ML19324C382

Forwards Corrective Action Plan Summary in Response to Confirmatory Action Ltr 89-11.Evaluation of Effects of Natural Circulation Test on Charging Nozzle & Startup Test Program Rev Already Completed

ML19324C382
Person / Time
Site:	Seabrook
Issue date:	10/31/1989
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CAL-89-11, NYN-891335, NUDOCS 8911160195
Download: ML19324C382 (13)

Text

,' ] M ' y,  ;

,,../. , '6 >

New Homoshire '

Ted C. Feigenboum Senior Vice President and -

- - _ _ Chief Operating Officer  ;

NYN- 891335

)

October 31, 1989 b

United States Nuclear Regulatory Commission '

Region I  !

475 Allendale Road . .;

King of Prussia.-PA 19406 i Attentions Mr. William T. Russell Regional Administrator' .

References:

a) Facility Operating License NPF-67, Docket No. 50-443 b) USNRC Confirmatory Action Letter (CAL) 89-11 dated June 23, l 1989 W. T. Russell to E. A. Brown c) NHY Letter NYN-89128 dated October 23, 1989, "New Hampshire Yankee Corrective Action Plan." T. C. Feigenbaum ,;

to W. T. Russell 5 a ,

' subject: New Hampshire Yankee Corrective-Action Plan l

Dear Mr. Russell:

,I New Hampshire Yankee (NHY) submitted an update and status report of the Confirmatory Action Letter 89-11 Corrective Action Plan on October 23, '

1989, via Reference (c). The Corrective Action Plan has been reviewod and the status as of October 27, 1989, is provided as an enclosure to this letter. It should be noted that a date has been established'when each item f will be ready for NRC review and closure.

l' Several action items involve ongoing activities such as the procedure '

conversion effort. These items will be monitored and the date that they l' will be ready for NRC review will be updated when the programmatic aspects are complete and a representative sample of the final product is ready for NRC review. Fourteen action itema have been independently evaluated and are ready for NRC review as of October 27, 1989.

B l' Should you have any questions regarding the Corrective Action Plan.

please contact Mr. James M. Peschel, Regulatory Compliance Manager, at l

/603) 474-9521 extension 3772.

Very truly ycurs, 8911160195 891031 '

k& /' h

.PDR ADOCK 05000443

• Ted C. Feigenbaum i P PDC Enclosure New Hampshire Yankee Division of Public Service Company of New Hompshire P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521

'h i

__= ..

.e J:

United States Nuclear Regulatory Commission October 31, 1989 Attention: Mr. William T. Russell Page 2 cci Mr. William T. Russell Regional Administrator United States Nuclect Regulatory Commission Region I 475-Allendale Road T.ing of Prussia', PA 19406 Mr. Victor Hersos, Project Manager Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington..DC 20555 Mr. Antone C. Cerno I NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 l

l l

l l

l l l

l l ,

c .

.,

L

,j ..

, New Hampshire Yankee October 31, 1989 o

3 I

w ENCLOSURE TO NYN.891335  !

c. CORRECTIVE ACTION PLAN 3 y i

.i r

k t

t

?

l i.

't' l

l<

l l' s

.c l

5 tf'

'A-CORRECTIVE ACTION Pt.AN

SUMMARY

~~

OCTOBER 27, 1989 .

