ML20217N989
| ML20217N989 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/01/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-98066, NUDOCS 9805060023 | |
| Download: ML20217N989 (10) | |
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i North North Atlantic Energy Service Corporation P.O. Box 300 Atlantic Seabrook, NII 03874 n
(603) 474-9521 The Northeast Utilities System May 1,1998 Docket No. 50-443 NYN-98066 Ref.: AR#98006702 ACR 98-1088 AR#98007022 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station Reply to a Notice of Violation North Atlantic Energy Service Corporation (North Atlantic) provides in the enclosure, its response to a Notice of Violation forwarded in an April 1,1998 letter from H. J. Miller to T. C. Feigenbaum.
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 ATLAN SERVICE CORP.
C. Feiga46aum
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Executive Vice Presi t and
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Chief Nuclear Officer
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cc:
H. J. Millet, NRC Region I Administrator C. W. Smith, NRC Project Manager, Project Directorate 1-3 g
R. K. Lorson, NRC Senior Resident Inspector
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REPLY TO A NOTICE OF VIOLATION In a letter dated April 1,1998, the NRC described three violations involving the failure to promptly identify and/or correct conditions adverse to quality at Seabrook Station. The NRC classified the three violations in the aggregate as a Severity Level III problem.
1.
Description of Violatiom The following are restatements of the violation:
During an NRC inspection conducted between December 7,1997, and January 31,1998, for which an exit meeting was held on February 12,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC
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Enforcement Actions," NUREG-1600, the violations are listed below:
j 10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Contrary to the above, measures were not established to assure that significant conditions adverse to quality were promptly identified and corrected, and the causes of the conditions were determined and corrective action taken to preclude repetition.
Specifically, 1.
Between November 1996 and December 5,1997, a condition adverse to quality existed involving leakage from stainless steel pipe in the vicinity of the "B" Residual Heat Removal pump suction relief valve (RC-V-89), and this condition adverse to quality was not identified until December 5,1997, despite prior opportunities to do so. Specifically, a.
In November 1996, the licensee had been aware of the existence of boric acid residue external to pipe wrap material on the piping. However, the licensee did not remove the pipe wrap material to positively identify the source of this residue until December 5,1997 even though engineers, supervisors, and maintenance and health physics technicians had been aware of this condition.
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b.
During the June 1997 refueling outage, the licensee planned to remove the pipe wrap material and inspect this section of piping. Although a system engineer determined, on or about June 15,1997, that this work activity did not occur and informed his supervisor, an adverse condition report was not generated, and actions were not taken to remove the insulation and inspect
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the pipe prior to the start-up on June 26,1997.
2.
Since 1993, a condition adverse to quality existed involving degradation of the control building air conditioning (CBA) compressors, used to cool critical instruments within the control room for up to thirty days following a postulated accident, which resulted in multiple compressor failures. Corrective action was not taken until December 1997 to address the root causes for this condition, even i
though prior opportunities existed to address this problem.
Specifically, the i
licensee's staff compJeted an engineering evaluation in 1994 (to address a 1993 CBA compressor failure), and that evaluation resulted in development of a design change request to correct the root cause(s) for the compressor failure. Those causes included: loss of bearing lubrication caused by refrigerant contamination of the lubricating oil; and/or refrigerant slugging to the cylinder piston assembly.
l Although the modification was scheduled to be implemented in the third quarter of 1996, it was delayed several times and not implemented until after another CBA compressor failed on December 16,1997. In each of the prior cases when the compressors failed, the licensee's corrective actions focused on component replacement rather than correcting the root causes of the failures.
3.
In November 1997, the.NRC observed that a caution tag on a pressure switch for the Positive Displacement Charging Pump indicated that the pump could trip off from starting due to an oil leak from the pump's sensing line. Although this leak challenged the reliability of the pump, a component important to safety, the I
licensee's plans did not include repair of the leak until after installation of a modification to relocate the pressure switch. Ilowever, in October 1997, the plans for the modification were canceled without resolving this adverse condition.
