ML20195J122
| ML20195J122 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/15/1999 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137T709 | List: |
| References | |
| NYN-99058, NUDOCS 9906180100 | |
| Download: ML20195J122 (15) | |
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\' North Atlantic Energy Service Corporation North .
im. iw 3* Seabrook, NII 03874 Ak1MIkW (t:03) 474-9521 The Northeast Utilities System June 15,1999 Docket No. 50-443 NYN-99058 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to Request for Additional Information Regarding the June 2.1999 Pre-decisional Enforcement Conference North Atlantic Energy Service Corporation (North Atlantic) has enclosed additional clarifying information to supplement the information provided at the June 2,1999 pre- J decisional enforcement conference at Region 1. This information is being provided at the request of the NRC. I l North Atlantic has also enclosed (Enclosure 4) declarations by three North Atlantic ' employees to correct inaccuracies and omissions in their respective NRC Office of Investigations interview summaries. We understand that Williams Power Corporation I will be providing similar clarifications under separate cover. These declarations are being ) provided to ensure that the interview summaries are complete and accurate. As such, we i request that the declarations be appended to the interview summaries and withheld from ; public disclosure pursuant to 10 CFR 2.790. ! Should you have any questions regarding this information, please contact James M. Peschel, Regulatory Compliance Manager, at (603) 773-7194. Very truly yours, ih NORTH ATLANTIC ENERGY SERVICE CORP. j b / fed C. Feig'enb[a1 ; Executive Vice President and Chief Nuclear Officer ; cc: H. J. Miller, NRC Regica ? Administrator J. T. Harrison, NRC Project Manager, Project Directorate 1-2 R. K. Lorson, NRC Senior Resident Inspector , g Nc L ; 2 9906180100 990615
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I I l ENCLOSURE I TO NYN-99058 i i i
CLARIFYING INFORMATION FOR JUNE 2,1999 PRE-DECISIONAL ENFORCEMENT CONFERENCE The following additional information is provided to clarify discussions during the June 2, 1999 pre-decisional enforcement conference. I 1 Question 1: On what date was the electrician initially granted computer access? l When was his access revoked? When was his computer access reinstated? Answer 1: The electrician was initially granted North Atlantic computer access on August 1,1996. This access was tenninated on August 15,1996 when it is believed that the individual was laid off. The electrician was again granted computer access on December 25, 1996. This access was terminated on February 5,1998 due to the electrician's assignment to field I work associated with the 480 volt cable replacement which eliminated his need for computer access. The electrician's computer access was temporarily suspended in the Spring of 1997 and reinstated in the Fall of 1997. North Atlantic does not have specific dates for the period when the electrician's computer access was suspended. i Question 2: What specific directions in the work package allowed the removal of the wire from terminal 10? Answer 2: The last paragraph of the " Description of Work" section on page 3 of Work Request 97W001282 contains instructions to:
" Perform internal wiring modifications in CBA-CP-l?7 (Node GUI) in accordance with wiring instructions on DCN-34 pg 2 e ' the marked up Vendor diagrams (Enc 1 E, pgs 6, 8, 9 and 10) using wire selected in accordance with 300230 sh 61."
In turn, page 2 to DCR 94-0025 DCN-34 (Enclosure E page 41 to the work package) provides direction to:
"Determ wire between device D6TR-L2 and D7F-10 at D6TR end; reland this wire on D6TRl-L2. If wire is too short, install new using 1/C # 14 per 1-NHY-300230 sh.61."
