ML20128D953
| ML20128D953 | |
| 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) |
| Shared Package | |
| ML20128D879 | List: |
| References | |
| NYN-92-172, NUDOCS 9302100273 | |
| Download: ML20128D953 (7) | |
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eab o k, H 03874 r_eia,a At;Jantic Telephone (603)474 9521 Energy Service Corpo.ation NYN 92172 December 31, 1992 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 December 1,1992, 'NRC Region ! Inspection 50 443/92 25,* J. C. Linville to T. C. Feigenbaum (c)
North Atlantic Letter dated December 10,1992, " Licensee Event Report (LER) 92 022 00:
Non compliance With Technical Specification Surveillance Interval for Containment Air Locks", T. C. Feigenbaum to USNRC (d)
North Atlantic Letter dated December 11,1992, ' Licensee Event Report (LER) 92 023 00: Missed Technical Specification Surveillances*, T. C.
Feigenbaum to USNRC
Subject:
Reply 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 Mr. James M.
Peschel, Regulatory Compliance Manager, at (603) 474 9521, extension 3772.
Very truly yours, g,,>
, r/r Bruce. Draw ridge Executive Direc(to -
Nuclear Production BLD:TGP/ tad Enclosure 9302100273 930203 PDR ADOCK 05000443 G
PDR a member of the Northeast Utilities system
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i United States Nuclear Regulatory Commission December 31, 1992 l
i Attention:
Document Control Desk Page two STATE OF NEW liAMPSHIRE Rockingham, ss.
December 31, 1992 Then personally appeared before me, the above. named Bruce L. Drawbridge, Executive Director of Nuclear Production, being duly sworn, did state that he is of the North Atlantic Energy Service Corporation that he is duly authorized to execute and file the foregoing information in the name and on the behalf of North Atlantic Energy Service Corporation and 1
that _the statements therein are true to the best of his knowledge and belief.
Aaw a. &&dd Tracy A. 'DeCredico, Notary Public My Commission Expires: October 3,1995 cc:
Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer North Atlantic Energy Service Corporation P.O. Box 300 Seabrook, NH 03874 MyThomas k Marting.
Regional Administrator U. S. Nuclear Regulatory Commission 8
Reg on _!
475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate I.3 Division of Reactor Projects U.S. Nuclear _ Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector.
P.O. Box 1149 Seabrook, NH ' 03874 3
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i North Aij,,g;c Decernber 33,3997 ENCLOSlfRE TO NYN 9217_2_
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Reply to a Notice of Violation I
During an NRC inspection conducted at Seabrook Station on October 13 November 16, 1992, two violations of NRC requirements were identified. The violations as provided in to inspection Report 50 443/92 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 is in mode 4 and the air lock is being used for multiple entries.
Contrary to the above, on November 10, 1992 the containment air lock seal leakage had not been verified for over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the plant had entered mode 4 and the alt lock had been used for multiple entries.
This is a Severity Level IV violation.
i B.
Technical Specification 4.0.5.a states that inservice testing of AShiE Code Class 1,2, and 3 valves shall be performed in accordance with Section XI of the ash 1E Doller 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 supply instrument air to the component cooling water system temperature control valves, had not been performed in accordance with Section XI of the AhtSE Boiler and Pressure l
Vessel Code.
2.
Contrary to the above, on' November 16, inservice valve stroke testing of the 'A' accumulator isolation valve, SI V 3, had not; been performed in accordance with Section XI of the AShtE Boiler and Pressure Vessel Code.
This is a Severity Level IV violation.
Vlointion A Reason for the Violatiqa-This event was discussed in Reference (c), Licensee Event Report (LER) No.
l 92 22 00, North Atlantic has determined that the root cause of the violation is as follows:
The cause for this event was determined to be the lack of an administrative me l
alert operations staff to perform the air lock scal' surveillance at the completion of long terrn outages when containment integrity has been set, Operations procedure ON1090.04, l
" Containment Entry,"_ provides an adequate administrative mechanism to ensure that this i
surveillance is performed during all phases of power operation and for initial entry following reactor shutdown.
This procedure does no_t apply, however, when multiple containment entries are being made during outages.
The routine surveillance airlock seal test surveillance package,1 hihi 0T001, procedure OX1460.01, 'Altlock Seal Test Containment,"
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4 is normally generated on a weekly basis during power operation, required for a containment entry.
or when specific ally where containment entries are typleally made every two wee of multiple containment entries at the completion of an outage.
Corrective Actions North Atlantic personnel identified this violation during the review of surve 1
Upon discovery, the following actions were taken:
1.
Upon determination the that Technical Specification 4.6.1.3 surveillance late been exceeded, a leak test was immediately performed on the personnel hatch.
test demonstrated that containment integrity was not compromised.
This 2.
Operations Management reviewed this event, the root cause, and the correctiv actions with the operating crews.
3.