These violations represent a Severity Level Ill problem (Supplement 1).
1 11.
Renly to Violation:
Reason for Violation:
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l North Atlantic agrees with the violation. The safety significance of each item individually was minimal. Ilowever, as described below, North Atlantic recognizes the p.-ed to enhance the operational focus at Seabrook Station to ensure that degraded conditions are promptly addressed.
During the SALP Board meeting on February 4,1998, North Atlamic acknowledged that the loss of proper operational focus and some complacency may have contributed to a tolerance for l
degraded equipment as evidenced by the examples above. Ilowever, once the items were 1
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identified, North Atlantic took prompt action to correct the conditions. Subsequent review of each item revealed that the safety significance of each issue was minimal and the existing programs properly identified the concerns. Ilowever, it was also noted, as stated above, that North Atlantic recognized that the organization needs to emphasize operational focus along with an aggressive followup to promptly correct degraded conditions.
1 As we stated during the pre-decisional enforcement conference, we had determined after receipt of the SALP report, that our performance had declined during the last year. We believe that we became distracted from our primary task of supporting the day to day operation of the plant with the allocation of some of our resources to projects like the 10 CFR 50.54(f) response. As a l
result, our operational focus decreased, we became somewhat complacent with the status quo and we began to tolerate and accept degraded or less than optimal plant equipment conditions, q
Aller receipt of the SALP report, we held a management meeting to ensure that the management
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team fully understood expectations and standards regarding the need to promptly restore the appropriate operational focus. Coming out of the meeting we established a 90 Day improvement Plan to provide prompt corrective action and to immediately redirect the organization in key areas. With a few exceptions, the actions described in the 90 Day Improvement Plan are not new and were already addressed in our 1998 Operational Plan. However, we reiterated some of the actions to ensure the organization received the appropriate direction. We have subsequently updated our 1998 Operational Plan to include attributes from the 90 Day Improvement Plan and we will continue to update and revise our plans as required.
The critical success factors established in our 90 day plan are:
Improve our operational focus and raise our standards, Improve communications, and Improve accountability.
The key initiatives that we have implemented to improve our performance and address degraded equipment or adverse conditions are described in Section 111 of this reply.
For each example of the violation described above, the reason for violation will be presented along with the corrective actions that have been taken. The corrective actions that are being taken to avoid further violations and to improve the operational focus will follow.
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- Residual Heat Removal Pumn Suction Relief Valve (RC-V89k Reason for Violation for RC-V89:
On December 5,199~7, system leakage of a drop every two to three minutes (weepage from four locations) was discovered on the inlet piping to the Residual Heat Removal pump 8B suction relief valve (RC-V-89).' The weepage sites were in the metal adjacent to the welds (heat affected zone) that connected the piping spool piece to the relief valve flange and the 3" to 12" weldolet that connected the pipe to the 12" RHR pump suction line. One weep was in the upper heat affected zone and three were in the lower heat affected zone.
Subsequent metallurgical evaluation, conducted by an independent laboratory, determined that only three, instead of four, through wall indications, one at the top and two at the bottom, existed. North Atlantic personnel perfonned a preliminary evaluation of the weepage sites and were unable to quantify the air leakage in Standard Cubic Feet per Hour (SCFH). Therefore, North Atlantic conservatively
- determined that the Limiting Condition for Operation for Technical Specification 3.6.1.1, Containment Integrity, could not be satisfied. North Atlantic declared the Containment inoperable and entered the referenced action statement. In addition, the Residual Heat Removal (RHR) and Containment Building Spray (CBS) systems, which utilize the same section of pipe, were declared inoperable. A plant shutdown was commenced and completed in accordance with the requirements of the Technical Specification. A one hour report was made to the NRC pursuant to 10 CFR 50.72(b)(i)(A).