Additionally, as stated on page 3 of the work request, this information is also depicted on the marked up vendor diagrams. Copies of the above referenced pages of the work package are included in Enclosure 2. 1
Question 3: What would have been the effect on the Control Duilding Air Handling System (CHA) if the wires had not been reversed to the correct configuration? Answer 3: The subject wiring discrepancy involved an Elapsed Time Meter (ETM) for the Train A CBA air conditioning unit at l'anel CBA-CP-177 that was wired backwards from that shown on its wiring diagram. The work request provided instructions to add a time delay relay (TRI) in parallel with an existing time delay relay (TR). The change involved disconnecting TR from the ETM and paralleling it to the new TRI relay which was then connected to the ETM. Had the electrician not properly identified the wiring discrepancy, it is likely to have been identified during wiring verification checks, post-modification functional testing, or normal system operation. However, in the unlikely event that this discrepancy was not corrected, it would have affected the Train A CBA air conditioning subsystem as described below. This discrepancy had no impact on the Train B CBA air conditioning subsystem. Had the wiring discrepancy not been corrected it would have adversely affected operation of both TR and TRI. The TR relay provides a bypass of the low compressor suction pressure trip (non-safety related) during compressor startup. Improper wiring of TR to the opposite terminal than intended would have caused it to be shorted out by its own normally closed contact. This would keep TR from energizing and the compressor would not trip as intended if a low suction pressure condition existed. Prolonged compressor operation with low suction pressure may cause long term degradation of the compressor. The TRI relay automatically opens a non-safety related solenoid-operated valve (SOV) after a period of time from compressor startup that drains oil from an oil / refrigerant separator that was recently installed in the system. Improper wiring of TRI would preclude the SOV from opening hence preventing the oil / refrigerant separator from draining oil. This could allow approximately one gallon of oil to accumulate in the oil / refrigerant separator, which is insignificant since the compressor crankcase holds approximately 10 gallons of oil. However, this condition could allow oil to be carried over with the refrigerant into the compressor. Operation with oil carryover for extended periods can eventually result in compressor degradation due to: 1) oil slugging into the compressor suction; 2) oil accumulation in the evaporator coils causing the thermostatic expansion vanes to malfunction, resulting in refrigerant overfeed to the compressor suction; and 3) accumulation of liquid refrigerant in the compressor oil 2
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sump causing wear and eventual failure of bearing surfaces. These issues may affect long term compressor operation and decrease compressor life, it should be noted thc.t the system operated for a number of years prior to the implementation of a design modification that installed the oil / refrigeration separator in January 1998. While system reliability just prior to implementation of this modification was less than desirable, the system had operated for a number of years before that time with minimal reliability concerns. Operation of the system with the subject SOV closed is similar to system operation prior to the implementation of this design modification. Question 4: Provide additional information regarding the recommendations North Atlantic made to Williams Power Corporation and the actions that Williams implemented. Answer 4: Consistent with a safety conscience work environment, North Atlantic j recommended to Williams Power Corporation that:
. The individual be reinstated and be made whole for any lost time.
On January 19,1998, North Atlantic recommended that Williams Power Corporation reinstate the electrician. This recommendation was not based i on a conclusion that discrimination had occurred, but rather on the need to I reinforce North Atlantic's values concerning a safety conscience work i environment to preclude any potential chilling effect on employees. North ) Atlantic also agreed to fund the position to facilitate reinstating the electrician. As a result, on January 20, 1998, Williams rehired the electrician and paid him for eny lost time from when he was laid off.
. Williams Power Corporation meet with electrical supervision and i craft to explain what happened and what would be happening.
In preparation for reinstating the electrician, Williams management met l with their foreman and the supe visors to inform them that the electrician was going to be rehired and that absolutely no comments or actions against the electrician by either supervision or the craft workers would be tolerated. Following the meeting with the supervisors and foreman, two meetings were conducted by Wilhams's management with their cran workers. These meetings were held on or about January 26,1998 in place of the weekly safety meeting. The meetings stressed that identification of adverse conditions was the responsibility of everyone on site and that 3
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l North Atlantic management encouraged contractor involvement. The ACR process was also explained and the meeting attendees were l encouraged to become part of the process. After the electrician was reinstated, Williams's management met with him several times to confirm that he was being treated fairly. l . Williams Power Corporation improve the quality of documentation i supportmg personnel actions, i Williams issued administrative guidelines called Desk Top Instructions I (DTI). The DTI's augment North Atlantic's procedures and provide additional detail on conducting activities. One DTI was issued on February 25,1998 regarding disciplinary action. This DTI clarifies the administrative process and the requirements for documenting unacceptable tehavior and/or work activities and practices. It also provides examples of those behaviors that warrant the conduct of counseling sessions and the issuance of employee reprimand reports.
