ML20198L106
| ML20198L106 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/15/1997 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigenbaum T, Harpster T NORTHEAST UTILITIES SERVICE CO. |
| References | |
| 50-443-97-03, 50-443-97-3, NUDOCS 9710240246 | |
| Download: ML20198L106 (2) | |
See also: IR 05000443/1997003
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October 15,1997
Mr. Ted C. Feigenbaum
Executive Vice President and Chief Nuclear Officer
Northeast Utilities Service Company
clo Mr. Terry L. Harpster
P.O. Box 128
Waterford, CT 06385
SUBJECT:
INSPECTION REPORT NO. 50 443/97 03
Dear Mr. Felgenbaum:
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This letter refers to your August 29,1997 correspondence, in response to our
August 13,1997 letter. Thank you for informing us of the corrective and preventive
actions documented in your letter.
We note that both violations involve a common cause of " cognitive errors". Your
corrective actions are generally: Individual counseling, site wide communications for
heightened awareness, and for the pressure tubing problem, enhanced procedural controls.
We also appreciate you addressing your programmatic corrective actions which involves
additional staffing.
These actions will be examined during a future inspection of your licensed program. Your
cooperation with us is appreciated.
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Sincerely,
Original Signed By:
Richard J. Conte, Chief
Projects Branch 8
Division of Reactor Projects
Docket No. 50-443
cc: w/o cv of Licensee's Resoonse Letter
B. D. Kenyon, President Nuclear Groun
D. M. Goebel, Vice President Nuclear oversight
F. C. Rothen, Vice President Work Services
J. K. Thayer, Vice President Recovery Officer, Nuclear Engineering & Support Officer
H. F. Haynes, Director - Nuclear Training
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B. L. Drawbridge, Executive Director - Services & Senior Site Officer
A. M. Callendrello, Licensing Manager - Seabrook Station
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W. A. DiProfio, Nuclear Unit Director Seabrook Station
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R. E. Hickok, Nuclear Training Manager - Seabrook Station
L. M. Cuoco, Senior Nuclear Counsel
'971024bCK05000443
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cc: w/cy of Licensee's Response Letter
D. C. McElhinney, RAC Chairman, FEMA Rl, Boston, Mass.
R. Backus, Esquire, Backus, Meyer and Solomon, New Hampshire
D. P. Forbes, Director, Nuclear Safety, Massachusetts Emergency
Management Agency
F. W. Getman, Jr., Vice President and General Counsel Great Bay Power
Corporation
Commonwealth of Massachusetts, SLO Designee
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R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts
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Seacoast Anti Pollution League
State of New Hampshire, SLO
D. Teff t, Administrator, Bureau of Radiological Health, State of New Hampshire
S. Comley, Executive Director, We the People of the United States
Distribution w/cv of Licensee Response Letter
Region i Docket Room (with concurrences)
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Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
H. Miller, RA
W. Axelson, DRA
R. Conte, DRP
M. Conner, DRP
C. O'Daniell, DRP
K. Kennedy, OEDO
R. Correia, NRR (RPC)
F. Talbot, NRR
D. Serenci, PAO, ORA
DOCDESK
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\sb9703.rpy
Ta ,eceive e copy of thle document. Indcate in the boa: 'C' = Copy wrthout ettechment/ enclosure
'E' = Copy with attachment / enclosure
'N' = No copy
OFFICE
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OFFICIAL RECORD COPY
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Nonh Atlane Enna Smice Corgioration
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P.O. Box 300
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Atlantic
Seaino a siio3874
(603) 474 9521
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Tlie Northeast Utilities System
August 29,1997
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Docket No. 50-443
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NYN 97095
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AR# 97019225
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United States Nuclear Regulatory Commission
Attention: Document Control Desk
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Washington, D.C. 20555
Seabrook Station
1[cply to Notices of Violation
- This letter responds to the Notices of Violation described in NRC Inspection Report 50-443/97
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03. The reply is provided in the enclosure along with commitments made in response to the
violations.