The weepage sites were caused by chloride induced transgranular stress corrosion cracking (SCC). The source of the chlorides was a non standard insulating jacket that had been on this section of pipe since at least 1988. Independent laboratory analysis determined that the SCC had started on the outside of the pipe and had migrated inward. It is suspected that repeated wettings and dryings of the insulating jacket, caused by wetting of the surfaces during draining of the pipe as part of maintenance performed in refueling outages, may have caused the chlorides to concentrate on the pipe over time.
Boron residue was noted on this pipe section beginning in March of 1996 and continuing until the weepage was discovered on December 5,1997. During this time it was believed that the source of the boron was related to water spillage on the jacket and on insulation on the 12" RHR pump suction line during outage maintenance activities. It was believed that the water absorbed by the insulation was drawn up the jacket in a wicking process and then evaporated leaving the boric acid residue behind. This theory was reinforced by the fact that at no time did anyone report finding moisture or wet boric acid when inspecting or cleaning the boron buildup. For these reasons thejacket was not removed and a positive determination of the source of the boron
~ buildup determined until December 5,1997.
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The piping section containing the defects was removed and subjected to a leak rate test. The leak rate test pressurized the pipe to between 50 and 52 psig. This is greater than the containment design basis accident pressure of 49.6 psig. The makeup flow required to maintain the pressure at 50 - 52 psig was measured. The leak rate was determined to be 1.363 standard cubic feet per hour (SCFil). This compares to an allowed penetration leak rate of 37 SCFil or 0.05 L, as described in the containment leakage rate testing program. In addition, the piping section was analyzed with the assumption of a bounding 0.5 inch diameter through wall hole. The evaluation determined that the piping section and the weldolet were fully capable of carrying all design loads. The structural integrity of the piping system under all normal and accident conditions would have been maintained.
North Atlantic performed an engineering evaluation and determined that the piping spool was degraded and nonconfomling, but that the three systems, Containment, RHR and CBS were fully capable of performing their specified safety functions if required and were operable utilizing the j
guidance of Generic Letter 91-18, Revision 1. Therefore, North Atlantic withdrew the one hour report of December 5,1997.
Based upon the event evaluation and root cause analysis, it was determined that the boron residual indications were not promptly addressed due to the lack of the proper questioning attitude and the failure to implement the question, validate and verify (QV&V) principle.
Corrective Stens That Have Been Taken For RC-V89:
The spool piece and weldolet that attached to RC-V89 were replaced. This activity is complete.
- 2. An event evaluation and root cause analysis were performed. This activity is complete.
Control Building Air (CBA) Comnressors Reason for Violation for CBA Comoressors:
l On December 16,1997, with the plant in Mode 4, transitioning towards a restart following repair of the Residual IIeat Removal pump 8B suction relief valve inlet piping, both A & B trains of Control Building Air llandling (CBA) were declared inoperable. While compressor CBA-AC-5B was inoperable due to a mechanical failure, compressor CBA-AC-5A tripped causing operators to declare both trains of CBA inoperable on December 16, 1997. As a result. Technical Specification LCO 3.0.3 was entered and the plant was returned to Mode 5. A one hour report was made to the NRC pursuant to 10 CFR 50.72(b)(i)(A).
North Atlantic conducted a review of the CBA system history which revealed a total of eight compressor failures. Based upon this review, it is believed that the compressor failures in 1997 were caused by the same issues that had caused compressor failures in 1993,1994, and 1996.
These mechanical failures are attributed to a general loss of bearing lubrication caused by r
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I refrigerant contamination of the lubricating oil, and/or liquid oil / refrigerant slugging to the cylinder piston assembly.
The CBA system was placed in service in 1986 and operated until 1993 without a failure of the compressors. After the first compressor failure occerred in 1993, an engineering evaluation was initiated to determine the cause and develop corrective actions. This evaluation was completed in 1994 and it identified a number of system design and operation related causes that led to system problems. A design change (Design Coordination Report DCR 94-025) was initiated in 1994 as the corrective action to address these failures and prevent recurrences.
