ML20126H851
| ML20126H851 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/31/1992 |
| From: | Drawbridge B NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-92172, NUDOCS 9301050342 | |
| Download: ML20126H851 (7) | |
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M__u. Atlantic Telephone (603)474 9521 ama Enorgy Sorvico Corporation NYN 92172 Decernber 31, 1992 United States Nuclear llegulatory Commission Washington, D.C.
20555 Attention:
Docurnent Control Desk liefercnces:
(a)
Facility Operating License No. NPF 86, Docket No. $0 443 (b)
USNitC Letter dated December 1,1992, 'NRC lleglon i inspection 50 443/92 25,* J. C. Linville to T. C. Felgenbaum (c)
North Atlantic Letter dated December 10,1992, ' Licensee !! vent Iteport (Ll!It)92-022 00:
Non compliance With Technical Specification Surveillance Interval for Containment Air Locks" T. C. Felgenbaum to USNRC (d)
North Atlantic Letter dated December 11,1992, " Licensee Event Iteport (Ll!!!) 92 023 00: hiissed Technical Specification Surveillances" T. C.
Feigenbaum to USNRC
Subject:
Iteply to a Notice of Violation Gentlemen:
In accordance with the requirements of the Notice of Violation contained in Reference
-(b), the-North Atlantic Energy Service Corporation (North Atlantic) response to the Notice of Violation is provided as Enclosure 1.
Should you have any questions concerning this response, please contact htr James bl.
Peschel, llegulatory Compliance hinnager, at (603) 474 9521, extension 3772c Very truly'yours,
. lrk og Bruce.. Drawtgidge Executive Directdb Nuclear Production llLD: TOP / tad
()Ub Enclosure 9301050342 921231 a member of the Northeast Utilities system
'PDR ADOCK 05000443
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s United States Nuclear Regulatory Commission December 31, 1992' Attention:
Document Control Desk Page two i
STATl! OF N!!W llAMPSilliti!
Rockingharn, u.
December 31, 1992 Then personally appeared before me, the above. named lituce L, Drawbridge, !!xecutive Director of Nuclear Production, being duly sworn, did state that he is of the North Atlantic linergy Service Corporation that he is duly authorired to execute and file the foregoing infortnation in the name and on the behalf of North Atlantic Energy Ser.> ice Corporation and that the statements therein are true to the best of his knowledge and belief.
Althkf.$ hl$1/lllO Tracy A. 'DeCredico, Notary Public My Commission Expires: October 3,1995 cc:
Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer North Atlantic IInergy Service Corporation P.O. Ilox 300 Seabrook, Nil 03874 Mr. Thomas T. Martin e
Itegional Administrator U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Gordon-l!. Edison, Sr. Project Manager Project Directorate 13 Division of Itcactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Ilox 1149 Seabrook, Nil 03874
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North Atlaritic December 31, 1992 1:NCI OSUltlC TO NYN 92172
l litply to n Nojire of Violation Dusing an NltC inspection conducted at Scubrook Station on October 13 November 16, 1992, two violations of NiiC requirements were identified. _ The violations as provided in i
!!nclosure 1 to inspection Iteport $0 443/92 25 are listed below:
A.
Technical Specification 4.6.1.3.a requires that containment air lock seal leakage be verified at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, when the plant 16 in mode 4 and the air lock is being used for multiple entties.
Contrary to the above, on November 10, 1992 the containment air lock seal leakage had not been verified for over 72 hourt, after the plant had entered mode 4 and the air lock had been used for multiple entries.
This is a Severity Level IV violation.
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11.
Technical Specification 4.0.$.a states that inservice testing of ASMl!
Code Class 1,2, and 3 valves shall be performed in accordance with
_i Section XI of the ASMl! Iloller and Pressure Vessel Code.-
1.