North Atlantic-initiated a lluman Performarce Enhancement System (HPES) evaluation for this event.
The recornmendation from the HPES evaluation are incorporated in the corrective actions and the corrective actions to prevent recurrence.-
Corrective Actions to Prevent Recurrence North Atlantic's corrective actions to prevent recurrence include the following:
1.
The airlock seal test surveillance package,1 MM 0T001, will be 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 automatical will ensure that the air lock seat surveillance is performed at least every 7 This i
whenever containment entries are made while in these modes, this action will be completed by January 15, 1993.
it is anticipated that 2.
remind operators of the containmentA status board has been installe surveillance status.
hatch status and the containment air lock 3.
A Training Development Request (TDR) will be initiated to ensure that this e reviewed with Operations shift crews during pre outage training sessions.
. is anticipated that this TDR will be issued by January It 15, 1993.
4 the air lock leak rate after each air lock usage.The person North Atlantic will evaluate the return of this system to service.This service.
Date of Full Comoliance The immediate corrective actions taken by North Atlanti Technical Specification 4.6.1.3.a.
c resulted in compliance with These actions were completed ~ on November Additionally, the longterm corrective 10, 1992.
actions described above will casure continued compliance with this Technical Specification.
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Violation 11 Reason for the Violation North Atlantic has determined that the root cause of t i
92 23 00 1.
The root cause of not testing the Inservice Test of the Instrument Air che during the second refueling outage has been identified as personnel error es-times of various Primary Component Cooling Wa
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accordance with procedure OX1412.11, 'PCCW System Cold Shutdown Va n
Included in this procedure is the open and close exercise of the Instru
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backup air supply isolation check valves, IA V 8030, IA V 8031, IA V 8032 i
IA.V 8033.
These check valves are in the piping between Instrument Air Loo
, and and Loop B and the backup nitrogen supply cylinders which provide j
nitrogen to the PCCW Temperature Control Valves and PCCW Tempe Dypass Valves, t
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The -initial surveillance testing performed during the second refue procedure OX1412.11 required stroke time limits.was unsatisfactory when two PCCW valves exceeded their time since the effect of repairs on the remainder of the test valves which initially failed were repaired and successfully tested The instrument air check valves were tot included in the retest surveillance-Howeve i
surveillance was not annotated to indicate that it was a partial surveillanceThe j
been so annotated the ' retest coordinator or Work Control Superviso
. If it had i
been alerted to the fact that the surveillance was to be performed e
a retest of the failed valves.
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tested. quarterly as requireIn addition, it was determinec that these I
submitted to the NRC on Marc y the North Atlantic inservice Testing Program as the first refueling outage to allow perfonnanceP ant modifications were installed during I
f the testing. These valves were inappropriately listed in proce ur and were therefore tested on a cold i
1, from the first refueling outage a
u i t e see ad f lin ou being during the first refueling outage.ge, these check valves were only tested o 2.
.been identified as a procedure deficiency.The root cause of I-e has valves should have been coded as' being required for Cold SbuidownT was erroneously coded as an event-driven surveillance.
However, it existing programs would have identified this surveillance on the MODE checklist.
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,C.ntrective Action 4
North Atlantic personnel identified the events listed in Violation B during the rev surveillance packages.
Upon discovery, the following actions were taken:
of 1.
The Inservice Testing of Instrument Air check valves IA.V 8030, IA.V 8 IA V 8032. IA.V.8033 and Si accumulator isolation valve SI.V 3 was perform the same day it was identified that the tests had been missed (November 1 1992, respectively). All valves were tested satisfactorily.
Corrective Actions to Prevent Recurrence North Atlantic's longterm currective actions will include the following:
1.
Testing of the Instrument Air check valves will be included in the Station Proc for performing quarterly valve operability tests.
January 30, 1993.
This is expected to be completed by 2.
shutdown surveillance.The Inservice Testing of the SI accumulator isolatio This is expected to be cornpleted by March 31, 1993.
3.
The concept of proper documentation of partially completed surveillanc be stressed to operators and retest personnel during the first phase of 199 requalification training. This is expected to be completed by March 1,1993.
4
" Partial RTS* stamps will be provided to make it easier to identify partia surveillances.
This is expected to be completed by January 30, 1993.
5.
The method for writing / changing RTS's when changed will be reviewed and appropriate changes made, procedures are written, rev 30, 1993.
This is expected to be completed by June 6.
North Atlantic will investigate adding a screen to the Action Statemen progratu to provide a list of sur 'eillances required when an action statement is entered.
This is expected to be e ompleted by June 30, 1993, 7.
The method of developing, revis ng and changing procedures which implem Inservice Testing program will be reviewed and appropriate changes made expected to be completed by Junc-30, 1993.
This is Dnte of Full Comnllance The immediate corrective actions taken by North Atlantic resulted in comoliance Technical Specification 4.0.5.a.
with will ensure that the probability of recurrence of this type of even 4
.