North Atlantic has pursued correcting these system design and operational causes since 1994. A number of corrective actions were taken to address individual failure events. However, these actions were focused on correcting the discrete component failures and did not effectively address the cause of the failure on a system basis as proposed in DCR 94-025. The implementation of DCR 94-025 was delayed beyond its original implementation date of the third quarter of 1996 because the design change was not complete and that temporary measures were implemented that would alleviate the cold start and low load system operation issues associated with the compressors. In September 1997, full implementation of the design changes described in DCR 94-025, while the plant was on line, was delayed due to the inability to implement the design change in the allowed outage time (AOT). At that same time, North Atlantic began implementing portions of DCR 94-025 to improve the reliability of the existing compressors.
Based upon a review of the history of CBA, it was determined in this case, that the corrective action program did not ensure the timely implementation of the design change to prevent recurrence of the compressor failures.
Corrective Steps That Have Been Taken For CBA Compressors:
- 1. Those portions of DCR 94-025 needed to improve the reliability of the CBA compressors were installed. This activity is complete.
- 2. An event evaluation and root cause analysis were performed. This activity is complete.
Positive Disniacement Pumn CS-P128:
Reason for Violation for CS-P128:
On November 4,1997 the NRC Resident Inspector observed a caution tag hung on the control switch for the Positive Displacement Charging Pump (PDP tag number CS-P128) on the Main Control Board. This tag identified that the pump could trip due to oil leaks. Upon further investigation the Inspector discovered that:
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the control room operators were unaware of plans to repair the pump;
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the design change that would reiocate the 'eaking oil pressure gauge and switch had been i
e canceled on October 6,1997; a Deliciency Evaluation Tag that was hung by the PDP stated the PDP would not be e
operated in the near or distant futun and that minor oil leakage is acceptable and would not be repaired; and after the oil pressure gauge and switch were relocated, the PDP motor started but would e
not pump until after the fluid drive war manually primed.
The PDP has had a history of various leaks as;ociated with the pressure switch and oil gauge.
North Atlantic had a design change in process to correct this condition. Ilowever, since the normal charging function was performed by tb safety related charging pumps (CS-P2A/B),
North Atlantic did not aggressively pursue the ruolution to correct the pressure switch and oil gauge concern. In April of 1996, the station pursued the operation of the PDP to provide normal charging in lieu of the safety related charging pumps. The PDP was successfully operated from i
May 14,1996 to June 6,1996 as the source for no mal charging. The pump was shutdown on I
June 6,1996 due to the housekeeping concerns with ae oil leaking from the PDP. At this time, a l
caution tag was hung on the PDP control switch on the Main Control Board to provide the operator information regarding the potential for the pump to trip due f a c.1 leaks.
l In December of 1996 it was determined that the des!=i ermal clw..tg flow rate was above the l
output of the PDP and therefore the PDP would r.ot be used Dv norm:.1 charging flow. From this followed decisions that repairing minor oil leaks or perfomiing design enhancements on the PDP were no longer necessary or desired. In February of 1997 a Deficiency Evaluation Tag was hung on the PDP stating that it would not be operated in the near to distant f uture and that minor l
l oil leakage was acceptable and would not be repaired.
North Atlantic approved the design change to relocate the pressure switch and oil gauge in September 1997, llowever, the Station Modification and Resource Committee (SMRC) recommended that the design change be voided because the pump was to no longer be used for normal charging. Subsequently, the design change was approved and the pressure switch and oil gauge were relocated to correct the leaks from these components on November 18,1997. In addition, a surveillance activity has been established to operate the PDP on a quarterly basis.
This will ensure that the PDP will be capable of performing its boron injection function in the l
UFSAR as well an alternate source of high pressure injection in the Emergency Operating l
Procedure FR-C.1, " Response to inadequate Core Cooling."