. Williams reinforce its commitment to a safety conscience work environment to its entire Seabrook Station workforce. ;
1 l As stated above,'in preparation for reinstating the electrician, Williams j management met with their foreman and the supervisors to inform them ! that the electrician was going to be rehired and that absolutely no comments or actions against the electrician by either supervision or the craft workers would be tolerated. Following this meeting, two meetings ; were conducted by Williams's management with their craft workers. ! These meetings were held on or about .ianuary 26,1998 in place of the I weekly safety meeting. The meetings stressed that identification of l adverse conditions was the responsibility of everyone on site and that j North Atlantic management encouraged contractor involvement. The i ACR process was also explained and the meeting attendees were encouraged to become part of the process. l i Williams's management conducted and continues to conduct periodic ; meetings with their supervision and craft. Topics addressed at these ; meetings include management expectations, industrial safety, ; encouragement in using the. Adverse Condition Report process, self l identification of ACRs, lessons learned, specific relevant events ' documented in ACRs, the EAR Program, open door policy, concerns, and training. The ACR, open door policy, concerns, and EAR Program discussions specifically relate to a safety conscience work environment in l that employees are encouraged to identify and raise issues and concerns to 4 I L
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Williams management personnel or the EAR Program, re " cessary, for resolution. These meetings have been conducted on a u A j basis since November 1998. Before that time, these meetings were conducted less frequently. Williams's management conducted and continues to conduct quarterly meetings between North Atlantic and Williams management and the Business managers of the local unions. Topics addressed during these meetings include upcoming work, manpower needs, training, inprocessing, expectations, the EAR Program, and the need to foster a safety conscience work environment. On February 21, 1998, Williams issued a DTI on Adverse Condition Reports (ACRs). The purpose of this DTI is to clarify the administrative process for issuing ACRs and/or identifying plant conditions, both personnel and equipment safety and non-safety, which warrant identification to the appropriate North Atlantic personnel for investigation and resolution. This DTI is used in conjunction with the Seabrook Station Operating Experience Manual procedure OE 3.1, " Adverse Condition Report." In March 1999, North Atlantic provided safety conscience work environment training to Seabrook Station managers and supervisors. Williams's supervisors and foreman were also p>ovided this training. This training was designed to provide managers and supervisors with objective tools to detect, respond to and prevent retaliation. It also described actions i to prevent potential chilling effects on employees that raise concerns. Question 5: Provide Sections 1.0,2.0, and 3.1 of the Seabrook Station Operating Experience Manual (SSOE) that were in etYect in December 1997. Answer 5: Enclosure 3 to this letter contains copies of Sections 1.0,2.0, and 3.1 of the Revision 15 of the Seabrook Station Operating Experience Manual (SSOE) that were in effect in December 1997. 5
l l l ENCLOSURE 2 TO NYN-99058 l
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1 05936.0370385 CONTINUATION SHEET q SHEET 3/ oF ____ WRNc i9j7lW 0 0 1 2 8 2 DATE FORM SECTION NUMBER AME OF BLOCK CONTINUED TAG NO. lll Description of Work 1-CBA-AC-5-A 12/24/97 f S D DESCRIPTION OF WORK: g g (ME) Calibrate the new Agastat relay (E7012AE, SIC 25523) in accordance with LS0563.22. The relay is to be set to pick up after a 60 sec. delay and is required to have +/- 20% repeat accuracy. jv v, 4
! .h to j (CS) Install the new Agastat relay TR1 in accordance with DCN-34, Enct E, Pg 12.
