ML20217F059
| ML20217F059 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/23/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-443-97-09, 50-443-97-9, AR#97031129, AR#98003729, AR#98004482, NYN-98042, NUDOCS 9803310253 | |
| Download: ML20217F059 (7) | |
Text
.L'J uo A-North North Atlantic Energy Service Corporation P.O. Box 300
-Atlan. ic Seahreet.un 03874 t
i
-(603) 474-9521 The Northeast Utilities System March 23,1998 Docket No. 50-443 NYN-98042 AR#98003729 AR#97031129 (ACR 97-2772)
AR#98004482 (ACR 98-0680)
United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station Reply to a Notice of Violation This letter responds to the two violations and one unresolved item identified in Inspection Report 97-09. The enclosure to this letter provides North Atlantic Energy Service Corporation's (North Atlantic) response to these violations. The enclosure also provides additional information regarding the unresolved item.
North Atlantic is making certain commitments in response t.o the violations and unresolved item.
The commitments are fully described in the enclosure to this letter.
Should you have any questions concerning this response, please contact Mr. Terry Harpster, Director of Licensing Services, at (603) 773-7765.
Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.
/Aff / A&
C. Feigni6auTn
[
] g } ;, O Executive Vice P sident and ChiefNuclear Offic t
- e,ci-H. J. Miller, NRC Region I Administrator l
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C. W. Smith, NRC Project Manager, Project Directorate 1-3 t
R. K' Lorson, NRC Senior Resident Inspector 9803310253 980323 PDR.ADOCK 05000443 0
PDR,1
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ENCLOSURE TO NYN-98042
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l REPLY TO A NOTICE OF VIOLATION NRC Inspection Report 97-09 describes two violations and one unresolved item regarding the Seabrook Station Measuring and Testing Equipment (M&TE) program. The first violation involves the revision to procedure MA2.3 " Control and Calibration of Measuring and Test Equipment," without performing a 10 CFR 50.59 evaluation. The second violation involved a failure to control, calibrate and adjust certain M&TE at specified periods to maintain accuracy within necessary limits.
I.
Description of Violations:
The following are restatements of the violations:
A.
VIO 97-09 Failure to Perfonn a 10 CFR 50.59 Evaluation When Procedure MA2.3 Was Changed 10 CFR 50.59, " Changes, tests and experiments," in part, permits the licensee to make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report without prior Commission approval, provided the change does not involve a change in the technical specifications or an Unreviewed Safety Question (USQ). The licensee shall maintain records of changes in the facility and these records must include a written safety evaluation which provides the bases for the determination that the change does not involve a USQ.
UFSAR, section 17.2.12.3, Calibration, states, in part, that primary standards have an accuracy of at least four times the required accuracy of the end use equipment being calibrated.
Contrary to the above, on March 13,1997, the licensee changed procedures as described in the UFSAR and failed to perform a written safety evaluation to determine that the change did not involve an unreviewed safety question (USQ). Specifically, the licensee changed procedure MA 2.3," Control and Calibration of Measuring and Test Equipment,"
Section 4.1.8, which implements UFSAR, Section 17.2.12.3, to modify the requirement for accuracy of the primary standards such that the procedure no longer required that the primary standard have an accuracy of at least four times the required accuracy of the end use equipment being calibrated. No safety evaluation was performed to determine that the deletion of the requirement to compare the accuracy of the primary standard with the end use equipment did not involve a USQ.
This is a Severity Level IV Violation (Supplement I).
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1 B.
VIO 97-09 M&TE Was Not Properly Controlled 10 CFR 50, Appendix B, Criterion XII, " Control of Measuring and Test Equipment,"
requires measures to be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
UFSAR, Section 17.2.12.3, Calibration, states, in part, that primary standards have an accuracy of at least four times the required accuracy of the end use equipment being calibrated. Less acconte standards may be acceptable when the use of such standards and the basis of calihion acceptance is authorized and documented.
Contary to the above, prior to January 21,1998, measuring a.nd testing devices were not properly controlled to maintain accuracy within necessary limits. Procedure MA 2.3, section 4.4.2, which implements UFSAR, section 17.2.12.3, did not require authorization and documentation for standards less accurate than 4:1.
This is a Severity Level IV Violation (Supplement I).
II.