Contrary to the above, on November 12, inservice valve stroke testing of check valves, IA V 8031, 8032, 8033, and 8034, which -
l supply instrument air to the cornponent cooling water system j
temperature control valves, had not been performed in
-l accordance with Section XI of the AMSil lloiler and Pressure l
Vessel Code.
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2.
Contrary to the above, on November 16, inservice valve stroke-i testing of the 'A' accumulator isolation valve, SI V-3, had not s
been performed in accordar;ce with Section XI of the-ASMl!'
Iloller and Pressure Vessel Code.
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This is a Severity Level IV violation, i
Violatinn A_
Itenson for the Viointion l-I' This event was discussed-in iteference (c), Licenece !! vent lleport (Ll!!1) No. 92 22 00.
North Atlantle has determined that the root cause of the violation is as follows:
l The cause for this event war, determined to be the lack of on adminiitrative mechanism to alert operations staff to perform the air lock seal surveillance at-the completion of long
'tcrm outages when containment integrity has been set. Operations procedure ON1090.04,
- Containment !!ntry,' provides nn-adequate -administr_ative mechanism-to ensure _ that this surveillance is performed during all phases of power operation and for initial.cntry following..
l reactor shutdonn,. This procedure: does _ not. apply, however, when multiple. containment entries are-being made during outages.~
The routine surveillance airlock seal test surveillance package,1 MM 0T001, procedure OX1460.01, " Airlock Seal Test Containment /'
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weekly basis during power operation, or when specifically is n,ormally generated on a
- required for a containment entry. While this frequency is adequate for power operation where containment entries are typically made every two weeks, it is not adequate for periods of multiple containment entries at the completion of an outage.
1 Corrective Aetions North Atlantic personnel identified this violation during the review of surveillance packages.
Upon discovery, the following actions were taken:
1.
Upon determination the that Technical Specification 4.6.1.3 surveillance interval had been exceeded, a leak test was irnmediately performed on the personnel hatch. This test demonstrated that containment integrity was not compromised, j
2.
Operations Management reviewed this event, the root ca usts, and the corrective nctions with the operating crews.
3.
North Atlantic initiated a iluman Performance !!nhancement System (llPES)
I evaluation for this event.
The recommendation from the llPI2S cvaluation are' incorporated in the corrective actions and the corrective actions to prevent recurrence.
Corrective Actions to l'revent' Recurrence Noith Atlantic's corrective actions to prevent recurrence include the following;
[
1.
The altlock seal test surveillance package, 1 MM.OT001, will be - automatically computer generated every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when the plant is in MODES 2, 3, and 4.
This will ensure that the air lock seal surveillance is performed at least every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> whenever containment entries are made while in these modes, it is anticipated'that.
this action will be completed by January 15, 1993.
2, A-status board has been installed in the work control aren in the Control Room to remind operators of the containment hatch status and the containment air lock surveillance status.
t 3.
A Training Development Request (TDit) will be initiated'io ensure that this event-Is_
reviewed with Operations shift crews during-pre outage training sessions.
It is anticipated that this TDit mill be issued by January 15, 1993.
4.
The personnel air lock is equipped with a system that will automatically determine the air lock leak rat _c after each air lock usage. -This system is not - currently in i
service.- North Atlantic will evaluate the return of this system to service.
f Date of Full Comollance The immediate corrective actions taken by North Atlantic.resulted in compliance with t
Technical Specification 4.6.1.3.a.
These actions were completed on November 10,.1992.
Additionally, the longterm corrective actions described above - will ensure continued
- compliance with this Technical Specification, 2
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1(cason for the Violation These events are discussed in Reference (d), Licensee Event 1(cport (LElt) No. 92 23 00.
North Atlantic has determined that the root cause of the violation is as follows:
1.
The root cause of not testing the Inservice Test of the Instrument Air check valves during the second refueling outage has been identified as personnel error, inservice Testing, which verifies valve posillon indication, status lights and stroke times of various l'rlmary Component Cooling Water (PCCW) valves, is perfortned in accordance with procedurn OX1412.11, 'PCCW System Cold Shutdown Valve Test".
