ML20199M044
| ML20199M044 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/25/1997 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-443-97-05, 50-443-97-5, NYN-97117, NUDOCS 9712020179 | |
| Download: ML20199M044 (3) | |
Text
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'Ihe Northeast Utilitica System November 25,1997 Docket No. 50-443 NYN-97117 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Seabrook Station Renly to Insnector Follow-un item 97-05-01 In a letter dated October 27, 1997 the NRC requested additional information regarding the programmatic controls for the deficiency evaluation process. The enclosure to this letter provides North Atlantic Energy Service Corporation's (North Atlantic) response to this request.
North Atlantic is making certain commitments in response to this request. The commitments are fully described in the enclosure to this letter.
Should you have any questions concerning this response, please contact Mr. Terry L. Ihrpster, Director of Licensing Services, at (603) 773-7765.
Very truly yours, NORTil ATLANT C-EhM VICE CORP.
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Executive Vice Presiden Chief Nuclear Officer cc:
H. J. Miller, Region 1 Administrator C. W. Smith, NRC Project Manager, Seabrook Station R. K. Lorson, Senior Resident Inspector, Seabrook Station 9712O20179 971125 '
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Reply to Inspector Follow-up Item 97-05-01 NRC inspection Report 97-05 requested North Atlantic to describe the actions taken or planned to address weaknesses in the programmatic controls for the deficiency evaluation process. North Atlantic's response to this request is provided below.
1.
Inspector Follow-un Item During the inspection conducted on August 25 to Septemb. r 10, 1997, the NRC requested additional information describing the actions taken or planned to address the weaknesses in the programmatic controh of the deficiency evaluation process, The following is a restatement of the request:
"One area of particular concem was the adequacy of the station work control procedures for the deficiency evaluation process. The team found that the process as described in procedures MA 3.0 and 3.1 had weak programmatic controls in that system engineer responsibilities are not well defined and formalized with controls, and there was an unc! ear linkage to the processes that address safety evaluations and plant design changes. We (the NRC) understand that, in response to the team's finding, your si'e organization has initiated actions to address these issues. Please respond to this letter within 30 days to describe the actions taken and planned."
II.
Reason for the Insnector Follow-uo item The deficiency evaluation process was initiated at Seabrook Station after plant personnel conducted benchmarking visits at other plants to identify strengths in their work control programs. The deficiency evaluation process was identified as a method to inform personnel that a deficiency has been determined to be acceptable as stated within the conditions specified on the deficiency evaluation tag. Prior to the deficiency evaluation process, such deficiencies ' vere identified in the field, a deficiency tag was placed on the component, a work request was generated to address the concem, the system engineer evaluated the condmon as being acceptable and voided the work request, and the deficiency tag was removed. The deficient condition was then identified at a later date by another individual and the process was repeated.
The deficiency evaluation process was identified as an improvement to the work control program in that it eliminated repetitive work requests by identifying the condition and providing an evaluation and a means for a periodic review. Nonh Atlantic considers that there is value in the deficiency evaluation process. However, the programmatic controls identifying the system engineer's responsibilities were not fully implemented. Aller recent evaluation of our deficiency evaluation process (ACR 97-2032) and in light of the NRC concerns in IFl 97-05-01, North Atlantic has decided to discontinue the use of this program until a further in-depth review of the deliciency evaluation process can be performed.
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Corrective Actions North Atlantic has initiated the following corrective actions:
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- 1. North Atlantic has removed the 36 existing deficiency evaluation tags (green tags) from plant equipment and replaced them with deficiency tags (orange tags). This activity is complete.
Each of these deficiency tags will require the evaluation of the equipment deficient condition as part of the normal work control process. Preliminary review of the work requests indicate that these items do not have any adverse impact on plant safety.
- 2. North Atlantic has revised the Maintenance Manual (Sections MA 3.0 and 3.1) to delete the deficiency' evaluation process. This activity is complete.
- 3. North Atlantic will be implementing a 12 Week System Week process which will require open work documents to be worked or evaluated on each system week (under a 12 week
. process, this review will occur four times per year). The current system week process requires open work documents to be evaluated twice a year. It is anticipated that the 12 Week System Week process will be implemented during the first quarter of 1998.
- 4. North Atlantic will perform a root cause evaluation to' determine why the deficiency evaluation process was not effectively implemented.
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