ML20129G280
| ML20129G280 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/12/1996 |
| From: | Feigenbaum T NORTHEAST UTILITIES SERVICE CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20129G248 | List: |
| References | |
| NYN-96048, NUDOCS 9610070147 | |
| Download: ML20129G280 (12) | |
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.c 4 i -North North Atlantic Energy Service Corporation P.O. Box 300 i
I Atlantic Seabroot,N u 03874 (603) 474-9521 The Northeast Utilities System July 12,1996 Docket No. 50-443 NYN-96048 United States Nuclear Regulatory Commission Attention: Document Control Desk j Washington, D.C. 20555 Seabrook Station Renly to a Notice of Violation In a letter dated June 14,1996' the NRC described two violations and several weaknesses regarding the Fire Protection program at Seabrook Station. Accordingly, the enclosure provides North Atlantic Energy Service Corporation's (North Atlantic) response to these violations. The enclosure .i also describes North Atlantic's plans for addressing other Fire Protection program weaknesses !
identified in the inspection report. Overall, North Atlantic believes that the collective set of i corrective actions that have been and will be taken to address these issues.will ensure that the Fire l Protection program meets both NRC and North Atlantic expectations.
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North Atlantic is making certain commitments in response to these violations and weaknesses. The commitments are fully described in the enclosure to this letter.
Should you have any questions concerning this response, please contact Mr. Anthony M.
Callendrello, Licensing Manager, at (603) 474-9521, extension 2751.
Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.
9610070147 960930
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l PDR ADOCK 05000443 T* C* Fei8 um G PDR Executive ice President and ChiefNuclear Officer cc: T. T. Martin, Regional Administrator l
A. W. De Agazio, Sr. Project Manager J. B. Macdonald, NRC Senior Resident Inspector
- NRC Inspection Report 96-03, dated June 14,1996, J. F. Rogge to T. C. Feigenbaum.
F NYN-96048 REPLY TO A NOTICE OF VIOLATION Cuoco, L. NU ;
DiProfio, W. A. 49-SS i Garfield, G. DB&H !
McKenna, K. A. Millstone 475/5 '
Millstone Licensing cc: Mail !
Sovetsky, E. J. 49-SS 3
Warnock, J. J. 02-07 !
Letter Distribution ec: Mail !
File 0001 01-48 RMD 02-06 I
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ENCLOSURE I TO NYN-96048 3
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REPLY TO A NOTICE OF VIOLATION l
NRC Inspection Report 96-03 described two apparent violations of the Fire Protection Program. l The first violation contained two examples of failing to follow procedures regarding control of '
combustible materials and repair of emergency lights. The second violation concerned an ;
inadequate Fire Protection procedure that did not reflect design basis information. North i Atlantic's response to these violations is described below.
I. Description of Violations The following are restatements of the respective violations:
A. VIO 96-03 Failure to Follow Procedures License Condition F requires NAESCO to implement and maintain in effect all provisions of the approved fire protection program. Technical specification 6.7.1.h requires that written procedures shall be established, implemented, and maintained covering the activities of the fire i protection program implementation.
Contrary to the above, written fire protection procedures were not adequately implemented in the i following examples:
- 1. Fire protection procedure 2.2, Revision 2, " Control of Combustibles," requires personnel to store Class I liquids in approved safety cans or in the manufacturer's original container when not being used and when left unattended during lunch breaks, shift changes, or other similar periods.
On April 18,1996, at about 12:05 p.m., procedure 2.2 was not implemented properly in that three unapproved and unlabeled plastic pails of a Class I combustible epoxy primer l paint were inappropriately stored and left unattended on the 50 ft. elevation of the turbine building.
- 2. Operations procedure OS0443.47, Revision 5, "8 Hour Emergency Lighting Units Monthly Functional Test," requires personnel to report the identification of inoperable emergency lights to the Unit Shift Supervisor and declare the light (s) inoperable. The work completion form,Section V - Operability, requires the documentation number for the work order initiated as follow up action for identified inoperable emergency light (s).
On January 28,1996, procedures were not implemented properly in that fire protection staff personnel identified three inoperable emergency lights (ESLO25, ESLO72, and ESL073 A) and did not report the inoperable lights to the Unit Shift Supervisor or initiate a work order as follow up action to restore the lights to service.
This is a Severity Level IV violation (Supplement I).
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B. VIO 96-03 Inadequate Procedures License Condition F requires NAESCO to implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Program Report. The Fire Protection Program Report requires that implementing test procedures are written and used to assure that the system is in conformance with the design requirements.