l ACTION SUBMITTED TO IRT ITEM FOR INDD fRDENT READY FOR NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE VERIFICATION NRC REVIEW PROCEDURE COMPLIANCE Hold meetings with each of the shift crews to review 1.A-1 the policy on procedure compilance, Station Manager Completed October 4, 1989 October 25, 1989 Revise and reissue the procedure compliance policy in the Seabrook Station Management Manual to more clearly state that all procedures are to be followed when operating Seabrook Station unless an overriding safety 1.A-2 concern prohibits such action. Station Manager Completed October 6, 1989 October 20, 1989 Issue a memorandum from the NitY President to all pers>nnel working at Seabrook Station re-emphasizing 1.A-3 the requirement that all procedures are to be followed. President Completed October 2, 1989 October 20, 1989 Enhance the Seabrook Station Management Mar.ual procedure compliance policy to clearly specify that the only conditions under which departure from approved is allowed is when such action is required to protect the public health and safety, personnel safety 1.A-4 or to prevent serious damage to plant equipment. Station Ma,ager Completed October 6, 1989 October 27, 1989 Develop and issue NHY Policy statement on Core 1.A-5 Values and Work Ethic. President Completed October 2, 1989 October 25, 1989 Develop and issue a comprehensive NHY policy to e' clearly define procedure adherence requirements for Regulatory Compliance 1.A-6 all NHY activities. Manager Completed October 2, 1989 October 27, 1989 Review 1-ST-22, Natural Circulation Test, to provide further instruction regarding initial conditions and Power Ascension to determine the ability to perform the test with Test Program I.A-7 the controls in automatic. Manager Completed October 2, 1989 November 3, 1989 S

• _ . _ , ~ . - - ~ . . . . - _ - , . . , . . .. - - - . _ - -

. CORRECTIVE ACTIDN PLAN

SUMMARY

OCTOBER 27, 1989 ',

(CONTINUED)

ACTION SUBMITTED TO IRT ITEM FOR INDEPENDENT READY FDR ~

NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE VERIFICATION NRC REVIEW PROCEDURE COMPl!ANCE Reorganize Operations to provide personnel to perform the required development, periodic reviews and Executive Director -

1.A-S consistency reviews of Operations procedures. Nuclear Production Completed October 23, 1989 November 20, 1989 Provide t aining to all NHY personnel on the enhanced I.A-9 MH1r procedure compliance policy. Training Manager Completed October 27, 1989 November 3, 1989 Appoint a Human Performance Evaluation System (HPES) Executive Director -

1.A-10 Coordinator and loplement the IMPO HPES Program Nuclear Production October 31 1989 November 10, 1989 Enhance the Licensed Operator Training Program to include simulator training which challenges the 1.A-11 operators with regard to following procedures. Training Manager Completed October 23, 1989 November 3, 1989 EQUIPMENT READINESS Complete a Licensee Event Report to include a 10CFR50.59 analysis of the Natural Circulation Regulatory Compliance 1.8-1 Test and reactor trip. Manager Completed October 2, 1989 October 27, 1989 Inspect and evaluate the steam dump valves to determine the cause of the failure, the required corrective action and a schedule for completion for Technical Support -"

1.B-2 the corrective action. Manager Completed October 2, 1989 November 3, 1989 Re-evaluate the routing maintenance frequency and the post maintenance testing criteria for the Maintenance 1.8-3 steam dump valves. Manager Completed October 2, 1989 November 3, 1989 e , w 7- -*W-a *e- ~ w r p e p p ++ -O _ _ _ - 7 -

CDRRECTIVE ACTION PLAN * '*

SUMMARY

DCTDBER 27, 1989 (CONTINUED) .;

ACTION SUBMITTED TO IRT-ITEM TOR INDEPENDENT READY FOR NUMBER CDRRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE VERIFICATIDN NRC REVIEW EQUIPMENT READIRESS 2

Evaluate the effect of the Natural Circulation Test on the charging nozzle and develop a schedule for Engineering 1.8-4 any corrective action. Manager Completed October 2, 1989 ,0ctober 27, 1989 Examine valves siellar to the steam dump valves to determine if similar conditions exist, and develop a Engineering 1.0-5 schedule for any corrective action. Manager Completed October 6, 1989.. November 3,1989 Evaluate the maintenance program to ensure that sufficient emphasis placed upon post-maintenance 1.B-6 testing and visual inspections. Operations Manager November 13, 1989 November 13, 1989 Evaluate the methods used to operate the letdown isolation valve to determine the effects of any flashing that occurred during the test. Develop operating techniques to ensure the water does not Engineering 1.B-7 flash to steam. .9a9ager Completed October 6, 1989 November 13, 1989 Revise the Startup Test Program to provide controls to ensure that all relevant Work Requests are closed out prior to the initiation of tests that utilize the relevant equipment (for example, steam dump on the Power Ascension Test 1.B-8 non-nuclear side of the plant). Program Manager November 13, 1989 November 13, 1989 Enpand the MODE change checklist process to allow it to be utilized to perform pre-test checklist ict major Power Ascension Test 1.B-9 system testing and integrated system testing. Program Manager November 13, 1989 November 13, 1989 i

i

^

i

- - - . - . , ., ., , , y - - . - . - .. . . . - , ,. z. . . .

