ML20199D082
| ML20199D082 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/07/1997 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigengaum T, Harpster T NORTHEAST UTILITIES SERVICE CO. |
| References | |
| 50-443-97-04, 50-443-97-4, NUDOCS 9711200247 | |
| Download: ML20199D082 (2) | |
See also: IR 05000443/1997004
Text
- .___ -. . . __ __
,
'
t
'
,
4'
~
,p
-
?
-
November 7, 1997
Mr. Ted C. Feigenbaum
Executive Vice President and Chief Nuclear Officer ,
Northeast Utilities Service Company:
c/o Mr. Terry L. Harpster
P.O. Box 128_ ,
Waterford, CT 06385
SUBJECT: INSPECTION REPORT NO. 50-443/97-04
Dear Mr. Feigenbaum:
This letter refers to your October 23,1997 correspondence, in response to our September
23,1997 letter.
Thank you for informing us of the corrective and preventive actions to address the
concerns regarding the failure to incorporate new boron concentration limits in'two safety-
related procedures prict to startup form refueling outage five, and the change to the safety
' injection system test iiender lineup without revising the procedure. These actions will be
examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
'
Sincerely,
ORIGINAL SIGNED BY:
.
Richard J. Conte, Chief
Projects Branch 8
Division of Reactor Projects
Docket No. 50 443
& cc: w/o cv of Licensee's Resoonse Letter- l
B. D. Kenyon, President - Nuclear Group
D. M. Goebel, Vice President - Nuclear Oversight
F. C. Rothen, Vice President - Work Services [@
' l) l
. D. B. Amerine, Vice President, Nuclear Engineering & Support Officer
R. N. Johannes, Director - Nuclear Training
B. L. Drawbridge, Executive Director - Services & Senior Site Officer
. A. M. Callendrello, Licensing Manager _- Seabrook Station
W. A. DiPr_ofio, Nuclear Unit Director - Seabrook Station
R. E._Hickok, Nuclear Training Manager - Seabrook Station -
,'
L. M. Cuoco, Senior Nuclear Counsel .
,
.
9711200247 971107
.
,
G
ADOCK 05000443
pp, l lll lfll
r-- mr1- t-- v- f
- .-. - - - - . .. -. . .. . . .
.
,
l
'
Mr, Ted C. Feigenbaum
.
2
cc: w/cy of Licensee's Response Letter
D. McElhinney, RAC Chairman, FEMA Rl, Boston, Mass.
R. Backus, Esquire, Backus, Meyer and Solomon, Nsw Hampshire
D. Forbes, Director, Nuclear Safety, Massachusetts Emergency
Management Agency
,
F. Getman, Jr., Vice President and General Counsel Great Bay Power Corporation
Commonwealth of Massachusetts, SLO Dn anee
R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts
Seacoast Anti Pollution League
State of New Hampshire, SLO
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
S. Comley, Executive Director, We the Peop!e of the United States
Distribution w/cv of Licensee Response 131191
Region i Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
PUBLIC
NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
R. Conte, DRP
E. Conner, DRP
C. O'Daniell, DRP
K. Kennedy, OEDO
R. Correia, NRR
F. Talbot, NRR
D. Screnci, PAO, ORA -
DOCDESK
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\sb3704.rpy
Ta receive e copy of th6e documen..
a
Indicate in the boa: "C* = Copy without attachment / enclosure "E" = Copy with attachmentienclosu,e *N' = No copy
OFFICE Rl/DRP Riyf l /
NAME EConner J--3?f RCohte
DATE 11//497 11!'!97
"
OFFICIAL RECORD COPY
-- ., . . - . . _ .
.,
, .
- "
.
,
I
, n.... ,
North
~
North Atlantic Energy Service Corporation
1 P.O. Box 300
' .$xAtlant.ic seehroot Niioaav4 - .,
' '
H
(603) 474-9521
The Northeast Utilities System
B
N '
October 23,1997
Docket No. 50-443 ..
n
NXN-97108 .
'
AR# 97017022
APJ/ 97023545 .
,
United States Nuclear Regulatory Commission e.
Attention: Document Control Desk
Washington, D.C. 20555
Seabrook Station
Renly to Notices of Violation
s
This letter responds to the Notices of Violation described in NRC Inspection Report 50-443/97- .
04. The reply is provided in the enclosure along with commitments made in response to the
violations.
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.
.
