ML20237E954
| ML20237E954 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/28/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-443-98-04, 50-443-98-4, ACR-98-1417, ACR-98-2038, AR#98009418, AR#98014612, AR#98016104, NYN-98105, NUDOCS 9809010325 | |
| Download: ML20237E954 (4) | |
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g~ North Ph. Un 3M North Atlantic Energy Service Corporation Seabrook, NII 03874 A i
, lill8I111C (603) 474M21 The Northeast Utilities System August 28,1998 NYN-98105 Ref: ACR 98-1417 AR#98009418 ACR 98-2038 AR#98016104 AR#98014612 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station Reply to Notice of Violation North' Atlantic Energy Service Corporation (North Atlantic) provides in the enclosure its
. response to the Notice of Violation described in Inspection Report 98-04.
Should you have any questions concerning this response, please contact Terry L. Harpster, Director of Licensing Services, at (603) 773-7765.
Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.
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l fJAba4-Ted C. Feigenbat 1
" " 0 Executive Vice ' resident and Chief Nuclear Officer
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H. J. Miller, NRC Region I Administrator 7
l J. T. Harrison, NRC Project Manager, Project Directorate 1-3 l
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R. K. Lorson, NRC Senior Resident inspector I
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ENCLOSURE TO NYN-98105 l
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REPLY TO NOTICE OF VIOLATION NRC Inspection Report 98-04 describes a violation where North Atlantic did not take action to promptly detemiine the status of the A and D steam generator steam pressure protection channels. North Atlantic's response to this v;olation is presented below.
1.
Description of the Violation:
The following is a restatement of the violation:
10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, states, in part, that measures shall be implemented to ensure that conditions adverse to quality are promptly identified.
Contrary to the above, on May 4,1998, NAESCO did not take action to promptly identify whether steam pressure protection channels for the A and D steam generators were operable, j
after three of the six steam pressure protection channels for the B and C steam generators were j
found to be inoperable. Subsequent testing determined that two of the sis A and D steam J
generator pressure protection channels were inoperable.
This is a Severity Level IV Violation (Supplement 1).
2.
Reply to the Notice of Violation:
Reason for the Violation North Atlantic agrees with the violation. On April 27, 1998, North Atlantic commenced calibration activities for six (three each on the B and C steam generators) steam generator pressure protection channels. On May 1,1998, the lead / lag value for three channels were found outside of the acceptability limits specified in the calibration procedures. The three channels were calibrated and returned to service. On May 4,1998, North Atlantic determined that the lead / lag values addressed in the calibration procedures were Technical Specification allowable values and, as such, the as-found data was outside the Technical Specification limits.
An Adverse Condition Report (ACR) was initiated and the event was determined to require a License Event Report (LER) pursuant to 10CFR50.73(a)(2)(i) due to the operation of the plant from May 1,1998 to May 4,1998 in a condition prohibited by the Technical Specifications.
North Atlantic submitted LER 98-005-00 on May 29,1998.
On May 1,1998, Station management requested Maintenance personnel to investigate the applicability of this condition on the A and D steam generators. This was not acted upon promptly. Additionally, the individuals involved in the preparation and review of the ACR did not recognize that the out of tolerance condition identified on the B and C steam generators should have called into question the adequacy of similar channel calibrations performed on the A and D steam generators. By May 4,1998, North Atlantic had not pursued the validation of the status of similar channels on the A and D steam generators in a timely manner.
In addition, Page 1 of 2
4 when the ACR was discussed during the daily Station meeting on May 5,1998, insufficient information was presented regarding the potential for the condition to be common to the other steam generators and as a result the operability of the A and D steam generators was not pursued promptly.
This event was included in the scope of a comprehensive review of lead / lag issues. North Atlantic performed a thorough review of the calibration methodologies used to determine NLL card time constants. This review was proactive and involved forming an event team, consulting with vendoes and bench top testing.
The cause of this event is that the Corrective Action System was not effectively implemented af ter the initiation of the ACR. There was not adequate communication between the departments regarding the specifics of the channel calibration failures and the potential for common failures was not adequately questioned / pursued. As a result, action was not promptly initiated to validate the status of the A and D steam generators in a timely manner.
Corrective Actions
- 1. The individuals involved in initiating and reviewing this Adverse Condition Report have been coached and counseled.
Date When Compliance Will Be Achieved North Atlantic is currently in compliance with 10 CFR 50 Appendix B, Criterion XVI
" Corrective Action "
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