ML20105B824
| ML20105B824 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/18/1992 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-92123, NUDOCS 9209210211 | |
| Download: ML20105B824 (6) | |
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4 M_. North L#:2NNee74 Telephone (603)474 0521
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Facsimile (603)474 2987 Energy Servico Corporation Ted c. Feigenbaum Senior Vico President and NYN 92123 Chief Nuclear Officer September 18, 1992 United States Nuclear llegulatory Cornmission Washington, D.C.
20555 Attention:
Document Control Desk It cie rence s:
(a)
Facility Operating License No. NPF 86, l',cket No. 50-443 (b)
USFAC Letter dated August 20, 1992, "Scabrook inspection 50 443/92 13,' J. C. Linville to T. C. Feigenbaum (c)
North Atlantic Letter dated July 17, 1992, "I.icensee livent Iteport (LI!!<) 92 07-00:
Non compliance With Technical Specification 3.8.1 Action itequirements," T. C. Feigenbaum to USNitC
Subject:
lleply to a Notice of Violation Gentlernen:
In accordance with the requirements of the Notice of Violation contained in Reference (b), the North Atlantic !!nergy Service Corporation (North Atlantic) response to the cited violation is provided as I?nclosure 1.
i Should you have any questions cencerning this response, please contact Mr. James M.
peschel, P.cgulatory Compliance Mangr r, at (603) 474 9521, extension 3772.
Very truly yours, b d. +
f p/
Ted C. Feigen5aam TCF:TG l'/a ct linclosure 1
^4onnW a mornber of the Northeast Utikties system 9209210211 9fcO918 DR ADOCK 05000443 (J
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United' States Nuclear Regulatory Commission September 18, 1992 l
' llention:
Document Cr ntrol Desk Page two A
i STATE OF NEW ll AMPSillRii Rockingham, ss.
September 18, 1992 Then personally appeared before me, the above-named Ted C. Feigenbaum, being duly sworn, did state that he is Senior Vice l' resident and Chief Nuclear Officer of the North Atlantic Energy Service Corporation that he in duly authorized to execute and file the foregoing information in the name and on the behalf of North Atlantic Energy Service Corporation and that the statements therein are true to the best of his knowledge and belief.
?> c i 9t$1. h nNOmwug fleverly E. Siljdway, Notary Public 3 j
My Commission Expires: February 28, 1995 cc:
Mr. Thomas T. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, Sr. I'roject Manager l
Project Directorate 1-3 Nvision of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P,0. Ilo.s 1149 Seabrook, Nil 03874 i
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North Atlantic September. 18, 1992 i
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ENCL,OSURE TO NYN 92123 r
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S REPLY TO A NOTICE OF VIOLATION Violating During an NRC inspection conducted on June 16 - July 27,1992, two violations of NRC
. requirements were identified.
In accordance with the
- General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C, the violations are listed below:
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- A.
Technical Specification 3.8.1.1.c.1 requires that when an emergency diesel generator is inoperable, all required systems that depend on the remaining operable emergency diesel generator as a source of emergency power must be operable.
Contrary to the above, on June 17, aftL "mergency Diesel Generator B was (3 ;lared inoperable, calibration of a pressure instrument was approved which caused the-A train of the Containment Enclosure Emergency Air Cleanup system, which depends.
on Emergency Diesel Generator A as a source of emergency power, to be inoperable.
This is a Severity Level IV violation.
D.
Technical Specification 3.8.1.1.a requires that, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an emergency diesel generator being declared inoperable, the remaining emergency diesel generator be started from ambient conditions per Technical Specification surveillance requirement 4.8.1.1. 2 a.5.
f Contrary to the above, on June 18, 1992 at approximately 5:00 a.m.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after declaring Emergency Diesel Generator B inoperable, Emergency Diesel Generator A had not been started from ambient conditions per Technical Specification surveillance requirement 4.8.1.1.2a.5.
This is a Severity Level IV violation.
Reason for the Violation These events were discussed in Reference (c), Licensee Event Report (LER) No. 92-07 00.