The PDP oil leak was not promptly repaired due to a tolerance for degraded conditions and the failure to recognize that the PDP, although not required by the Technical Specifications, was an important piece of backup equipment. The primary cause for the degraded PDP condition was Page 7 of 9 1
the lack of clear and consistent management expectations on the disposition of minor equipment deficiencies.
Corrective Steps That Have Been Taken For CS-P128:
- 1. A minor modification was implemented to relocate the pressure switch (CS-PS-7426) and oil pressure gauge (CS.PI-2597). This activity is complete.
- 2. Procedure OS1402.01 was revised to operate CS-P128 quarterly. A repetitive task sheet (1PDP-OS002) has been developed that documents this activity. This activity is complete.
- 3. A root cause analysis was performed. This activity is complete.
III.
Corrective Actions That Are Beine Taken to Avoid Further Violations:
The key initiatives that we have implemented to improve our performance (i.e., the 90-Day Plan) and address degraded equipment or adverse conditions are:
- 1. North Atlantic has conducted two all hands meetings with the entire organization to allow management to provide the reasons for our actions, our standards and expectations and to provide feedback on how we are progressing.
- 2. The format of the morning Station meeting has been revised. The Operations Manager conducts the meeting with the focus being on the activities that are required to support operation of the Station. The Operations Manager provides his listing of the short term (daily) and long term activities that departments need to address and he holds personnel accountable to achieve the schedules.
- 3. Operations has established a Shift Manager Teamwork meeting, consisting of personnel from Operations, Maintenance, Engineering, Technical Support and Oversight, that meets in the Control Room each morning at approximately 6:15 to establish the priorities of the day.
- 4. An engineer from Design Engineering has been assigned to Operations to provide full time assistance in configuration control issues and in resolving engineering issues. This engineer works out of the Control Room on the day shift, not on all three shifts as stated in your letter of April 1,1998, and has as his sole responsibility the resolution of engineering issues.
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- 5. A System Walkdown Program has been established to perform controlled walkdowns of plant systems using a standardized procedure developed from benchmarking industry leaders.
The program is lead by a Shift Manager and teams, comprised of Operations, Maintenance and Technical Support with support from Oversight, are walking down systems on a biweekly basis to identify degraded conditions for correction. The walkdown procedure contains the criteria and establishes our new standards.
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- 6. We are actively pursuing industry standards by benchmarking industry leaders and utilizing INPO for assist visits to improve our processes. As an example, we have recently completed benchmarking of utilities in the 12-week system week process and have completed an INPO evaluation of our work control program. INPO has conducted assist visits in Chemistry and Health Physics and visits are scheduled for Engineeringfrechnical Support, Maintenance and l
Operating Experience and Corrective Action.
- 7. We are implementing the 12-week system week process. The first work week under the new system will commence on May 3,1998. The goals for the 12-week process are that all outstanding deficiencies on that system, that can he worked, will be closed during the week.
The 12-week process is a primary tool that we will use to promptly correct degraded conditions and to decrease the cycle time for the completion of work activities.
- 8. The maintenance concepts developed by the Fx-it-Now (FIN) Team are being expanded to the maintenance shops to allow increased efiloency in completing maintenance tasks.
- 9. We have established a set of key performance indicators (KPIs) and we hold biweekly Teamwork meetings to review the indicators and to determine the required actions to support attainment of our goals.
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- 10. As part of our KPIs, we have established aggressive goals for the reduction of backlogs for the Corrective Action Program, Work Requests, Engineering Work Requests and Training Development Requests. The progress on these goals is monitored as part of our KPIs and Teamwork meetings.
These initiatives are underway to restore the Operational focus at Seabrook Station to ensure degraded equipment is promptly identified and the corrective actions are aggressively pursued.
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IV. _
Date When Full Compliance Will Be Achieved:
I North Atlantic is currently in compliance with 10 CFR 50 Appendix B, Criterion XVI
" Corrective Action."
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