Included in this procedure is the open and close exercise of the Intittument Air backup air supply isolation check valves, IA V.8030, IA-V-8031, IA-V 8032, and I A.V 8033. These check valves are in the piping between Instrument Air Loop A and Loop D and the backup nitrogen supply cylinders which provide safety grade nitrogen to the PCCW Temperature Control Valves and PCCW Temperature Control llypass Valvct,.
The initial nirveillance testing performed during the seccnd refueling outage per procedure OX1412.11 was unsatisfactory when two PCCW valves exceeded their required stroke time limits. The instrument air check valves were not tested at this time since the cifcet of repairs on the remainder of the testing was unknown. The valves which initially failed were repaired and successfully tested, llowever, the instrument air check valves were not included in the retest surveillance. The original surveillance was not annotated to indicate that it was a partial surveillance, if it had been so annotated the rctest coordinator or Work Control Supervisor would have been alerted to the fact that the surveillance was to be performed for more that just a retest of the failed valves.
In addition, it was determined that these Instrument Air check valves had not been tested quarterly as required by the North Atlantic inservice Testing Program as submitted to the NRC on March 11, 1991. Plant inodifications were installed during the first refueling outage to allow performance of the testing. These valves were inappropriately listed in procedure OX1412.11 and were therefore tested on a cold shutdown basis instead of quarterly.
As a result, from the first refueling outage until the second refueling outage, these check valves were only tested once, that being during the first refueling outage.
2.
The root cause of missing the Inservice Test of the Si accumulator isolation valve has-been identified as a procedure deficiency. The test of the Si accumulator isolation valves should have been coded as being required for Cold Shutdown. 1lowever, it was erroneously coded as an event driven surveillance. 11ad it been properly coded,
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existing programs would have identified this surveillance on the MODE 5 to MODE 4 checklist.-
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.Cninihe Action.
North Atlantic personnel identified the events listed in Violation 11 during the review of surveillance packages. Upon discovery, the following actions were talent 1.
The Inservice Testing of instrument Air check valves I A V.8030, I A V 8031, IA.V 8032, IA V 8033 and Si accumulator isolation valve SI V 3 was performed on the same day it was identified that the tests had been missed (November 12 and 16, 1992, respectively). All valves were tested satisf actorily.
Corrective Actions to Prevent Hecurrence North Atlantic's longterm corrective actions will include the following:
i 1.
Tetting of the Instrument Air check valves will be included in the Station Procedures for performing quarterly valve operability tests. This is expected to be completed by January 30, 1993.
i 2.
The Inservice Testing of the Si accumulator isolation valves will be coded as a cold shutdown surveillance. This is expected to be completed by March 31, 1993.
3.
The concept of proper documentation of partially completed surveillances (RTS's) will be stressed to operators and retest personnel during the first-phase - of 1993 requalification training. This is expected to be completed by March 1,1993.
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4.
- Partial RTS* stamps will be provided. to make it easier to identify partial surveillances. This is expected to be completed by January 30, 1993.
5.
The method for writing / changing RTS's when procedures are written, revised or.
f changed will be reviewed and appropriate changes made. This is expected. to be --
completed by June 30, 1993.
6.
North Atlantic will investigate adding a screen to the Action Statement Tracking program to provide a list of surveillances required when an action statement ~is e nt er e d.
This is expected to be completed by June 30, 1993.
7.
The method of developing, revising and changing proceoures which implement the Inservice Testing program will be reviewed und appropriate changes made. This is expected to be completed by June 30, 1993.
IJ!pte of l'ull Compilansr.
. The immediate corrective actions taken by North Atlantic resulted in-compliance.with.
L Technical Specification 4.0.5.a.
In addition, the longterm corrective actions described above:
will ensure that the probability of recurrence of this type of event will be minimited,-
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