer da; abase was performed to verify proper valve kneups. All valves were determined to be properly positioned.
4)
Use of the tagging enmputer database in the preparation of tagging testorations was discontinued and the Shitt Superintendents personnel were counseled on completing tagging restoration sheets using the appropriate system restoration valve lincup.
5)
Spectacle flanges were installed on three radiation monitoring skids to provide additional assurances that process fluid will not enter the Dh1 System.
6)
A Safety Evaluation was performed to verify that plant operation would not involve an unreviewed safety question.
Corrective Action to Prevent Recurrence New linmpshire Yankee's inng term corrective actions will include a review of system interfaces between non contaminated systems and potentially contaminated systems, T his review will identify potential system enhancements and will include industry experience ie this
- area, it is anticipated that this revie,v will be completed by December 30, 1991.
New llampshire Yankee will also develop radiation monitoring skid purge procedures for the manipulation of radiation monitor valves.
These procedures will include a precaution concerning Dht System pressure being lower than the process fluid pressure.
It is anticipated that these procedures will be completed by h1 arch 1,1972.
New llampshire Yankee will also validate the computerited tagging database prior to its use in tagging restoration. The database will also be provided with sufficient security to ensure only valid changes / revisions can be made to it.
It is anticipated that the enhancements to the computerized tagging database will be cotapleted by hiay 1,1992.
Date of Full Comollance The immediate corrective actions taken by New liampshire Yankee resulted in compliance with Technical Specification 6,7.la. Additionally, the long term corrective actions described above will ensure continued compliance with this Technical Specification.
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