a

^

~

.- -CORRECTIVE ACTION PLAN -

"6]

suMMART _ y DCTOBER 27.'1989-

~~

(COMTINUED) --._. 2 i

ACTION SU6MITTED TO IRT IVEM FOR INDEPENDENT READT FOR NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER' DUE DATE VERIFICATION NRC REVIEW-PRETEST PREPARATION Revise the policy on Control Room Access to establish the maximum number of personnel allowed in the Control 1.C-1 Room and the horseshoe area of the Control Room. Operations Manager Completed October 2, 1989 Noveer 3,1989 -

Revise the Startup Test Program to require that a more comprehensive pre-test briefing be provided prior to test crew assuming the shift to ensure that the crew understands the test criteria, expected parameters Power Ascension Test 1.C-2 and required actions. Program Manager November 13, 1989 November 13, 1989 Revise the Startup Test Program to require that additional preparation, including simulator rehearsals when feasible, be given to test crews assigned to Power Ascension Test 1.C-3 perform complex issts. Program Manager November 13, 1989 November 13, 1989 Revise the Power Ascension Test Program to require that test specific training be conducted within three months Power Ascension Test 1.C-4 of the conduct to the test. Program Manager November 13, 1989 November 13, 1989 POWER ASCENSION TEST PROGRAM Review the Startup Test Program and remaining Startup Test Procedures and revise as appropriate to incorporate the guidance which currently exists in the /

Station Management Manual and other applicable NMT manuals and to ensure the test procedure format and guidance is consistent with current Station Operating Power Ascension Test 1.0-1 Procedure guidance. Program Manager December 14, 1989 Deceder 14, 1989

- , , _ , _.--g,_ +<.w-u.m _ __..u___e .s_m,-- - ..- - mump---  %-

e M gyg y.w-- y g g.q ,e.__y-______. __ u-w .ep"* sa

. CORRECTIVE ACTION PLAN _

5tfMMARY OCTOBER 27, 1989 ~-.

(CONTINUED)

ACTION SUBMITTED TO IRT ITEM FOR INDEPENDENT READY FOR NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE VERIFICATIDN NRC REVIEW POWE9 ASCENSION TEST PROGRAM -

Revise the Startup Test Program to remove the reactivity computer from the horseshoe area when Power Ascension Test I.D-2 it is not required for testing. Program Manager November 13, 1989 November 13, 1989 .

Revise the Startup Test Procedures to provide additional guidance for terminatir.g the test and exiting the test procedure when equipment Power Ascension Test 1.D-3 malfunctions occur during testing. Program Manager November 13, 1989 November 13. 1969 Revise the Startup Test Procedures which will be used for power ascension testing and stellar testing to i make them part of the Station Operating Procedure Power Ascension Test .

1.D-4 System. Program Manager December 14, 1989 December it. 1999 Establish a new Power Ascension Test organization that will work closely with Operations and that has clearly ,

defined responsibilities specifying which individual ,

is responsible for all aspects of the Power Ascension l- 1.D-5 Test Program. Station Manager Completed October 23, 1989 November 13, 1989 Revise the Power Ascension Test Program to include NHY Executive Management " review points

• at the key Power Ascension Test

, 1.D-6 plateaus of 5%. 30% 50% and 75%. Program Manager November 13, 1989 - '

November 13, 1989 Revise the Power Ascension Test Program to require that each procedure have a background document that describes the reason the test is being conducted, the basis for any set points and criteria, or other such information related to the test. The background document will be included in the procedure throughout Power Ascension Test ,

l.D-7 the review, approval and implementatlan cycles. Program Manager November 13, 1989 November 13, 1989 e, ~ +

w -

e_-- - m ~ m- g e -m-u

- , - w -

m .-+-- -1 r -__--------s e a

. CDRRECTIVE ACTION PLAN , - - -'