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Should you have any questions concerning this response, please contact Mr. Terry L. Ilarpster,
Director of Licensing Services, at (603) 773 7765.
Very truly yours,
e
NORTil
EANTic ENER 'Y SERVICE CORP.
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Executive Vicc Pr sident a
Chief Nuclear Ofncer
cc:
11. J. Miller, Region 1 Administrator
A. W. De Agazio, Sr. Project Manager
F. P. Bonnett, NRC Senior Resident inspector
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REPLV TO A NOTICE OF VIOLATION
NitC Inspection Iteport 97-03 describes tm violations. The first violation identifies North
Atlantic's failure to control licensee designated vehicles insida the Protected Area as required by
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
Atlantic's response to these violations is provided below.
1.
Dncription of the Violations
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The following are restatements of the violations:
A.
Section 6.7.4, Licensee Designated Vehicles (LDVs), of the Seabrook Station Physical
Security Plan, Itevision 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.
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Contrary to the above, on hiay 22, i>>7, vehicle number LDV 16-02 was found
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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).
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10CI:lt 50, Appendix B, Criterion XVI, Correc'ive 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 and
nonconformances are promptly identified and corrected.
Contrary to the above, on hiay 27, 1997, during Emergency Core Cooling System
(ECCS) valve testing, a temporary tygon tube failed that was installed on flow transmitter
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 insuflicient pressure rating have occurred in the past three
years.
This is a Severity 1.evel IV Violation (Supplernent 1).
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11.
Reply to the Notices of Violation
A.
Designated Vehicle Left Unattended with Keys in the Ignition and Running-VIO 47-03-
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Reason for the Violation
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Nonb Atlantic agrees with this violation. The Seabrook Station Physical Security Plan (SSPSP)
requires that a licensee designated vehicle (LDV) inside the protected area be controlled by the
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authorized operator at all timca or have its ignition locked and the keys removed.
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Contrary to the above, on hir.y 22,1997, the NRC Resident inspector identified that LDV #16-02
was unattended with its engine running and keys left in the ignition. The Inspector informed a
Security Officer of the condition. The Security Officer turned off the vehicle's engine, took
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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 farm tractor with a small trailer that was used to make routine deliveries inside
protected area during th: recent refueling outage, OR05. The vehicle was driven to the south side
of the Diesel Generator iluilding and backed into the area next to the building to be unloaded.
The operator left the vehicle running while the vehicle was being unloaded. The operator
- ubsequently 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 v,as coached and counseled on the requirements of controlling LDVs.
hiaintenance Services vehicle operators were briefed on the event and they ainowledged
their understanding of the LDV program.
2. Three articles were printed in Seabrook Station intemal publications, two in the "OR05
Outage liighlights," hiay 24, hiay 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 h1ust 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.
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Date When Comnliance Will Be Achieved
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North Atlantic is in compliance with the SSPSP.
B.
Failure to Take Adeauate Corrective Actions for Use of Pressure Tubing-VIO 97-03 f '
Reason for the Violation
North Atlantic agrees with this violation. A root cause evaluation of the OR05 event included a
review of similarities between this event and four previous events which resulted in burst tublog.
This event and the four prior events are described below.
On May 27,1997, during OROS, 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
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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 briefing 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 of 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 I&C technicians on pressure ratings of tubing and hoses
used for testing and preventive maintenance. 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 oserpressurized and ruptured due to improper operation of a pressure regulator.
This was caused by a personnel error, however, it also was not similar to the May 27,1997 event.
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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
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of temporary equipment to process systems. This guidance requires the utilization of high
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pressure tubing for connections to inservice components. Training for 1&C personnel on this
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guidance and this event will be completed by September 19,1997.
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Programmatic Corrective Actions
1. North Atlantic recognizes that while significant improvement has been made in the corrective
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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 perfoimance 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
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drivers in their organization and strategies to address them in addition, we are developing a
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perfonnance monitoring system that will include 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.
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