Contrary to the above, fire protection procedures were not adequately written to assure that emergency lights conform with design requirements. Seabrook procedures OS0433.47, Revision 6, and LS0564, Revision 2, were not written to include Seabrook Design Basis Document, DBD-FP-01, " Emergency Lights," design requirements for returning 10 CFR Part 50, Appendix R emergency lights to an operable status within 30-days of being identified as inoperable.
This is a Severity Level IV violation. (Supplement I)
IL Reply to Violations A. Failure to Follow Procedures - VIO 96-03-01 Examnle 1: Control of Combustible Material Reason for Violation North Atlantic agrees with this example of the violation, however, the following clarification is warranted. The violation stated that three unapproved and unlabeled plastic pails of Class I I combustible epoxy primer paint were inappropriately stored and left unattended on the 50 ft.
elevation of the Turbine Building. Further investigation has revealed that the paint in question !
was actually a white latex primer with a flammability rating of Class III, i.e., it was not flammable. Therefore, while the paint pails were not labeled appropriately, it was not necessary to store the paint in approved safety cans or in the manufacturer's original container.
l As an immediate corrective action for this apparent condition, all painting work was stopped inside the protected area and the jobs were reviewed by the Fire Protection staff. This review ,
determined, however, that a Class I red epoxy primer paint was being used on the 75 ft. elevation i cf the Turbine Building. Similar to the statement of the violation, this paint was not being stored in accordance with programmatic requirements in that it was not in approved safety cans or in the j manufacturer's original contamer. '
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North Atlantic has determined that this violation was caused. by a misinterpretation of how Fire l
Protection program and labeling requirements apply to painting activities. A contrifiuting cause is the clarity of Fire Protection procedure FP 2.2," Control of Combustible Materials." FP 2.2 is confusing in that it does not clearly differentiate program requirements for safety related and I non-safety related areas, nor does it clearly define " storage" and "in-use" as they apply to l painting activities. Another contributing cause is thd%ttentiveness of the Fire Protection staff. 1 i
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l North Atlantic believes that the Fire Protection staff should have been more attentive and more
. aggressive at monitoring the use of paints in the plant. ;
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1 Corrective Actions for Example 1 I l \
- 1. North Atlantic immediately stopped all painting work inside the plant's protected area I and stored the paints in accordance with the Fire Protection program. All painting work ,
was reviewed to determine if the requirements of the Fire Protection Program were being implemented. This review identified the aforementioned program deviation.
- 2. Painters and their line supervision were counseled on the requirements of the Fire Protection program. Discussions focused on procedure FP 2.2," Control of Cerabustible
%tedals," and the need for proper labeling of paint containers.
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- 3. The Fire Protection staff were apprised of this condition and were counseled on the need -
to monitor painting and other plant activities to ensure they are in compliance with Fire Protection Program requirements. Q4 ' ' l
- 4. North Atlantic has procured additional combustible material storage containers and made i them available to the painters. Additionally, an approved fire-rated storage cabinet has '
been installed in the Turbine Building.
- 5. Proper labeling and the programmatic requirements for leaving flammable paint l unattended were discussed at a May 15,1996 Site Services weekly safety meeting. The i painting staff was in attendance at this meeting. !
- 6. Procedure FP 2.2 will be revised to improve overall clarity and eliminate any potential for confusion regarding control of combustible materials. It is anticipated that FP 2.2 will be revised by August 15,1996.
- 7. A member of the Fire Protection staff will discuss this event, the requirements of the Fire Protection program, and how the program applies to specific work activities, at department meetings for Maintenance Mechanical, Maintenance Electrical, I&C, Chemistry, Health Physics, Operations, Site Services, Technical Support, Waste Management, and Design Engineering personnel. It is anticipated that these briefings will be completed by September 30,1996. j Additional programmatic corrective actions are described in Section III of this response.
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1 Examnle 2: Emergency Lighting Reason for Violation North Atlantic agrees with this violation. The statement of the violation notes that on January 28, 1996, Fire Protection staff did not follow procedures when three emergency lights were found to be inoperable in that they did not report the inoperable lights to the Unit Shift Supervisor or initiate a work request to restore the lights to service. The inspection report expands the scope of the violation to include the fact that no actions were taken to implement compensatory actions to address the lights being out of service. Each aspect of the violation will be addressed below.
- a. Lack of a Work Request While performing Operations Procedure OS0443.47, "8 Hour Emergency Lighting Units Monthly Functional Test," Fire Protection staff identified three inoperable lights (ESLO25, ESLO72, and ESLO73A). The inoperable lights were recorded on the Repetitive Task Sheet (R'is) for OS0443.47, and it was noted that they were entered into the Minor Maintenance program for repair. No work request was initiated for these lights, nor was one required to be initiated. Specifically, procedure OS0443.47,, Revision.6, Change 3 (which was in effect on January 28,1996), step 8.1.2.7 stated "For any. abnormal, conditions with an emergency lighting y unit, hang an equipment deficiency tag, submit a work request or add to minor maintenance
/[ electrical maintenance (LS0551.02) RTS at the work control desk." This procedural step allowedjnoperable hence, a workstreque, emergency lighting units to'be repaired via the Minor Ma was not needed.
