ML20138A326

Responds to NRC 970307 Ltr Re Violations Noted in Insp Rept 50-443/96-11.Corrective Actions:Completed Rev to MOV Program Document ES1850.003 & Strengthened Certain Administrative Controls for Engineering Evaluation

ML20138A326
Person / Time
Site:	Seabrook
Issue date:	04/18/1997
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-97041, NUDOCS 9704280046
Download: ML20138A326 (5)

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. North North Atlantic Energy Service Corporation P.O. Box 300 d

Atlantic Seehreet, Nii O3874 (603) 474-9521 The Northeast Utilities Systern April 18,1997 Docket No. 50-443 NYN-97041 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Seabrook Station Renly NRC Inspection Renort 96-11 3

In a letter dated March 7,1997, the NRC requested that North Atlantic Energy Service Corporation (North Atlantic) provide the reasons why the motor-operated valve (MOV) program document was not revised by January 31,1997 as committed during the NRC Generic Letter 89-10 MOV close-out inspection. The inspection report also requested the updated projected completion date for the MOV program document revision. Accordingly, the enclosure to this letter provides the requested response, t

North Atlantic is making certain commitments in response to this Inspection Report. The commitments are fully described in the enclosure to this letter.

Should you have any questions concerning this response, please contact Mr. Terry L. Harpster, Director of Licensing Services, at (603) 773-7765.

I Very truly yours, I NORTH A 1Tf5C EkERG SERVICE CORP.  ;

280019 N.'hM C. Feigdigaum A lh /

j 9704280046 970418 Executive Vice Pres' ent t

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W _ and ChiefNuclear Officer cc: H. J. Miller, Regional Administrator A. W. De Agazio, Sr. Project Manager J. B. Macdonald, NRC Senior Resident Inspector g ...<.*-

g'g g py j l ' NRC Inspection Report 96-11, dated March 7,1997, J. F. Rogge to T. C. Feigenbaum.

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. ENCLOSUllE 1 TO NYN-97041 S

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REPLY TO NRC INSPECTION REPORT 96-11 '

j In NRC Inspection Report 96-11, North Atlantic was requested to provide the reasons for l l .why the motor-operated valve (MOV) program document was not revised by January 31, j u 1997 as committed during the NRC Generic Letter 89-10 MOV close-out inspection.

l The inspection report also requested the updated projected completion date for the MOV ,

l program document revision. The following provides North Atlantic's response to these

! requests, j 1. Background North Atlantic made two commitments to the NRC at the November 15,1956 exit  ;

meeting for the MOV close-out inspection. The first commitment was to revise the ,

MOV program document ES 1850.003, " Motor Operated Valve Performance  !

L Monitoring," by January 31,1997, to strengthen certain administrative controls for  !

engineering evaluations and dynamic test acceptance criteria. The second commitment was to test 15 MOVs, over the next two refueling outages, to obtain  ;

L additional site-specific performance data. These commitments were originally made

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! .by North Atlantic during the conduct of the inspection to address the inspector's i concerns. Both of these commitments were documented in North Atlantic's exit j

! meeting minutes, however, they were not entered into the. Action Information

l. Tracking and Trending System (AITTS). Notwithstanding, North Atlantic j management personnel agreed with these commitments and were aware that they had i been made. At the time that NRC Inspection Report 96-11 was issued (March 7, 1997), the revision to the MOV program document had not' been ' completed.  ;

However, actions to address testing of eight valves during the upcoming raibeling  !

I outage to satisfy the second commitment were on schedule and had been substantially I completed. Seven additional valves will be tested during the sixth refueling outage.

II. Causes  ;

i Three apparent causes have been identified for the failure to implement this +

commitment in a timely manner:

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a) Resource Management Recently, adequate personnel resources have not been available to perform all MOV related tasks in a timely manner. These tasks include routine program updates, development of MOV work packages for the outage, updates / revisions to MOV design basis calculations, planning for margin p improvements, program improvements to address NRC concerns, valve  !

E testing, analysis of valve data, emergent work activities, etc. The majority of these MOV activities are the responsibility of the MOV system engineer, with  !

I the periodic support of other engineering resources. The MOV system j engineer was aware of the commitment to update the MOV program f

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, document. While revision of the program document was one of his top i[ priorities, it became subordinate to supporting emergent work activities and the development of work packages for performing additional valve testing -

during the upcoming refueling outage, in part, to comply with the other NRC commitment to obtain additional data on stem friction coefficients.

The MOV system engineer kept Technical Support management aware of the

} aforementioned resource limitations. In response, management directed him j to arrange for either in-house engineering support or outside contract i resources. The MOV system engineer had limited success in obtaining

assistance from in-house engineering resources due to other competing

i. engineering priorities. Similarly, the MOV system engineer attempted to find i

qualified contract personnel with no success. Technical Support management

was apprised of the MOV system engineer's lack of success in obtaining

resources, however, they were also unsuccessful at obtaining additional l resources. Additional resources would have allowed the MOV system engineer to complete the revisior

to the MOV program document by January

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l b) Manaoement Monitorino l 2

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Technical Support management typically relies on AITTS to track the progress - .:

! of NRC and other commitments. Technical Support management lost track of '  !

the status of this specific commitment since it was not entered onto AITTS. l l The reason why the commitment was not entered into AITTS relates _to the. l

[ adequacy of applicable administrative procedures in specifying when. verbal -

commitments are to be entered into AITTS, Specifically, the responsible '

Licensing engineer intended to enter all inspection related commitments into

AITTS upon receipt of the inspection report. These commitments would be

subsequently updated to reflect the information provided in North Atlantic's 1

anticipated response to the inspection report. This would ensure that the i

commitments entered onto the tracking system were consistent with the way they were characterized in the inspection report and in the subsequent response.

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l It would also ensure that the verbal commitments were described in docketed

[ correspondence as is required by the Regulatory Compliance Manual. While

! the Regulatory Compliance Manual was clear that verbal commitments need to  ;

I be subsequently described in docketed correspondence, it was not clear when i

, such commitments needed to be captured on AITTS. i

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! c) Communications i

- Prior to January 31,1997, Tecunical Support management had been informed

by the MOV system engineer that he was in jeopardy of missing some of his  ;

commitments. In response, management provided their expectations that commitments were to be completed on time. The MOV System engineer did 4

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not subsequently apprise Technical Support management that the commitment to update the MOV program would not be completed as scheduled.

III. Corrective Actions 2

1. On March 17,1997, . North Atlantic completed.the revision to the MOV program document ES1850.003. The revised program document strengthens certain administrative controls for engineering evaluations and dynamic test acceptance criteria and reflects how the MOV program is currently being implemented at Seabrook Station.

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2. North Atlantic is currently in the process of obtaining additional personnel

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resources to support implementation of the MOV program. These additional resources will consist of either in-house personnel, contract personnel, or both, and will support actions necessary to obtain MOV program closure.

, Subsequently, North Atlantic will evaluate the resources necessary for long-

, term implementation and maintenance of the MOV program.

3. North Atlantic will revise the Regulatory Compliance Manual to clarify that verbal regulatory commitments are to be entered into AITTS as soon as possible after they are made and that they should be revised / updated, as necessary, to reflect the description of the commitment in subsequent docketed correspondence.

4. Technical Support t nagement has adopted a more active role in monitoring and supporting the MOV system engineer in the implementation of the MOV program.

IV. Completion Date for Revision of the MOV Program Document As described in the first corrective action above, North Atlantic has completed the revision to the MOV program document.

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