ML20245L064
| ML20245L064 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/26/1989 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-89199, NUDOCS 8907050362 | |
| Download: ML20245L064 (6) | |
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George S. Thomas
'I New Hampshire.
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Yankee 4
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i NYN-89199 1
i June 26, 1989 l
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United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
References:
(a) Facility Operating License NPF-67, Docket No. 50-443 (b) Facility Operating License NPF-56, Docket No. 50-443 (c) USNRC letter dated May 25, 1989, " Inspection Report
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No. 50-443/89-03,"- James T. Wiggins to Edward E. Brown (d) NHY letter NYN-89047 dated April 28, 1989 " Licensee Event Report (LER) No. 89-006-00," G. S. Thomas to USNRC I
Subject:
Response to Inspection Report No. 50-443/89-03 l
Gentlemen:
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In accordance with the requirements of the Notice of Violation identified l
in Reference (c), enclosed please find our response to that violation.
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Should you have any questions concerning our responsr, please contact j
Mr. James M. Peschel at (603) 474-9521, extension 3772.
i Very truly yours, o
Georg homas Enclosure
-r 8907050362 B90626 PDR ADOCK 05000443 l
0 PNU l
p0I New Hampshire Yankee Division of Public Service Company of New Hompshire g
P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474-9521
.i-1 United States Nuclear Regulatory Commission June 26', 1989 j
Attention: Document Control Desk Page 2 1
i cc Mr. William T. Russell' Regional Administrator 1
-United States Nuclear Regulatory Commission j
Region I l
475 Allendale Road King of Prussia, PA 19406 Mr. Victor Nerses Project Manager Project Directorate I-3 I
United States Nuclear Regulatory Commission J
Division of Reactor Projects l
Washington, DC 20555 j
NRC Senior Resident Inspector P.O. Box 1149 Seabrook Station, NH 03874
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ENCLOSURE TO NYW-89199 Notice of Violation During an NRC inspection conducted on February 28 - April 24, 1989, 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 53 Federal Register 40019 (October 13, 1988), the violation is listed below:
l Seabrook Station, Unit No. 1 Facility Operating License NPF-56, I
paragraph 2.C(11)c states that certain valves (
Reference:
PSNH letter to the USNRC, SBN-1196 dated September 17, 1986) will be mechanically locked closed with chains and padlocks. New Hampshire Yankee Station Operating Procedure, OS86-1-7 (Revision 3) indicates that certain valves listed on form 0886-1-7A (the list of which j
comprises an attachment to SBN-1196) may be unlocked and operated only under the requirements listed in Section 5.2, precautions, or i
under the conditions noted.
Contrary to the above on April 7, 1989, and again on April 17, 1989, valves CS-V625 and CS-V176, respectively, both of which are valves l
listed on form OS86-1-7A were found mispositioned.
The
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administrative measures that were established to implement procedure j
OS86-1-7 to verify the closed, locked and chained position of valves CS-V625 and CS-V176, were not adequate in that they lacked the i
requisite clarity to assure positive control and preclude improper positioning. While the violations of NPF-56, paragraph 2.C(11)c were identified and properly reported by the licensee, the measures established to control valve position failed to meet the requirements of the Facility Operating License.
Response
The activities associated with the above events have been evaluated to determine the causes of the violation.
It was determined that the Station Operating Procedures utilized for operation and verification of the valves on the "Unborated Water Source Locked Valve List," which implemented the locked closed valve requirements of NPF-56, paragraph 2.C(11)c, did not have adequate provisions for specific valve verification and documentation. Other procedures associated with the control of unborated water source valves did not provide requisite clarity and guidance. Additionally, the auxiliary operators who verified valve position by performing the "Unborated Water Source Valve List" procedure did not pay sufficient attention to detail, and did not properly perform the procedure.
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Short-Term Corrective Action The following short-term corrective actions were taken:
- Valve CS-V625 and the air supply valve to CS-V176 were immediately repositioned to their proper position and locked after their discovery.
