ML20236Q213
| ML20236Q213 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/17/1987 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NYN-87132, NUDOCS 8711190243 | |
| Download: ML20236Q213 (3) | |
Text
-
UI George S. Thomas Vice hesident Nuclear Production :
Put:4c Service of New Hampshire New Hampshire Yankee Division NYN-87132 1
November 17,.1987 c
-q United States Nuclear Regulatory Commission
.)
Washington, DC 20555
]
Attention: Document Control Desk I
References:
(a) Facility Operating License NPF-56, Docket No. 50-443-(b) USNRC Letter, Dated October 21,-'1987, " Inspection Report' I
No. 50-443/87-16", James T. Wiggins to Robert J. Harrison Subj ect : Response to Inspection Report No. 50-443/87-16 Gentlemen:
l 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, dfyr f
George 8.
Thomas Enclosure cc:
Mr. William T. Russell, Regional Administrator U.S. Nuclear Regulatory Commit.sion - Region I 631 Park Avenue King of Prussia, PA 19406 Mr. A. C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874 8711190243 871117 PDR ADOCK 05000443 G
PDR P.O. Box 300. Seabrook, NH 03874. Telephone (603) 474-9574 Il/
=
ENCLOSURE TO NYN-87132 NRY RESPONSE TO NOTICE OF VIOLATION l
Notice of Violation 87-16-01
]j During an NRC inspection conducted between July 7 and September 8,1987, a j
violation of NRC requirements was identified.
In accordance with the " General d
Statement of Policy and Procedure for NRC Enforcement Actions",
')
10 CFR Part 2, Appendix C (Enforcement Policy 1986), the violation is listed i
below:
10 CFR 50, Appendix B, Criterion XVI' and the Seabrook Station FSAR,-
j Section 17.1.1.16 require that measures be established to assure that conditions adverse to quality be corrected in such a way that the cause j
of the condition is determined.and the corrective action taken precludes q
repetition.
10CFR2, Appendix C, part V.A indicates that for violations identified by the license, a' notice will be issued in those cases where i
it was expected that licensee corrective action for a previous violation l
should have prevented the identified violation. Technical Specification (TS) 3.3.3.1 requires that the control room air intake radiation i
instrumentation channels be operable to provide control roem isolation at f
radiation levels consistent with the instrument setpoints. These radiation monitors must be " armed" by their control logic circuitry to be capable of performing the control room' isolation safety function.
j Contrary to the above, on August 19, 1987, during the conduct of a TS surveillance required to test channel operability, at least one train of the control room air intake radiation instrumentation was identified by the licensee to be incapable of providing control room isolation, and therefore of performing its safety function.
Such a condition adverse to quality could have existed since the previous conduct of the TS surveillance on July 20, 1987, since no positive indication of the
" armed" status of the subject radiation monitors was otherwise available to the operators.
Similar problems with the control logic circuitry of the control room isolation function were brought to the attention of the licensee during NRC inspections 86-54 and 87-02, at which time a deviation and violation respectively were issued.
Licensee corrective
{
action to these enforcement actions, as it relates to the measures j
provided to ensure the " armed" status of the air intake radiation 1
monitors, failed to preclude repetition of a noncompliance with TS j
requirements.
Response
d The reason for the violation has been attributed to system hardware design, procedure inadequacies 9 and f ailure to follow instructions on a caution tag.
1 of 2 i
1 2
_J
l l
o ENCLOSURE TO NYN-87132 Subsequent to the notice of violation identified in IR 443/87-02, a review of the procedural and administrative controls was conducted.' As a result of this review, it was felt that existing procedural and' administrative controls would be adequate to assure that the isolation function would be armed for an interim period until design. changes which significantly modified the Control Room Ventilation System (CBA) were completed.
l Immediate Corrective Action i
As a result of the above stated violation, the following additional corrective actions have been taken:
1.
A temporary modification has been completed that added a white indicator light to each of the four radiation monitor isolation circuits to designate the armed status for the isolation signal control logic. These lights provide positive indication that each circuit is armed.
i 4
2.
Procedure changes have been made to the Technical Specification Surveillance procedures for the four radiation monitors -to add a step on the system " arming" process when returning the system to normal f
upon completion of the surveillance.
J 3.
Procedure changes were made to OS1023.51, Control Room Ventilation and Air Conditioning System Operation, to address damper operation,.
j to clarify control logic arming sequence, and to explain the new i
indicator light operation.
4 A directive has been issued for each control room shif t to log the status of the lights in the remarks section of the Technical j
Specification Log.
Long Term Corrective Acti_gn Significant design changes to the CBA System are being developed and will be completed prior to entry into Mode 1.
These design changes will include a system alignment with both remote intake isolation valves (1-CBA-V9, 2-CBA-V9) opened to a predetermined throttle position. This alignment will eliminate the need for any isolation function. Therefore, a permanent design modification providing position indication of the " armed" status of the isolation is not necessary.
2 of 2