-[g gh9 W<^
Ted C. Feigenbaum ' b
Executive Vice President and
Chief Nuclear Officer
ec: II. J. Miller, Region 1 Administrator
A.W. De Agazio, Sr. Project Manager
R. K. Lorson, NRC Senior Resident inspector
.
~
g
- --
_
- -
,
.
,
-
8
'
REPLY TO A NOTICE OF VIOLATION
NRC Inspection Report 97-04 describes two violations. The first violation identifies North
Atlantic's failure to revise two safety related procedures to incorporate new Cycle 6 boron '
concentration limits prior to stfJtup from refueling outage fiVe. The second violation describes
North Atlantic's failure to process two procedure revisions utilizing the station qualified reviewer -
or the SORC review process. North Atlantic's response to these violations is provided below. .
s
1. Description of the Violations
The following are restatements of the violations:
A. Technical Specification 6.7.1.a states, in part, that written procedures as recommended in
Appendix A of Regulatory Guide (RG) 1.33, shall be maintained. Appendix A of RG
\ 1.33 requires emergency and abnonnai procedures.
Contrary to the above, between June 27 and July 8,1997, emergency procedure, ES-0.1, ,
Reactor Trip Response, and off-hormal procedure OS1202.04, Rapid Boration, were not
'
revised (or maintained) to incorporate the new Cycle 6 boron concentrations required to
be injected in the event that more than one control rod failed to fully insert during a
reactor trip. As a result, the plant operated for 1i days, since the start of Cycle 6 without
updated boron values in these procedures.
This is a Severity Level IV Violation (Supplement 1).
B. Technical Specification 6.7.5 states, in part, that changes to procedures may be made
prior to a Station Qualified Reviewer (SQR) or Station Operation Review Committee -
(SORC) review provided, the intent was not changed, and the change was approved by
two members of the plant management, at least one of whom holds a Senior Operator
license,
, Contrary to the above, on August 6,1997, the operators changed the lineup of the safety
injection system test header froin the primary drain tank to the refueling water storage
tank without properly changing procedure OS 1005.05, Safety injection System
Operation. The procedure change constituted a change in intent and bypassed the SQR or
SORC review process. .
This is a Severity Level IV Violation (Supplement I).
.
av
@
e
Page1of4
o
,. .
,
.
-
11. Reoly to the Notice of Violation
A. Two Safety Related Procedures Not Revised Prior to Startun--VIO-97-04-02
.
Reason for the Violation
a
North Atlantic agrees with the violation. North Atlantic's design control approval process
requires that the review and approval of a Design Change Record (DCR) be performed by those .
departments identified on the Interdiscipline Review Summary Form to ensure that all affected
procedures are identified.
The cycle 6 corc design was processed as a Design Change Record. However, the two affected
procedures, ES-0.1 " Reactor Trip Response" and OS1202.04, " Rapid Boration" were not
identified as affected procedures requiring revision to incorporate a new boron concentration
value. The new boron concentration values are not developed as part of the DCR package but .
are a product of a calculation that is performed by Reactor Engineering (RE) while updating _
'
technical dc affected by the DCR after the DCR has been approved. The new boron
concentration number was calculated and the Reactor Engineering Technical Data Book, Figure
RE-18, was revised with the new boron concentration value on June 23,1997, prior to cycle 6
startup.
The boron cc, centration values that are used to update ES-0.1 and OS1202.04 are obtained from
the Seabrook SdpnW Study, setpoint ID A25 "Boration Value (PPM) for Stuck Rod Concern."
The basis for setpoint ID A25 in the Seabrook Setpoint Study, referenced a value from the
UFSAR that was part of the original core design and was not recognized as subject to change -
with the new longer life core designs. The reason that procedure ES-0.1 and OS1202.24 were not
identified as requiring revision is because the design control process did not provide adequate
consideration of all variables (e.g., procedures), that may require revision due to the development
of a long duration core or a core with unique considerations. The process relied upon the
reviewers to identify the inter-relationship between the design and the procedures.
The Seabrook Setpoint Study was not reviewed and updated during the development and review
of the cycle 6 core design. The incorrect value in ES-0.1 and OS1202.04 was identified by the
Operations departm during the annual Emergency Procedures setpoint review. In addition,
during reviews performed as part of the corrective actions, it was determined that procedure
OS1202.04 may be using a non-conservative methodology to determine the rapid boration value
for two or more stuck rods when the Refueling Water Storage Tank (RWST) is used as the
makeup source. This concern has been corrected.