Additionally, at'the time of the second event, Procedure OS-86-1-7, "Unborated Water Source Locked Valve List," was performed to verify that all valves on the list were in their proper position and locked.
No ' other valves were found udspositioned.
. Station Information Reports were initiated for each event and evaluated for 10 CFR 50.73 deportability requirements which resulted in the submittal of LER 89-006-00.
- The Station Operating Procedures which were used to manipulate and verify the valves were evaluated during an April 18, 1989, meeting of the Station Operation Review Committee and the below listed enhancements were made to the following procedures:
OS1002.02 " Operation of Letdown, Charging and Seal Injection" OS1002.03 " Operation of Excess Letdown System" OS1002.04
" Operation of the Letdown Degasifier" Cautions and precautions were added to the procedural steps where the valves were being manipulated to alert the operators to subsequent required valve restoration steps.
0S-86-1-7 "Unborated Water Source Locked Valve List" Steps were added to visually. verify the position of capped valves each time the surveillance is performed, track the position of manipulated valves on the
" Locked Valve Log", and provide determination of required valve positions by a Senior Reactor Operator.
. Each Shift Superintendent has discussed both events with shift personnel to emphasize the importance of s ecial license requirements.
f to stress the requirement for operatore co be aware of procedure changes and to pay attention to procedural detail.
- The Vice President - Nuclear Production issued a memorandum to Production Managers re-emphasizing the need to pay attention to detail and do things right the first time.
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Long-Term Corrective Action Paragraph'2.C(11)c of Facility Operating License NPF-56 required that certain l
valves be mechanically locked closed to prevent the flow of water, which is borated to less than 2000 ppm, into the RCS.
Since the time of this violation, Facility Operating License NPF-67 has been issued to Seabrook Station, superceding License No. NPF-56. The requirement to maintain valves locked closed in potential boron dilution pathways is not a condition of Facility Operating License NPF-67, precluding the potential for recurrence of this event.
An in-depth evaluation was performed for each condition of mispositioned boron dilution flowpath valves. The long-term corrective actions taken as a result of the evaluation are as follows:
- An evaluation of the administrative mechanisms for development and
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approval of procedure changes was completed by a special task team on April 21, 1989. The Seabrook Station Management Manual will be revised, at the task team's recommendation, to require that changes to a procedurr be incorporated into the body of the procedure. This administrative change, which will allow personnel to better concentrate on the specific task being performed, to minimize distractions and to reduce the risk of personnel error, is expected to be completed by July 30. 1989.
. A training session will be developed and will be included as part of the Licensed Operator Requalification and Auxiliary Operator continuing training programs. This training will' include the Operator's responsibility with respect to the performance of a procedure with changes attached, and the responsibilities asscciated with the manipulation and verification of components which have special guidance contained on caution tags.
The training will be presented to the Licensed and Auxiliary Operators prior to exceeding 5Z power.
- Station Operating Precedures associated with the control of locked valves in areas other than boron dilution flowpaths are currently being reviewed for similar inadequacies. This review and any required procedure revisions will be completed prior to exceeding 5Z power.
The senior management of New Hampshire Yankee, to emphasize the importance of attention to detail, has taken the following steps:
- A task team has been established under the direction of the Vice President - Nuclear Production to recommend ways to minimize human errors associated with the operation of Seabrook Station and to
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improve the accuracy and timeliness of the event evaluation process.
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. A request has been made to the New Hampshire Yankee Self Assessment Team (SAT) to. include, as part of its plan for monitoring Low Power Testing, reviews of processes associated with Station operation to identify areas where events similar to those described above could occur. The results of this evaluation will be included as part of the SAT Phase II report.and will be available after the completion of low power testing.
Additionally, New Hampshire Yankee will be implementing a Human Performance Evaluatibn System (HPES) in the latter half of 1989.
The HPES program will utilize the proven INPO methodology to evaluate personnel errors and c.atablish methods to prevent recurrence.
The HPES program will be implemented prior to exceeding SI power.
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