North Atlantic has determined that the root cause of the two violations are as follows:
Violation A The cause of this event was determined to be personnel error.
Specifically, there was inadequate communication between an I&C technician and the Work Control Cnordinator.
The technician performing the procedure realized that the fan would become inoperable but,.
during the pre job briefing he was not successful in communicating this to the individual
- responsible-for controlling work in the plant. In addition, the lack of adequate procedurcl~
. guidance contributed to the event. The procedure IS1624.327, 'P-5027 Charging Pump Room Return Duct Pressure - Train A," used to calibrate the pressure switch did not state that performance of the procedure would remove the ability of the fan to automatically start, thereby causing the fan to be considered inoperable.
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3.
- A Training Development Request (TDR) will be submitted to request training regarding disab!cments of automatic functions for Engineered Safety Features equipment. The TDR is scheduled to be submitted to Training by October 12,-
1992.
4.
A review will be performed of Technical Clarification 145, 'EAll and C11A System Components Required to be OPERAllL11 in MOD 11S 1-4,* to determine if additional guidance is required regarding the automatic start feature for fans EAll-FN 180A and EAll FN 1808. This review is scheduled to be compie:cd i
by October 12, 1992.
5.
A Technical Clarification will be developed to list the systems that must be reviewed for OPER AlllLITY per Technical Specification 3.8.1.1, ACTION c.1 when an EDG is determined to 3 inoperable. This Technical Clarification is -
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scheduled to be issued by April 1,1993.
Date of Full Comoliance The immediate corrective actions taken by North Atlantic for Violations A and 11 resulted in compliance with Technical Specifications 3.8.1.1.c.! and 3.8.1.1.a respectively. Additionally, t'
the long term corrective actions described above will ensure continued compliance with these Technical Specifications.
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Viointle il The cc 2 of this event was detert...aed to be personnel error. Specifically, there was an due to miscommunication. The requirement to complete Ndequate shift turnove. briefh 3 yC.;, '
u u a:veillance for the "A'.;ain EDO was verbally communicated to the oncoming shift but
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' wa aot recorded on the shift turnover briefing :.heet.
'k g ys give Action ry of the two violations, se:f-idertifiad by the Shift Superintendent for Violation 3
ncoming c mrating crew for Violation B, 'he following immediate actions were
$k Violation A - The Shift Superintendent directed the mainten ace workers to restore the "A" train of Containment Enclosure Emergency Air Cleanup System (EAll) fan to operable status.
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Violation B - Upon notification by the oncoming operations crew, the Shift y
Superintendent directed the control room operators to conduct the surveillance, gq and enterc' Technic ! Specification 3.0.3, " Limiting Conditions for Operations,"
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which req the plant to be placed in llot Standby within the next six hours. Tl:
erators completed th-diesel generator surveillance within 30
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minutes anu exited Technical Specification 3,P.
Cthout initiating a plant F,g
- shutdown, i
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Th" 'lan o.' the Day (POD) process was revise 1 t "o
rt that work activities not m p' fl during their assigned system wece aie either postpoacd to the nen k
...cn the affected train is removed from service or are reviewed to enstu acy can be worked in the oppcsite train system week without adversely affecting iraia opeiability.
4.
The Operations Manager reviewed the events with the Operations shift personnel to emphasize close scrutiny of non-technical specification wor ( it e ms for their effect on systeras required bv the Technical Specifications, diligent tracking of action requirements and written discussion on turnove notes.
Corrective Actions to Prevent Recurr-nec No.h Atlantic's lorig term correctise actions will include the following:
1.
A review will be performed of the applicable Instrumentation & Control (710) procedures to dcermine if sufficiet.t guidance is contained in the procedures to address Technical ',pecification Limiting Conditions for Operation and the cutry into ACTION statemet.ts during maintenance activities. This review is scheduled h be completed by January 30, 1993.
2.
The method utilized by Control Room personnel to track and schedule event driven surveillaace requirements will be reviewed to determine if a uvision can be made to provide enhanced tracking capability. This review is scheduled to be completed by January 15, 1993.
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