ML20212C257
| ML20212C257 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/23/1997 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-443-97-04, 50-443-97-4, AR#97017022, AR#97023545, NYN-97108, NUDOCS 9710290134 | |
| Download: ML20212C257 (5) | |
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___._____..._______...__._____m Mg\\m...,k North Nonh Atlantic 1:nng Senim aspomtion l'.O. Ilox 300
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(603)474-95'11
'Ihe Northeast Utilities Systern October 23,1997 Docket No. 50-443 NYN-97108 AR# 97017022 AR# 97023545 United States Nuclear Regulatory Commission At'.cntion: Document Control Desk Washington, D.C. 20555 Seabrook Station lieply to Notices of Violation This ktter responds to the Notices of Violation described in NRC In.ra etion Report 50-443/97 04 The reply is provided in the enciosure along with commitments made in response to the violations.
Should you have any questions concerning this response, please contact Terry L. Ilarpster, Director of Licensing Services, at (603) 773 7765.
Very truly yours, I
NORTil ATLANTIC ENERGY SERVICE CORP.
b f/
~~
Ted C. Feigenbaum '
Executive Vice President and Chief Nuclear Officer -
cc:
IL J. Miller, Region i Administrator A.W. De Agazio, Sr. Project Manager
%u R. K. Lorson, NRC Senior Resident inspector
/
9710290134 971023 P
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e IEpLY TO A NOTICE OF VIOLATION NitC Inspection Report 97 04 describes two violations. The first violation identifies North Atlantic's failure to revise two safety related procedures to incorporate new Cycle 6 boron concentration limits prior to startup from refueling outage five. 'ihe second violation describes North Atlantic's failure to process two procedure revisions utilizing the station qualified reviewer or the SOllC review process. North Atlantic's response to these violations is provided below.
I.
Descrintion of the Violations The following are restatements of the violations:
A.
Technical Specification 6.7.1.a states, in part, that written procedures as recommended in Appendix A of llegulatory Guide (RO) 1.33, shall be maintained. Appendix A of RG 1.33 requires emergency and abnarmal procedures.
Contrary to the above, between June 27 and July 8,1997, emergency procedure, ES-0 I, Reactor Trip Response, and off normal procedure OS1202.04, Rapid floration, were not revised (or maintained) to incorporate the new Cycle 6 boron concentrations required to be injected in the event that more than one control rod failed to fully insert during a reactor trip. As a result, the plant operated for 11 days, since the start of Cycle 6 without updated boron values in these procedures.
This is a Severity Level IV Violation (Supplement 1).
B.
Technical Specification 6.7.5 states, in part, that changes to procedures may be made prior to a Station Qualified Reviewer (SQR) or Station Operation Review Committee (SORC) review provided, the intent was not changed, and the change was approved by two members of the plant management, at least one of whom holds a Senior Operator license.
Contrary to the above, on August 6,1997, the operators changed the lineup of the safety injection system test header from the primary drain tank to the refueling water storage tank without properly changing procedure OS 1005.05. Safety injection System Operation. The procedure change constituted a change in intent and bypassed the SQR or SORC review process.
This is a Severity Level IV Violation (Supplement 1).
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II.
Reply to the Notice of Violation A.
Lvo Safety Related Prucedures Not Revised Prior to Startun-VIO 97-04 02 Reason for the Violation North Atlantic agrees with the violation. North Atlantic's design control approval process requires that the review and approval of a Design Change Record (DCR) be performed by those departments identified on the Interdiscipline Review Sum' ary Form to ensure that all affected m
procedures are identified.
l The cycle 6 core design was processed as a Design Change Record. Ilowever, the two alTected l
procedures, ES 0.1 " Reactor Trip Response" and OS1202.04, " Rapid lloration" were not i
identified as affected procedures requiring revision to incorporate a new boron concentnition value. The new boron concentration values are not developed as part of the DCR package but are a product of a calculation that is performed by Reactor Engineering (RE) while updating technical data alTected by the DCR aller the DCR has been approved.
The new boron concentration number was calculated and the Reactor Engineering Technical Data Book, Figure RE.18, was revised with the new boron concentration value on June 23,1997, prior to cycle 6 startup.
The boron concentration values that are used to update ES 0.1 and OS1202.04 are obtained from the Seabrook Setpoint Study, setpoint ID A25 "Doration Value (PPM) for Stuck Rod Concern."
The basis for setpoint ID A25 in the Seabrook Setpoint Study, referenced a value from the UFSAR that was part of the original core design and was not recognized as subject to change with the new longer life core designs. The reason that procedure ES 0.1 and OS1202.24 were not identified as requiring revision is because the design control process did not provide adequate consideration of all variables (e.g., procedures), that may require revision due to the development of a long duration core or a core with unique considerations. The process relied upon the reviewers to identify the inter-relationship between the design and the procedures.
