ML20198A266

Responds to Violations Noted in Insp Rept 50-443/97-06. Corrective Actions:Individuals Involved Have Been Coached & Counseled

ML20198A266
Person / Time
Site:	Seabrook
Issue date:	12/19/1997
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-443-97-06, 50-443-97-6, AR#97028271, NYN-97124, NUDOCS 9801050324
Download: ML20198A266 (6)

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The Northeast Utilities System December 19,1997 Docket No. 50-443 NYN-97124 AR#97028271 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. D. 20555 Seabrook Station Reply to Notice of Violation This letter responds to the Notice of Violation described in NRC Inspection Report 50-443/97-06 *1 ne reply is provided in the enitosure along with commitments made in response to the violation.

Sheuld you have any questions conceming this response, please contact Terry L. Harpster, Director of Licensing' Services, at (603) 773-7765.

Vea truly yours, NORTil ATLANTIC ENERGY SERVICE CORP.

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m Ted C. Feigenbau Executive Vice P esident and Chief Nuclear Officer cc:

11. J. Miller, Region I Administrator 79[

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I C. W. Smith, Project Manager R. K. Lorson, NRC Senior Resident Inspector

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REPLY TO A NOTICE OF VIOLATION 4

NRC Inspection Report 97-06 described a violation where procedures..cre not implemented to control rnaintenance activities.

North Atlantic's response to this violation is described below.

Uncription of Violall011 e

The following is a restatement of violation NOV 97-06-05:

Technical Specification 6 7.1.a states, in part, that written procedures shall be implemented as recommended in Appendix A of Regulatory Guide (RG) 1.33. RG 1.33 states that procedures should be implemented to control maintenance activities.

Contrary to the above, procedares were not irnplemented as noted below.

A.

Procedure IN1640.910, MDT-20 SG Feed Pump A Speed Control Calibration, step 8.9.1 required that the lifting cf an electrical lead (D4) be documented.

On September 18,1997,1&C technicians performing troubleshooting activities on the "A" main feed pump (MFP), lifted electrical lead (D4) without docrmenting this action as required. This resulted in the MFP being reassembled and tested without terminating lead (D4), defeating the electrical trip capability of the MFP.

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Maintenance Procedure MA 3.0, Work Practices required that design engineering evaluate replacement parts that look different from the originally installed part.

During refueling outage five, the nitrogen fill line check valves (NG V22 and NG-V24) to the "C" and "D" safety injection accumulators were reassembled with incorrect springs that had not been evaluated by design engineering. The NG-V22 valve then failed to operate while attempting to charge the "C" safety injection accumulator.

This is a Severity Level IV Violation (Supplement 1).

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Reasonfor the Violation North Atlantic agrees with this violation. Each example is addressed separately below:

Example A:

Wnile returning the "A" main feed pump to service, Operations personnel attempted to trip the pump from the main control board and it did not trip. It was identified that during the trouble shooting activities on the pump, a wire was lined per procedure IN1640.910 and was not restored at the completion of the work. An Adverse Condition Report (ACR) was initiated and an apparent cause evaluation was performed. The evaluation concluded that the data sheets were not at the joh nite, the signatures on the data sheets were not completed and the turnover between shins was inadequate. These items are discussed below:

I&C Technicians did not have data sheets required by procedurt IN1640.910 at the job site, it was recognized by the technicians that the data sheets were not available at the job site. Rather than take the time to retura to the I&C shop to obtain these sheets, it was decided that the sheets would be filled out upon completion of work.

This did not meet expectations for completing data sheets as the work is conducted.

1&C Technicians did not sign off steps on the data sheets. The technicians involved incorrectly assumed that the documentation would be taken care oflater and that the documentation would verify restoration of the wire. Procedure IN1640.910 step 8.9.1 requires that the lifting of electrical leads be documented.

The tumover of information between two shins of I&C Technicians was inadequate.

4 The turnover between I&C Technicians did not identify that the data sheets were incomplete. The night shin technicians that performed the por' ion of the procedure that lined the lead did not appropriately document the work activity. Since the day shin technicians had not been responsible for performing the portion of the procedure that lined the lead, the day shift technicians had no reason to believe that conditions had chsged.

This issue was selfidentified by North Atlantic during post maintenance activities on the main feed pump. Post maintenance activities are one of the barriers used to ensure maintenance on a component is complete prior to declaring a component operable.

