ML20198G471
| ML20198G471 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/29/1997 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-443-97-03, 50-443-97-3, AR#-97019225, NYN-97095, NUDOCS 9709040077 | |
| Download: ML20198G471 (5) | |
Text
_
4 qw...
A NOrtll Nonh Atlantic I:nerg &nir e Co:1> oration a
^
l'.O. Box 300 Atlantic seahrook, sii O3874 (603)474 9TGt i
The Northeast Utilities Systern August 29,1997 Docket No. 50-443 NYN-97095 AR# 97019225 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Seabrook Station Renly to Notices c.f Violation This letter responds to the Notices of Violation described in NRC Inspection Report 50-443/97-
- 03. The reply is provided in the enclosure along with commitments made in response to the violations.
Should you have any questions concerning this response, please contact Mr. Terry L. Ilarpster, Director of1.icensing Services, at (603) 773-7765.
Very truly yours, NORT11 PA'$T[b ENER Y SERVICE CORP.
/ ad f /
- /
' ed erhaum Executive Vicchesident a '
Chief Nuclear OfficU cc:
- 11. J. Miller, Region 1 Administrator I
A. W. De Agazio, Sr. Project Manager I
F. P.11onnett, NRC Senior Resident inspector j
i s
970904007/ 970829 gDR ADOCK 05000443 PDR r
REPLY TO A NOTICE OFTIOLATION NRC Inspection Report 97-03 describes two violations. The first violation identifies North l
Atlantic's failure to control licensee designated vehicles inside the Protected Area as required by I
the Seabrook Station Physical Security Plan. The second violation describes North Atlantic's failure to take adequate corrective actions related to the proper use of pressure tubing. North Atlantie's response to these violations is provided below.
1.
11cserintion of the Violations The following are restatements of the violations:
A.
Section 6.7A, Licensee Designated Vehicles (LDVs), of the Seabrook Station physical Security Plan, Revision 21, dated November 11,1996, requires, in part, that all LDVs when unattended must have the ignition locked, and the keys removed from the ignition and be controlled by an authorized person.
Conirary to the above, on May 22, 1997, vehicle number LDV 16-02 was four.d unattended, with the keys in the ignition and the engine running, and not in control of an authorized person.
This is a Severity Level IV Violation (Supplement 111).
IL 10CFR 50, Appendix 13, Criterion XVI, Corrective Action, requires in part, that measures shall be established to assure that conditions adverse to quality such as failure, malfunctions, deficiencies, deviations, defective material and equipment I
nonconformances are promptly identified and corrected.
Contrary to the above, on May 27, 1997, during Emergency Core Cooling System (ECCS) valve testing, a temporary tygon tube failed that was installed on flow transinitter CS-FT-121, which resulted in a radioactive spill due to the pressure rating of the temporary tubing being much lower than required for the system application. Several similar failures of tubing with insufficient pressure rating have occurred in the past three years.
This is a Severity Level IV Violation (Supplement 1).
Page1of4
-a
l 11.
Repjy to the Notices of Violation A.
Designated Vehicle I eft Unattended with Keys in the Ignition and Running-VIO 97-03 QB Reason for the V!nladpn
(
Ncrth Atlantie agrees with this violation. The Seabrook Station Physical Security Plan (SSPSP) requSes that o licence designated vehicle (LDV) inside the protected area be controlled by the amhorized %wMor at all times or have its ignition locked and the keys removed.
Contrary to tne above, on May 22,1997, the NRC Resident inspector identified that LDV #16-02 was unattended with its engine running and keys lef t in the ignition. The Inspector informed a Security Officer of the condition. The Security Officer turned off the vehicle's engine, took possession of the keys, and located the authorized operator of the vehicle. The operator was found behind a portion of a nearby building, but beyond line-of-sight from the vehicle.
LDV #16 02 is a Orm tractor with a small trailer that was used to make routine deliveries inside protected area duiing the recent refueling outage, OR05. The vehicle was driver to the south side of the Diesel Generator Building and backed into the area next to the building to be unloaded.
The operator left tne vehicle running while the vehicle was being unloaded. The operator subsequently lost focus of her responsibilities and became engaged in a conversation with another employee out of sight of the vehicle. The driver is a long-time contractor employee who is familiar with the security requirements of vehicles in the protected area.
Corrective Actions North Atlantic has initiated the following corrective actions:
- 1. The driver was coached and ceunseled on the requirements of controlling LDVs.