applicable seismic mounting details from DRR 89-0019 have been included in Encl. E. (CS) Install new conduit between existing control panel 1-CBA-CP-459-A (Node G5Z), existing compressor crankcase heater (NodoHK6) and the new solenoid (Node UK9) as shown on DCN 34, Encl. E pg 13 and LS0567.04. Conduit ID's are as follows: 3BDIRA, 3BHIRA, and 3Bl/RA. (Note: New solenoid CBA-FV-5338-A (Node UK9) is being installed in accordance with 97W(LATER). Coordinate this conduit installation with the work being performed under that work package) { S) Install and terminate new ASP cables as listed below in accordance with O ( L S0567.06 and LS0567.22: Cable ID From To DCN-34, Enci E Pg # G5Z-UK9 CP-459A, TB-1 FV 5338A, SOL-1 4,5,21,25 HK6-UK9 AC-5A Comp Htr FV-5338A, SOL-2 4,5,22,23,25 (CS) Terminate spare conductor (White w/ BK tracer) from Cable G5Z-GU1 in accordance with LS0567.22 and Enci E, Pgs 4,25. (CS) Perform internal wiring modifications in CBA CP-177 (Node GU1)in accordance with wiring instructions on DCN 34 pg 2 and the marked up Vendor wiring diagrams (Encl E, pgs 6,8,9 and 10) using wire selected in accordance with 300230 sh 61. MA 3.1C
- Rev. 26
DESIGN CilANGE NOTICE DOCUMENT NO.: DCR 94-0025 DCNNO. 34 ENCLOSURE: E PAGE4C TITLE: CONTROL ROOM HVAC ENHANCEMENT
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ENGINEERING O FIELD @ ADMINISTRATIVE D STOP WORK UNTIL APPROVED 0 ATRISK APPROVAL @ BRIEF DESCRIPTION (including references):
- 1. REQUEST ELECTRICAL DETAILS FOR THE ADDITION OF TRAIN A OIL DRAIN SOLENOID VALVE SIMILAR TO TRAIN B PROVIDED BY DCN 20.
i PROPOSED RESOLUTION (Enter the item # and Engineering Discipline abbreviation in the appropriate categories below . using NADC, Chapter 3, Figure 3-6-3 definitions): '
- l. I e INSTALL CLASS IE 120VAC, ON DELAY,20-200 SECONDS TIME RANGE, AGASTAT TIMER CAT # E7012AE INSIDE CBA-CP-177 PER ATTACHED DRAWINGS. RELAY SHALL BE INSTALLED PER DETAILS SHOWN IN DRR 89-019 (THIS IS INCLUDED IN THIS DCN FOR CONVENIENCE). THE INFORMATION PROVIDED j INCLUDES SKETCH OF MODELS 7014 & 7024 WHICH COVERS MOUNTING OF MODELS 7012 & 7022.
e INSTALL CABLES G52-UK9 & HK6-UK9 AND REQUIRED CONDUlTS AS SHOWN ON ATTACHED SHEETS. Ogy, [retl, h, hMi! 5'/l0-4, FITs //7,/!1-/21, I3']-/q/ t3-/g,' [Ag4, G f4lstr ?~/& l I ( 1 i Open item Design Interference Add'l Design Details Drawing Correction Procedur.: Changes 1E j Mat'l Substitution Vendor Details Ease of Construction As-Installed Cond. Added Scope CDE SIGN /DA CIE SI /DATE:
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DCR 94-0025 DCN-3tv ENCLOSURE E, PAGE4f CBA-CP-177 INTERNAL WIRING TERMINATE SPARE CONDUCTOR OF CABLE G5Z-GUI PER ATTACHED MARKUP,IF CONDUCTOR IS TOO SHORT TO REACH THE TERMINALS, FIELD TO EXTEND THE CONDUCTOR BY SPLICING WITH SIMILAR COLOR CONDUCTOR OBTAINED FROM CABLE CODES AGIP OR AG2P USING 1-NHY-300230 SH. 53.
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OF CP-177 WIRING DETERM WIRE BETWEEN DEVICE D6TR-L2 AND D7F-10 AT D6TR END; RELAND THIS WIRE ON D6TRI-L2. IF WIRE IS TOO SHORT, INSTALL NEW USING 1/C # 14 PER l-NHY-300230 SH.61, INSTALL FOLLOWlNG JUMPERS USING 1/C #14 PER l-NHY-300230 SH. 61 FROM TO D6TR-L1 D6TRI-L1 D6TR-L2 D6TRI-L2 D6TRI-5 D7D-TB7-5 D5D-1 D7D-TB7-5 D6TRI-3 D7D-TB7-6
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