ML20214E176

Responds to NRC Re Violations Noted in Insp Rept 50-443/87-02.Corrective Actions:Procedure Change to OS1023.51 Initiated & Implemented to Ensure That Appropriate Purge Valve Open Regardless of Which Air Intake Utilized

ML20214E176
Person / Time
Site:	Seabrook
Issue date:	05/15/1987
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NYN-87064, NUDOCS 8705210692
Download: ML20214E176 (4)

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George S. Thomas wce Pre-Nuclear Producson I

Putsc Service of New HampeNro New Hampshire Yankee Division NYN-87064 May 15, 1987 United States Nuclear Regulatory Commission Wr.shington, DC 20555 Attention: Document Control Desk

References:

(a) Facility Operating License NPF-56, Docket No. 50-443 (b) USNRC Letter, Dated April 10, 1987, " Inspection Report No. 50-443/87-02," Edward C. Wenzinger to Robert J. Harrison Subj ect: Response to Inspection Report No. 50-443/87-02 Centlemen:

In accordance with the requirements of the notice of violation identified in Reference (b), enclosed please find our response to that violation.

This response had originally been required no later than May 10, 1987.

Ilowever, discussions with the Senior Resident Inspector, Mr. A. C. Cerne, on May 6,1987, determined that a delay in response until May 15,1987, was acceptable and that he would notify the appropriate Regional personnel of this change. ,

Should you have any questions concerning our response, please contact Mr. Warren J. Hall at (603) 474-9574, extension 4046.

Very truly yours, 8705210692 870515 PDR ADOCK 05000443 0 PDR aje S/

George S. Thomas Enclosure cc: Mr. William T. Russell Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. A. C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874

.pbu I P.O. Box 300 . Seabrook, NH 03874 . Telephone (603) 474 9574 /

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i ENCLOSURE TO NYN-87064 NOTICE OF VIOLATION During an NRC inspection conducted on January 3 - March 9, 1987, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (Enforcement Policy 1986), the violation is listed below:

10 CFR 50, Appendix B, Criterion III and the Seabrook Station FSAR, Section 17.1.1.3 require that measures be established to assure that applicable regulatory requirements and the design basis for safety related structures, systems and components are correctly translated into specifications, drawings, procedures and instructions. FSAR Section 9.4.1 states that the control room makeup air subsystem is capable of normally maintaining a positive pressure within the complex at all times with respect to adjacent areas and the outside atmosphere to prevent the infiltration of air from local areas which could under certain circumstances contain objectionable contaminants. Station operating procedure OS1023.51 provides the method to be used in operating the makeup ventilation subsystem.

Contrary to the above, on March 3, 1987, the control room makeup air subsystem was identified to be in a configuration which did not preclude the infiltration of air which could contain objectionable contaminants.

This lineup did not take into account leakage past normally closed valves with a makeup air fan operating. This problem was caused by a change to OS1023.51 (Revision 3) which did not adequately address the complete design basis of the control room makeup air subsystem, as was supportable by existing design calculations. Specifically, a lineup for operation with the normally open intake isolated and makeup supplied from the normally isolated intake was not considered or documented by the procedural change. This failure to translate the design basis into a procedural requirement resulted in an inappropriate system configuration, as identified on March 3, 1987.

RESPONSE

On March 3,1987, a "B" train radiation monitor in the east air intake of the Control Room Makeup Air Subsystem of the Control Building Air Handling System (CBA) failed, and the Unit was placed into Technical Specification Action Statement 3.3.3.1 for an inoperable radiation monitoring instrument. The Shif t Superintendent (SS), af ter some discussion with the NRC Resident Inspector, placed the unit in the more restrictive Action Statement of Technical Specification 3.7.6. The SS then directed that the east air intake be closed and that the west air intake be opened.

Normal operation of the control room make up air subsystem is with the east intake (1-CBA-V9) open and the west intake (2-CBA-V9) closed. The purge valve for the east intake (1-CBA-V4) is closed and the purge valve for the west intake (1-CBA-V2) is open.

t During the course of the switchover from the east air intake to the west air

intake, the west intake purge valve was closed and the east intake purge valve l

was never opened.

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s LA revision ~to OS1023.51 on January 7,1987 established the normal operating lineup for the CBA System.' This lineup was with the east air intake (1-CBA-LV9) normally open and its associated purge valve.(1-CBA-V4) closed; the west air intaka .(2-CBA-V9): normally closed and its associated purge valve (1-CBA-

~V2) open. The' procedure did not provide direction to the operators as to appropriate valve lineups if the normai intake were switched to the west air

-intake.--This failure to translate information into procedures accounted for

-the inappropriate system configuration.

As a result of'the above stated violation, the following corrective actions have been taken:

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1) On the date of the violation, a procedure change to OS1023.51 fhad been initiated to include an expanded note that would have required,that if the east air intake (1-CBA-V9) is closed, then-the' east air intake purge valve-(1-CBA-V4) must be open, and if the west air' intake (2-CBA-V9) is closed, then the west air intake purge valve (1-CBA-V2) must be open. This procedure change was subsequently implemented to assure that the

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appropriate purge valve was open regardless of which air intake was being utilized.

2) PSNH Letter (NYN-87051) dated April 9,1987, provided a post-LOCA Control Room dose analysis which assumed a 50cfm inleakage past a closed intake isolation valve as a radiological contributor. The results of the analysis indicate that doses remain well within regulatory limits at 5%

power. Based upon this analysis, both purge valves could be normally closed and purging would only be performed in response to detection of 1 high radiation in a remote. air intake.

~3) On April 13, 1987, Operating Procedure OS1023.51 was revised to reflect the following:

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a) The last sentence to Section 3.0, Precautions, was deleted. This indicates that purge valves 1-CBA-V2 and 1-CBA-V4 associated with the west and east air intake respectively shall be normally aligned in the closed position.

b) Deletion of the first NOTE af ter step 6.6. This also indicates that the' purge valves will remain closed under normal operating conditions regardless of which intake is being utilized.

c) ' Deletion of NOTE 1 on Page 1 of 6 of " Control Room Ventilation System Lineup." This change indicates that the purge valves will remain closed under normal operating conditions regardless of which intake is being utilized.

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-An in-depth review of'the cause of this incident determined that-a lack of

" documented information flow contributed'to thisiviolation. In order to-preclude this type of incident,from reoccurring, the following actions will be taken:

1) 'A review of the Design Control Manual' will be undertaken. During'this review, engineering' interface, design. basis review considerations and the direction for translating design bases into procedures will be evaluated

. and, where necessary . procedural changes will be made. It is expected that this effort w111 be completed by July 15, 1987.

2) A procedure will be developed which provides a formal transmittal of -

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any recommended changes to Station procedures. The procedure will require i

that technical justification for the procedure changes ~ be provided if such-changes are required to support the design basis. The procedure will also

' provide'a. feedback provision to allow confirmation that the recommendations have been accepted or that alternatives have been appropriately justified. It is expected that this effort will be-completed by July 15, 1987.

3) Following review of the Design Control Manual, the Modification and Testing Program Manual will be reviewed to ensure. program consistency. It is expected that this effort will be completed by August 14, 1987.

Implementation of:the above corrective actions is expected to preclude

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problems of this nature from reoccurring.

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