The Seabrook Setpoint Study was not reviewed and updated during the development and review of the cycle 6 core design. The incorrect value in ES-0.1 and OS1202.04 was identified by the Operations department during the annual Emergency Procedures setpoint review, in addition, during reviews performed as part of the corrective actions, it was determined that procedure OS1202.04 may be using a non-conservative methodology to determine the rapid boration value for two or more stuck rods when the Refueling Water Storage Tank (RWST) is used as the makeup source. This concern has been corrected.
There were no adverse safety issues associated with this event. Technical Specification Surveillance Requirement 4.1.1.1.1.a requires that within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> aller detection of an inoperable control rod, the required shutdown margin be verified acceptable with an increased allowance for the withdrawn worth of the immovable or untrippable control rod (s). This verification wor.d be accomplished using procedure RX1707," Shutdown Margin Surveillance." The data necessary Page 2 of 4
to calculate the required increase in shutdown boron concentration (Figure RI? 18) was updated for the cycle 6 design on June 23,1997. Thus, the data necessary to perfonn a shutdown margin verification in response to stuck control rods prior to updating the Rapid lloration procedure was current for the cycle 6 design at the time of cycle 6 startup. Funhermore, there was enough conservatism in the beginning of cycle 6 conditions and in the method used to account ihr stuck rods to show that shutdown margin requirements would have been met with the existing boric acid concentrations.
Corrective Actions North Atlantic has initiated the following corrective actions:
1 1)
Procedures liS 0.1, " Reactor Trip Response" and OS1202.04, " Rapid lloration" were revised to reference Figure Ri? 18 of the Reactor !!ngineering Technical Data llook fbr the correct boron concentration values, including boration using the RWST as a souice.
2)
A review was performed to determine if the implementation et the Cycle 6 core design afTected the Core Operating 1.imits Report (COLR), Technical Data llook, Technical Specifications, Reactor !!ngineering and Operations Procedures. No additional procedure changes were identified as a result of the Cycle 6 core design implementation.
3)
The basis for setpoint ID A25 in the Seabrook Setpoint Study was reced to reference the value in Figure Rl!-18 of the Reactor IIngineering Technical Data llook.
4)
A checklist will be developed for future core reload DCR's to assist in the identification of those variables that will require review for potential revision as part of the core design process.
Date When Comnliance Will lle Achieved North Atlantic is currently in compliance with Technical Specification 6.7.1.a.
11.
Failure to Perform a Temnorary Change to Procedure-VIO 97-04 03 Reason for the Violation North Atlantic agrees with the violation. On August 6,1997, while using Procedure OS1005,05,
" Safety injection System Operation," it was noticed that during an attempt to seat an limergency Core Cooling System (ECCS) check valve, flow was present from the Refueling Water Storage Tank (RWST) through the ECCS check valve test header to the Primary Drain Tank ( PDT). This flow made it difficult for the Operations crew to determine if leakage was decreasing during the attempts to seat the leaking check valve. The Operations crew realigned the Safety inj etion System (SI) test header to the RWST. The Operations crew felt that alignment to the RWE.i was permitted since the section of OS1005.05 being used had the ibliowing Caution statement:"RCS Page 3 of 4 w
activity must be less than 0.0024 microcuries per gram dose equivalent 1131 and less than 0.24/l! microcuries per gram of gross activity to align to the RWST" and RCS activity was well within these limits. Since OS1005.05 did not provide specific instructions for the alignment to the RWST, the Operations crew chose to use the Miscellaneous Component 1.og, as defined in Procedure OS1090.05, " Component Configuration Control," to perform the alignment and maintain component configuration control. The Miscellaneous Component Log provides a method for controlling components that are not locked, or maintained, and are not being l
positioned by a procedure or other administrative controls.
The use of OS1090.05 to realign the Safety injection Test 11eader was inappropriate and procedure OS1005.05 should have been revised as an intent change via the procedure revision process.
Corrective Actions North Atlantic has initiated the following corrective actions:
- 1) Procedure OS1005.05 was revised to incorporate instructions for alignment of the Safety injection Test lleader to the RWST or the PDT.
- 2) Procedure OS1090.05 will be reviewed and additional guidance will be developed :s necessary, to ensure the Miscellaneous Component Log is used for the correct upplication.
- 3) This event will be reviewed during Operations continuing training.
Date When Full Comollance Will lic Achieved North Atlantic is currently in compliance with Technical Specification 6.7.5.
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