The description of the violation also stated that Section V of the RTS form " Operability,"
requires the documentation number for the work order initiated as follow-up action for identified inoperable emergency lights.Section V of the RTS does not contain such information.
However,Section VI "Closcout" does have entries for " Doc. Type" and " Doc. No." These entries are typically filled out by the System Engineer after the repair has been completed if a follow-up work request or other document is necessary. However, they do not constitute a o -requirement that a work request must be initiated. As stated above,Section IV of the RTS -
" Work Performance," did indicate that the three inoperable lights were entered onto the Minor Maintenance log for repair.
,It should be noted that for the January 28,1996 surveillance, all three emergency lighting units r were successfully repaired by the Minor Maintenance program prior to the next monthly surveillance. However, a review of past surveillances indicated that one of the lights (ESLO72) was on the Minor Maintenance log and had not been repaired within several surveillance periods l (since October 1995) prior to January 28,1996. North Atlantic believes that the repair of this light was less than expeditious. This issue is further dScussed in response to VIO 96-03-02 in Section B, below.
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- b. Notification of the Unit Shift Supervisor :
Procedure OS0443.47 requires that the Unit Shift Supervisor (USS) be notified of any emergency lighting unit that fails to operate or if any other discrepancies are found during the :
implementation of the procedure. North Atlantic has determined that Fire Protection personnel !
were not immediately notifying the USS of such failures. They believed this requirement was being met when the USS reviewed the completed RTS form. For clarity, it should be noted that the USS did sign-off on the RTS form as " failed" on January 28, 1996, the day after the ;
surveillance was initiated. This, however, does not meet North Atlantic's expectations regarding i notification of the USS. I
- c. Compensatory Actions forInoperable Emergency Lighting Units As noted in the inspection report, the Fire Brigade leader did not implement any compensatory measures while the emergency lighting units were out of service. No programmatic requirement ;
existed at that time to implement such compensatory actions. However, North Atlantic agrees that it is prudent to implement compensatory actions for inoperable emergency lighting units. i Corrective Actions for Examnle 2 l
- 1. The Operations Manager provided his expectations to the Fire Fighter Supervisor and the ;
Fire Brigade Leaders on the timeliness of notifying the USS of inoperable emergency lighting units. This topic was subsequently discussed with other Fire Protection staff at shift turnovers. I
- 2. Procedure OS0443.47 was revised to require the establishment of compensatory actions -
for inoperable Appendix R emergency lighting units.
- 3. Maintenance procedure LS0565.31, "8 Hour Emergency Light Inspections,".will be ;
revised to ensure that the USS is notified ci inop.erable Appendix R emergency lights and to require the initiation of a priority 2 work. request for lights that can not be repaired at 1 that time. It is anticipated that this procedure will be revised by October 30,1996.
- 4. Maintenance procedure LS0565.27, " Bus Outage Preparation for 8 Hour Emergency Lights," will be revised to ensure notification of the USS for emergency lights that will be made inoperable. It is anticipated that this procedure will be revised by October 30, ;
1996. !
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l B. Inadeouate Procedure - VIO 96-03-02 Rearon for Violation North Atlantic does not contest this violation, however, the following clarification is necessary.
The violation stated that procedures OS0433.47, Revision 6, and LS0564, Revision 2 (actually ,
LS0565.31, Revision 2), were not written to include Seabrook Design Basis Document, DBD-FP-01, " Emergency Lights," design requirements for returning 10 CFR Part 50, Appendix R emergency lights to an operable status within 30-days of being identified as inoperable. The inspection report also stated that the design basis document (DBD-FP-01, Revision 0) requirement for emergency light restoration to be completed within 30-days had been in effect since July 6,1989. However, Revision 0 of DBD-FP-01, which is still in effect, does not contain any such requirement or guideline. The proposed 30-day guideline is documented in the draft Revision 1 of DBD-FP-01. Revision I was developed in January 1996 ed is currently ,
undergoing review but has not yet been finalized. North Atlantic does not believe it is '
appropriate to modify its procedures or programs to conform to the proposed Revision 1 of DBD-FP-01 since it has not yet been finalized or codified. 1 Notwithstanding the above, it is necessary to discuss a self-identified issue associated with timeliness and the origination of the proposed 30-day guideline as contained in the draft design basis document. Speci5cally, the need for programmatic guidance for time limits for repairing inoperable Appendix R emergency lights was first identified by North Atlantic in a Quality Assurance Audit Report observation in August 1994. To address this observation, maintenance procedure MA 3.1, " Work Request," was to be revised by January 1995, to require the initiation l
of a priority 2 work request to repair inoperable Appendix R emergency lights. This was intended to ensure that inoperable emergency lighting units were repaired within 30-days. The 30-day guideline is a self-imposed time limit to ensure the lights were repaired prior to the next monthly surveillance. However, the subject procedure change was inadvertently not implemented. This oversight was subsequently identified by North Atlantic during a Maintenance Group self-assessment prior to' the arrival of the inspector and an Adverse Condition Report (ACR) was written to evaluate and resolve this condition.