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l k'orrective Actions That IInve Been Taken For Example A l, The individuals involved in this event have been coached and counseled.

2. Maintenance and Maintenance Services personnel were briefed on the ACR emphasizing the errors that were nnde as well as the positive aspects such as the technician promptly notified management of the error.

These corrective actions have been completed.

Example H:

The Maintenance Manual MA 3.0 " Work Control Prcetices" paragraph 4.3.7.5 states:

Persons installing replacement items that are within the scope of the Design Control Program shall perform the following:

.. Compare the new part to the old, and acte any differences on the work document.

b. Contact Procurement Engineering if any ditTerences are noted.

The intent of this procedure step is to ensure that the configuration of the station is maintained. Specifically. it protects against vendor's changing either the material or configuration of parts with out changing the part number. It also protects against mislabeling of a component or part by the Seabrook ::n.ted:.: handling organizations.

During the lifth refueling outage, both the NG-V22 and NG-V24 check valves weie disassembled. The Program Support Group (PG) engineer took measurements of both the old and new sp?ngs and noted the different spring dimensions on the work requests. For example, the work request for NG-V24 stated:

"The old spring dimensions were taken. The new spring was essentially the same except that it was 2.160 inches long versus 1.520 inches for the old spring. To improve closure the spring was also replaced."

liowever, even though he first part of MA 3.0 paragraph 4.3.7.5 was performed for the spring replacement, the second part of the step was not in that Procurement Engineering was not contacted.

This issue was selfidentified by North Atlantic during post maintenance activities on the NG-V22/24.

Post maintenance activities are one of the barriers used to ensure maintenance on a component is complete prior to declariag a component operable.

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Correctis c.i ilons That Have Been Taken For Example B'

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The individual involved in this event was coached and counseled on the MA 3.0 replacement parts requirements and the need for a questioning attitude.

This corrective action has been completed.

Corrective Acdons That Will Be Taktn.for Example B

1. North Atlantic will retrain the appropriate maintenance, technical support, program support and contractor personnel on the requirements of paragraph 4.3.7 of MA 3.0

" Work Control Practices" by refueling outage six.

2. MA 3.0 " Work Control Practices"(paragraph 4.3.7.5) will be revised to identify the expected actions of Procurement Engineering by March 16,1998.

3. An evaluation was performed to determine if these springs have been used elscwhere in the plant. The evaluation concluded that there were four other applications (ASC-V361, CS-V230, SA-V131 and IIWS-Vil6) that have used the issued springs in the plant. The springs will be replaced or accepted for use as is prior to restart from the current outage.

Additional Corrective Actions North Atlantic has recently completed the initial Station Common Cause Analysis as part of the Corrective Action Program. The Station Common Cause analyzes Adverse Condition Reports (ACR) to identify organizational or progmnmatic issues that may be the root cause or a contributor to the prablems identified on the ACRs. The Station Common Cause determined that three issues have contributed to ACRs that involve the failure to follow procedures; accountability, vertical communications and task observation.4. By improving our performance in these areas, we will minimize the preursors and improve our performance with regard to following procedures. Change Management Plans will be developed by March 31,1998 to address these issues and to communicate tLe proposed actions to the organization.

The Station Common Cause provides a benchmark for our perfons n. The next Station Common Cause is scheduled to be performed in april 1998 to cover our performance from October 1997 through Mawh 1998.

Date When Full Compliarlss_Will Be Achieved North Atlantic is currently in compliance with Technical Specification 6.7.1.a.

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i-NYN - 97124 North Atlantic Commitments

1. North Atlantic will retrain the appropriate maintenance, technical support, program support and contractor personnel on the requirements of paragraph 4.3.7 of MA 3.0

" Work Control Practices" by refueling outage six.

2. Procedure MA 3.0 " Work Control Practices", paragraph 4.3.7.5, will be revised to identify the expected acticns of Procurement lingineering by March 16,1998.

3. Change Managem:nt Plans will be developed for improvements in accountability, vertical communications and task observation as part of the response to the Station Common Cause by March 31,1998.

4. The springs for ASC-V361, CS-V230, SA-Vl31 and IlWS-Vil6 will be replaced or accepted for use as is prior to restart from the current outage.

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