SUMMARY

OCTOBER 27, 1989

~

• ~

(CONTINUED) g-m ACTIDM SUBMITTED TO IRT ITEM FDR INDEPENDENT READY FOR NUMBER CDRRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE - VERIFICATIDN NRC REVIEW POWER ASCENSION TEST PROGRAM Review the Power Ascension Test Program to ensure that the Power Ascension Test Program Manager provides frequent briefings to the Executive Director - Nuclear Production. Station Panager and Operations Manager on program status e .a upcoming evolutions to ensure Power Ascension Test 1.0-8 management involvement. Program Manager November 13 1989 November 13, 1989 Revise the Operations Management Manual and the Power Ascension Test Program to clearly state the responsibilities of Operations and Power Ascension Test personnel to raise any issue that is not understood, or to stop an evolution if they do not understand their responsibilities in the conduct Power Ascension Test 1.0-9 of the test. Program Manager November 13, 1989 November 13, 1989 Perform a safety evaluation of the Power Ascension Test Program procedures to verify that the conduct Executive Director of the tests within the test parameters will not Er.gineering and 1.D-10 involve an unreviewed safety question. Licensing December 14. 1989 December 14, 1989 POST EVENT MANAGEMENT Relieve the Vice President - Nuclear Production of 2.A-1 his duties related to Seabrook Station. President Completed October 2 1989 Detober 20. 1989 2.A-2 Replace the Vice President - Nuclear Production President Completed October 2. 1989 October 27, 1989 Revise the Power Ascension Testing Program to require the Event Evaluation Report to be completed prior to Power Ascension Test 2.A-3 recommending reactor restart. Program Manager November 13, 1989 November 13, 1989 q - ~ ,~ " e , , * . m, e w e m v ~~ v. g -

e e me sum * +w -_.,_____-_a_ _, u __w e_

-l _ ~.

~

. CORRECTIVE ACTIDN PL75

SUMMARY

~

OCTOBER 27, 1989' ',

(COMTINUED)

ACTION SUBMITTED TO IRT ITEM FOR INDEPENDENT READY FOR MUMBER CORREC1IVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE VERIFICATION NRC REVIEW POST EVENT MANAGEMENT Revise the Post Trip Review procedura to assign an individual as the NRC contact during the review process u d to include a discussion of the trip with the NRC Executive Director 2.A-4 prior to reactor restart. Nuclear Production November 13, 1989 November 13, 1989 Review the NHY Reperting Manual to determine if Regulatory additional guidance is required for 10CFR50.72 Compliance 2.A-5 reporting. Manager Completed October 11, 1989 November 3, 1989 Review the Event Evaluation procedure to determine if enhancements are required concerning the post-trip Regulatory review. assignment of personnel, pos* trip critiques Compliance 2.A-6 and written chronologies. Manager Completed October 2, 1989 Nov % 2 y Revise the Post Trip Review Procedure and the Event Evaluation Procedure to require that the Human Performance Evaluation System be utilized in the Regulatory ultimate evaluation and resolution of unplanned ~ Compliance 2.A-7 reactor trips. Manager November 27, 1989 November 27, 1989 OPERATIONS MANAGEMENT Issue letters of reprimand to the management personnel /

in the Operations chain of command who were present in the Control Room during the test, the personnel who were spoken to by the hRC inspectors regarding the 17%

pressurizer level trip criterion during the test, and the operators and startup engineers on the shift crew involved in the te t b 2 had the authority and 2.B-1 responsibility to c.*v 7< the procedure violation. President Completed October 2, 1989 October 27, 1989

- . - - - - - _ _ - _ _ _ _ _ _ - _ - . _ - - _ = - _ _ -

. CORRECTIVE ACTION PLAN

SUMMARY

" ~~

OCTOBER 27. 1989 1 (CONTINUED)