There were no adverse safety issues associated with this even'.. Technical Specification
Surveillance Requirement 4.1.1.1.1.a requires that within I hour after detection of an inoperable
control rod, the required shutdown margin be verified acceptable with an increased allowance for
the withdrawn worth of the immovable or untrippable control rod (s). This verification would be
accomplished using procedure RX1707," Shutdown Margin Surveillance." The data necessary
Page 2 of 4
_ _ _ _ . _ _
. -- - - ._ . . ..
_
.
.
,
d
to calculate the required increase in shutdown boron concentration (Figure RE 18) was updated
for the cycle 6 design on June 23,1997. Thus, the data necessary to perform a shutdown margin
verification in response to stuck control rods prior to updating the Rapid Boration procedure was
current for the cycle 6 design at the time of cycle 6 startup. Furthermore, there was enough -
conservatism in the beginning of cycle 6 conditions and in the method used to account for stuck
rods to show that shutdown margin requirements would have been met with the existing boric
acid concentrations. ?
Corrective Actions
.
North Atlantic has initiated the following corrective actions:
1) Procedures ES-0.1, " Reactor Trip Response" and OS1202.04, " Rapid Boration" were
revised to reference Figure RE-18 of the Reactor Engineering Technical Data Book for
the correct boron concentration values, including boration using the RWST as a source.
2) A review was perfomied to determine if the implementation of the Cycle 6 core design
affected the Cote Operating Limits Report (COLR), Technical Data Book, Technical
Specifications, Reactor Engineering and Operations Procedures. No additional procedure
changes were identified as a result of the Cycle 6 core design implementation.
3) The basis for setpoint ID A25 in the Seabrook Setpoint Study was revised to reference the
value in Figure RE-18 of the Reactor Engineering Tcchnical Data Book.
4) A checklist will be developed for future core reload DCR's to assist in the identification
of those variables that will require review for potential revision as part of the core design
process. [
Date When Comnliance Will Be Achieved
~
North Atlantic is currently in compliance with Technical Specification 6.7.1.a.
B. Failure to Perform qTemnorary Change to Procedure--VIO 97-04-01
Reason for the Violation
North Atlantic agro , with the violation. On August 6,1997, while using Procedure OS1005.05,
,
" Safety Injection System Operation," it was noticed that during an attempt .o seat an Emergency
'
Core Cooling System (ECCS) check valve, flow was present from the Refueling Water Storage
Tank (RWST) through the ECCS check valve test header to the Primary Drain Tank ( PDT). This
flow made it difficult for the Operations crew to determine ifleakage was decreasing during the
attempts to seat the leaking check valve. The Operations crew realigned the Safety Injection
System (SI) test header to the RWST. The Operations crew felt that alignment to the RWST was
permitted since the section of OS1005.05 being used had the following Caution statement: "RCS
l
.
! Page 3 of 4
. - _. . . - - - - .- -_ - . . .-
. . .
,
, ..
f
.
activity must be less than 0.0024 microcuries per gram dose equivalent 1-131 and less than
0.24/E microcuries per gram of gross activity to align to the RWST" and RCS activity was well
within these limits. Since OS1005.05 did not provide specific instructions for the alignment to
the RWST, the Operations crew chose to use the Miscellaneous Component ;.og, as denned in
Procedure OS1090.05, " Component Con 0guration Control," to perform the aligrenent and
mair,tain component configuration control. The Miscellaneous Component Log provides a
method for controlling components that are not locked, or maintained, and are not being
po itioned by a procedure or other administrative controls.
.
The use of OS1090.05 to realign the Safety Injection Test Header was inappropriate and
procedure OS1005.05 should have been revised as an intent change via the procedure revision
process.
Corrective Actions ,
'
North Atlantic har, initiated the following corrective actions:
1) Procedure 0S1005.05 was revised to incorporate instructions for alignment of the Safety
injection Test Ileader to the RWST or the PDT.
2) Procedure OS1090.05 will be reviewed and additional guidance will be developed, as
necessary, to ensure the Miscellaneous Component Log is used for the correct application.
3) This event will be reviewed during Operations continuing training.
Date When Full Comnliance Will Be Achieved
North Atlantic is currently in compliance with Technical Specification 6.7.5.
l
l
l
l
.
Page 4 cf 4