Reply to Violations:
A.
VIO 97-09 Failure to Perform a 10 CFR 50.59 Evaluation When Procedure MA2.3 Was Changed Reason for Violation I
North Atlantic agrees with this violation. Procedure MA2.3," Control and Calibration of Measuring and Test Equipment", provides the programmatic controls 'to implement UFSAR requirements regarding the control and calibration of measuring and test equipment. Revision 15 to MA2.3 replaced the reference to " Primary Standard" in section 4.8 with " Standards" to eliminate confusion with true primary standards maintained by the National Institute of Standards and Technology.
The requirement to maintain a 4:1 ratio between the accuracy of a standard and the end-use-device was changed to require a 4:1 ratio between the standard and the M&TE being calibrated.
The Seabrook Station M&TE Procedure TD1875.02," Calibration Program," requires that M&TE "..must not be less accurate than the device being calibrated." Combining the M&TE requirements in TD1875.02 with the requirements in MA2.3, Revision 15, maintains an overall ratio of 4:1 between the standards and the end use equipment.
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Revision 15 to MA2.3 in conjunction with TD1875.02, implements criteria which are consistent with the requirements contained in UFSAR Section 17.2.12.3. The administrative control of calibration ratios between calibration standards and M&TE is commensurate with the guidance contained in NUREG-0800," Standard Review Plan", Article 17.2.12 and IEEE Std. 498-1990, "lEEE Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities".
Based on the above, the personnel involved in developing and reviewing the change to MA2.3 did not recognize that it changed a procedure as described in the UFSAR and as a result they did not perform a written safety evaluation. In addition, the requirements for documenting the basis for 10 CFR 50.59 screening evaluations was not part of the 10 CFR 50.59 evaluation program when MA2.3, Revision 15 was issued. Procedure revisions now require documented bases for 10 CFR 50.59 screening evaluations and the detemiination that a safety evaluation is not required.
Corrective Actions:
- 1. The individuals involved in this event have been coached and counseled. This activity is complete =
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- 2. After receipt of the Notice of Violation, North Atlantic performed a safety evaluation for MA 2.3, Revision 15. This evaluation determined that the changes to MA2.3 did not create an
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unreviewed safety question. This is complete.
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- 3. North Atlantic prepared an UFSAR Change Request to revise UFSAR Section 17.2.12 to clarify the guidance in accounting for calibration ratios which fall below the 4:1 ratio. This is complete.
- 4. North Atlantic will be implementing an annual requalification program for personnel performing 10 CFR 50.59 evaluations. This will be completed by July 30,1998.
B.
VIO 97-09 M&TE Was Not Properly Controlled Reason for Violation:
North Atlantic agrees with this violation. Revision 15 to MA2.3 did not require a formal evaluation by Engineering to determine the effect on engineering calculations when there was a change in M&TE accuracy. The reason for this inadequacy was the individuals involved in the preparation and review of MA2.3, Revision 15 did not adequately review the UFSAR and incorporate the UFSAR requirements into the procedure. Upon discovery, North Atlantic promptly implemented a non-proceduralized evaluation process. Subsequently, MA2.3 was revised to provide the procedural requirements for evaluating changes to M&TE accuracy.
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,i ',t Corrective Actions:
1.' The individuals involved in this event were coached and counseled. This activity is complete.
'2.
MA2.3 was revised (Revision 15, Change 1) to formalize the review process used to evaluate
- changes to M&TE accuracy. This is complete.
'111.
Descrintion of Unresolved lica The following is a restatement of the unresolved item:
URI 97-09 Assessment ofInstruments to Determine Safety Significance The NRC found that North Atlantic has not completed the overall review of the impact of revised M&TE accuracies. As part of the Notice of Violation, the NRC requested that North Atlantic provide a completion date for this review.
North Atlantic will complete the review by October 1,1998.
IV.
Date When Full Comnllance Will Be Achieved North Atlantic is in compliance with the M&TE requirements as defined in UFSAR Section 17.2.12.
44,
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NORTH ATLANTIC COMMITMENTS
- 1. North Atlantic will be implementing an annual requalification program for personnel performing 10 CFR 50.59 evaluations. This will be completed by July 30,1998.
- 2. North Atlantic will complete the review of M&TE accuracies by October 1,1998.
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