ML20207P522
| ML20207P522 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/12/1987 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NYN-87004, NUDOCS 8701160213 | |
| Download: ML20207P522 (3) | |
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b George S. Thomas Vice Prendent-Nuclear Produchon Pdec Service of New Hampshire New Hampshire Yankee Division January 12, 1987 NYN-87004 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Document Control Desk
References:
(a) Facility Operating License NPF-56, Docket No. 50-443 (b) USNRC Letter, Dated December 12, 1986, " Inspection Report No. 50-443/86-47", Edward C. Wenzinger to Robert J. Harrison Subj ect: Response to Inspection Report No. 50-443/86-47 Gentlemen:
In accordance with the requirements of the notice of violation identified in Reference (b), enclosed please find our response to that violation.
Should you have any questions concerning our response, please contact Mr. Warren J. Hall at (603) 474-9574, extension 4046.
Very truly yours,
' ; /d e
Geor S. Thomas Enclosure cc: Regional Administrator U.S. Nuclear Regulatory Commission - Region I 631 Park Avenue King of Prussia, PA 19406 Mr. A. C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874 h
8701160213 870112 PDR ADOCK 05000443 I
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P.O. Box 300. Seabrook, NH 03874. Telephone (603) 474-9574
' ENCLOSURE TO NYN-87004.
NHY RESPONSE TO NOTICE'0F VIOLATION Notice of Violation 86-47-03 10,CFR 50, Appendix.B, Criterion XIV and the Seabrook Station FSAR,
.Section 17.2.14 require that adequate measures be established for indicating the operating status of components and that operations are -
controlled by documented procedures to assure' positive control and preclude ' inadvertent operation.
Seabrook Station, Unit No. 1 Facility Operating License NPF-56, paragraph 2.C (11) C states that certain valves (reference: PSNH letter to the USNRC, SBN-1196, dated September 17, 1986) will be mechanically locked closed with chains and padlocks. New Hampshire Yankee Station Operating Procedure, OS86-1-7 (Revision 1) indicates that under no cor.ditions shall the valves listed on form OS86-1-7A (the list of which comprise an attachment to SBN-1196) be unlocked and operated.
Contrary to the above, on October 23, 1986, a valve-(CS-V-744) listed on form OS86-1-7A was found to be mispositioned, i.e.,
locked open with a chain and padlock. The administrative measures that were established to implement procedure OS86-1-7 to verify the closed, locked and chained position of valve CS-V-744, were not adequate in that they lacked the requisite clarity _ to assuro positive control and preclude inadvertent operation. While the violation of NPF-56, paragraph 2.C (11) C was identified and properly reported by the licensee, the measures established by the licensee to control valve position in accordance with the Facility Operating License failed to meet 10 CFR 50, Appendix B in a manner which adequately addressed all conditions of surveillance, including frequency of performance and methods of valve locking.
Response
The violation occurred due to the valve being stuck open at the time of the original valve line-up. The operator initiating valve line-up procedure, OS86-1-7, incorrectly interpreted the lack of valve movement in the closed direction as indicative of the valve being closed. Additional operator surveillances to verify the locked valve list in Procedure OS86-1-7 were hindered by the configuration of the locking device.
Immediate Corrective Actions The following immediate corrective actions were initiated upon discovery of the mispositioning of valve CS-V-744:
o Valve CS-V-744 was closed and locked.
All other valves identified in OS86-1-7 were verified to be correctly o
positioned and locked to ensure that this was an isolated case.
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NHY RESPONSE TO NOTICE OF VIOLATION (CONT' D)
Training of all. auxiliary operators responsible for checking valve o
position was initiated to ensure that proper identification of valve-positions could be~ accomplished. prior to the auxiliary operators performance of the required verification checks. This training was
. conducted by each Shif t Superintendent with 'their respective
. operators.
A study was performed to determine the possible consequences of the o
CS-V-744 mispositioning during the time period the valve was open.
The study consisted of a review of associated drawings and-remaining valve alignments to investigate any possible dilution paths. No dilution paths were identified.
A review of chemistry records was performed of Reactor Coolant System o-samples taken before and after the discovery of the valve mispo-sitioning.to determine if any dilution of the system had occurred.
The results showed that no dilution had taken place.
o A work request "as issued to modify the locking device to allow the -
operators to more readily identify valve position without having to physically unlock the valve and remove the locking device cap.
-h Term Corrective Action Direction has been given to all operators specifying that they immediately notify management or initiate a temporary procedure change upon identification of any problems associated with unclear procedures.
Additionally, the Seabrook Training Center has included, as part of the required reading segment of the ongoing licensed operator and auxiliary operator training programs, information detailing the subject event, corrective actions taken, and proper methods for valve position identification.
It is anticipated that all operators will finish the required reading by March 31, 1987, thereby completing all corrective actions outlined herein.
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