ACTION SUBMITTED TO IRT ITEM FOR INDEPENDENT READY FOR NUMBER CORRECTIFF ACTION ITEM RESPONSIBLE RAMA5ER DUE DATE VERIFIEATION BRC REVIEW OPERAfl0NS MANAGEMENT Establish a shift manning policy to ensure that the Shif t Technical Advisor will not have collateral duties other than as the Unit Shift Supervisor or 2.0-2 Shif t Superintendent Operations Manager Completed October 2. 1989 Detober 27, 1989 Revise the Operations Management Manual to: 1) Clarify the integration of Startup Test personnel with the shift opercting cre#: 2) Clarify responsibility and authority when supplemental operators are assigned to a shift: 3) Encourage non-shif t Ilcensed Operations personnel to prov'.de a point of clarification or information wher an assigned operator's actions appear to be inarpropriate or are not understood by the observer: 4) Require the Operations Management Ilcensed personnel to define their responsibilities when they enter the horseshoe area of the Control Room during 2.B-3 testing. Station Manager Completed Detober 2. 1989 November 13. 1989 Establish a Policy and briefing for management personnel that focusses on their obligation to be cognizant of safety and operational limits associated with operations and test activities that are observed Executive Director 2.0-4 while they are in the Control Room. Nuclear Production November 13. 1989 -

November 13. 1989 A

+n- +-- g y > gy aMq  % **- + _-_ _mm__a4-'-__ u _-J+-__--r --amJ

~

^

CDRRECTIVE ACTION PLAN 0; _

SUMMARY

~-

DCTOBER 27. 1989 4 * ** 2 (CONTINUED)

ACTION SU8MITTED TO IRT ITEM FOR INDEPENDENT READT FOR NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE . VERIFICATION. NRC REVIEW OPERATIONS MANAGEMENT Conduct operating philosophy and event analysis seminars for Production management and licensed 2.B-5 personnel. Training Manager October 31. 1989 november 3. 1989 Rotate additional Station operations managers through Executive Director 2.B-6 the INPO Senior Plant Management Course. Nuclear Production November 13, 1989 November 13, 1969 MANAGEMENT OVERSIGNT Establish a rotating senior management oversight of 3-1 Station operations. _ Completed Octtber 2. 1989 move:Ser 13. 1989 Provide the President with a weekly status report of Regulatory 3-2 progress on the Corrective Action Plan Compilance Manager On-going October 25. 1989 Perform an independent evaluation and self assessment of the implementation of the Corrective Action Plan 3-3 and provide a report to the President. IRT Manager Dn-going Detober 25, 1989 Evaluate the effectiveness of the NHT procedure compilance policy upgrade by means of a combination of audits and surveillances to verify and assess the implementation of the policy, and provide a report Nuclear Quality

"' povember 13. 1989 3-4 to the President. Manager October 31, 1989 Establish a program to provide periodic evaluations of the Shift Superintendents to provide Executive Management with assurance that the operation of Seabrook Station will be conducted in accordance with NHT policies in a strong conservative manner during 3-5 all shifts. . Station Manager October 31, 1989 November 13. 1989 m- - -- ----+w - -.-n_. -- - - - -- -- --

~ ~

f_ :q l t

. CORRECTIVE ACTION PLAN -I,

SUMMARY

- tj OCTOBER 27. 1989 -

, f7 (CONTINUED) _ ^ *i ' ~ l.

ACTION ' SUBMITTED TO IRT

' ITEM FOR INDEPENDENT READY FOR NUMBER CORRECTIVE ACTION ITEM RESPONSIBLE MANAGER DUE DATE ~ . VERIFICATION NRC REVIEW -

MANAGEMENT OVERSIGHT Conduct an Operating Experience Seminar to review the June 22 event with Power Ascension Test personnel.

Operations personnel and Operations management 3-6 personnel. Training Manager October 31, 1989 November 3, 1989 .

Review the industry data to obtain test procedure problems or problems with the conduct of startup tests Regulatory 3

3-7 and review them for applicability to NHY. Compliance Manager November 13, 1989 November 13, 1989 ,-

Perform an independent evaluation of the 50RC and the 50RC process to include the criteria and guidance used Director of Quality 3-8 in the 50RC review process. Programs November 15, 1989 November. 15.-1989

~

p.-

4 '

e r

O m.__ a - __ __._e = _ -- - ._ , , , , -.--