Maintenance Services vehicle operators were briefed on the event and they acknowledged their understanding of the LDV program.
2.1hree articles were printed in Seabrook Station internal publications, two in the "OR05 Ov' age liighlights," May 24, May 26, and one in "Seabrook Today," July 18, to remind personnel of the requirements of controlling LDVs.
- 3. A 3 foot x 6 foot sign has been attached to the vehicle gate at the entrance of the protected area with the wording: " Vehicle Must be Attended When Running" and " Remove and Control Ignition Key from Unattended Vehicle."
- 4. LDV ignition keys have been attached to large key rings that have plastic tags embossed with the same wording as above.
Page 2 of 4 i
l<
Date When Compliance Will lle Achieved North Atlantic is in compliance with the SSPSP.
II.
Failure to Tak Adequate. Corrective Actions for Use of Pressure Tubine-VIO 97-03-02 Reason for the Violation North Atlantic agrees with this violation. A root cause evaluation of the OROS event included a review of similarities between this event and four previous events which resulted in burst tubing.
This event and the four prior events are described below.
On May 27,1997, during OR05, a technician used improper tubing during ECCS valve testing due to a lack of verification and validation. The individual was experienced and understood tubing pressure ratings. While the work package could have been more explicit, the technician agreed that the necessary information was available for him to have performed the task correctly.
The cause of this event is personnel error.
On December 6,1995, during OR04, improper tubing was used during pressure testing. The-technician was aware of the correct tubing to use to perform the assigned pressure test based on his training and an explicit pre-job briefmg by his supervisor. Ilowever, when the correct tubing could not be located, the technician used tubing with a lower rating without verifying the acceptability of this tubing with his supervisor. This event was caused by the use cf a shortcut, which is a human error failure mode.
On June 1,1995, during the investigation of an air trouble alarm in a 345 kV breaker, the flexible tubing for the air system pressure switch was found burst. The underrated tubing had been installed in 1992, prior to training of J&C technicians on pressure ratings of tubing and hoses used for testing and preventive maintmr.nce. This training was conducted when a problem not related to burst tubing revealed a general lack of knowledge among I&C personnel in this area.
The cause of this event has not been determined-On June 20,1995, tubing installed for filtering Main Steam Isolation Valve hydraulic fluid burst.
The cause of this event was the incorrect positioning of a valve on the filtration unit. The misalignment of the valve caused the pressure to increase above the pressure designated on the repetitive task sheet for that job. The cause of this event was determined to be personnel error, however, it was not similar to the May 27,1997 event.
On April 15,1994 tubing ruptured during the performance of a local leak rate test (LLRT). The supply hose was overpressurized and ruptured due to improper operation of a pressure regulator.
This was caused by a personnel e.ror, however, it also was not similar to the May 27,1997 event.
Page 3 of 4 I
~~
i+
Corrective Actions for the May 27.1997 Event
- 1. The individual involved in the event was counseled on the use of proper tubing.
- 2. The I&C Department developed department guidance (ICSE #27) regarding the connection of temporary equipment to process systems. This guidance requires the utilization of high pressure tubing for connections to inservice components. Training for I&C personnel on this guidance and this event will be completed by September 19,1997.
Programmatic Corrective Actions
- 1. North Atlantic recognizes that while significant improvement has been made in the corrective action program including the reduction of human errors, additional improvement is needed.
After benchmarking the corrective action programs of a number of top performing plants, North Atlantic established a contract with Performance improvement International (Pil) in the fall of 1996 to implement the Pil corrective action and human performance improvement methodology as part of our corrective action program. Training is being provided to personnel on the corrective action program including the identification of drivers of human errors, methods for recognizing when these drivers are present and techniques to address them. Supervisors are receiving additional training on recognizing the presence of these error drivers in their organization and strategies to address them. In addition, we are developing a performance monitoring system that will incluue real time indicators of how well plant personnel are meeting management expectations for human performance.
- 2. A new organization, led by a corrective action program manager, has been established to implement the corrective action program using the Pil technology. This organization includes trained root cause evaluators, trending personnel, and personnel dedicated to developing and implementing tools for error prevention. The revised corrective action program was implemented in April,1997. In addition, this organization is developing a performance monitoring system that will provide real-time indication of the effectiveness of the corrective action program. This monitoring program will be in place by the end of 1997.
Date When Comnliance Will Be Achieved North Atlantic is currently in compliance with 10 CFR 50, Appendix B, Criterion XVI.
Page 4 of 4 I