North Atlantic has determined that the 30-day guideline for repairing inoperable emergency lighting units was not incorporated into Station procedures bect.use of an oversight on the part of the Maintenance Group. This action item was inadvertently not entered into a tracking system.
Corrective Actions i
- 1. North Atlantic initiated Adverse Condition Report (ACR)96-290 to evaluate the cause for this condition and to develop corrective actions. l
- 2. Affected departments (i.e., Maintenance, Operations, Technical Support, Engineering, and Planning and Scheduling) were notified of the need to repair inoperable Appendix R emergency lighting units via priority 2 work requests.
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Procedure OS0443.47 was revised to define maintenance activities for Appendix R emergency lighting units that can be performed under the Minor Maintenance program '
and those activities that require a work request. Additionally, this procedure was revised to allow Fire Protection staff to replace burned out Appendix R emergency lighting bulbs ,
at the time they are discovered to be inoperable (# 4 ti b bd E
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- 4. As stated in response' to VIO 96-03-01, maintenance procedure LS0565.31, "8 Hour Emergency Light Inspections," will be revised to ensure that the USS is notified of inoperable Appendix R emergency lights and to require the initiation of a priority 2 work l request for lights that can not be repaired at that time. It is anticipated that this procedure will be revised by October 30,1996. .
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Maintenance procedure MA 3.1, " Work Request," will be revised to ensure that Priority 2
- work requests are initiated for the repair ofinoperable Appendix R emergency lighting i units and that such repairs should be completed within 30 days. It is anticipated that this 1 procedure change will be completed by September 1,1996. !
- 6. The Maintenance Group will evaluate whether enhancements are necessary to the processes for tracking items. It is anticipated that this evaluation will be completed by July 30,1996.
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- 7. The Maintenance Group will monitor any Appendix R emergency light failures and repairs for the remainder of the calendar year to verify the adequacy of the above !
described administrative enhancements. It is anticipated that this assessment will be i completed by December 31,1996.
1 III. Additional Corrective Actions NRC Inspection Report 96-03 requested that, in addition to the responses to the aforementioned j apparent violations, North Atlantic provide the plans for addressing other program weaknesses ~l described in the inspection report. As described in the executive summary of the inspection report, weaknesses were associated with procedure quality, staff understanding and awareness, reliance on personnel judgment, and the lack of established limits for identifying unacceptable plant conditions. Corrective actions for these weaknesses are described below.
Additional Corrective Actions
- 1. North Atlantic initiated Adverse Condition Report (ACR)96-544 to evaluate the collective set of Fire Protection program issues and weaknesses described in NRC Inspection Report 96 and to develop comprehensive corrective actions. It is anticipated that this ACR evaluation will be completed by August 31,1996. In addition to this ACR evaluation, North Atlantic intends to implement the following corrective actions.
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- 2. For the short-term, procedure changes will be implemented to correct selected specific weaknesses described in the inspection report. As an example, refer to proposed revisions to FP 2.2 to address specific weaknesses in the area of the control of combustible materials as described in the corrective actions to address VIO 96-03-01, above. It is anticipated that these short-term procedure changes will be implemented by August 15,1996.
- 3. For the longer term, North Atlantic will comprehensively review and revise the Fire Protection program. This program revision will take into account independent and self-assessment activities, feedback from departmental and interdepartmental meetings, reviews of other industry fire protection programs, and a detailed review of how the program satisfies regulatory requirements. It is anticipated _thatJh(revised Fire Protection program will be implemented by December 11_J 996.> Program implementation includes training of Fire Protection and other necessary Station personnel on the new program, and revision of other affected programs, procedures, and training.
- 4. The next phase of training for Fire Protection staff will include a detailed review of the Fire Protection Manual to ensure that all personnel understand program requirements, procedures, administrative controls, and management's expectations. The next pbase of training will begin on July 21, 1996, and is scheduled to be completed'by all Fire Protection staff by August 31,1996.
5.. North Atlantic will increase the level of oversight of the Fire Protection Program. 4 IV. Date When Full Compliance Will be Achieved North Atlantic is currently in compliance with regulatory requirements.
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