ML20077S223

Responds to NRC Re Violations Noted in Insp Rept 50-443/94-24.Corrective Actions:Util Revised Undervoltage Test Procedure to Perform Tadot W/O Disabling Existing Protection Circuitry

ML20077S223
Person / Time
Site:	Seabrook
Issue date:	01/13/1995
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-95003, NUDOCS 9501240003
Download: ML20077S223 (6)

Text

._ . ._ .. _ __ _._ _ . _ _ .

e w,,,

North Atlantic Energy Service Corporation

i. North y.0. 3o,300 N

Atlantic Seabrook, NH 03874 (603)474-9521, Fax (603)474-2987

)

The Northeast Utilities System Ted C. Feigenbaum  ;

NYN. 95003 Senior Vice President 8. ,

Chief Nuclear Officer January 13,1995 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

References:

(a) Facility Operating License No. NPF-86, Docket No. 50-443 (b) USNRC Inspection Report No. 50-443/94-24, dated November 22,1994, R. W.

Cooper to T. C. Feigenbaum (c) Enforcement Conference between USNRC (R. W. Cooper et. al.) and Nonh  ;

Atlantic (T. C. Feigenbaum et. al.) on December 5,1994, regarding NRC ,

Inspection Repon No. 50-443/94-24 (d) USNRC Letter dated December 16,1994, " Notice of Violation (NRC Inspection Report No. 50-443/94-24," R. W. Cooper to T. C. Feigenbaum (e) North Atlantic Letter NYN-94129, dated November 21,1994, " Licensee Event Report No. 94-016-00: Non-Compliance with Technical Specification 3.3.2 ,

Action Requirements," T. C. Feigenbaum to USNRC -

(f) North Atlantic Letter NYN-94145, dated December 29,1994, " Licensee Event Report No. 94-016-01: Non-Compliance with Technical Specification 3.3.2 Action Requirements," T. C. Feigenbaum to USNRC  ;

I

Subject:

Reply to a Notice of Violation i Gentlemen:

In a letter dated December 16,1994 (Reference (d)], the NRC described two violations regarding the procedure adequacy and corrective action aspects of emergency bus undervoltage testing at Seabrook Station. Accordingly, the Enclosure provides North Atlantic Energy Service Corporation's (Nonh Atlantic) response to these violations.

I Should you have any questicns concerning this response, please contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474-9521, extension 3772. l Very truly yours, TCF:JES/jes 1CGGS3 pd Ted C. Feigenb um nel sure 9501240003 950113 Cl ,  ;

PDR ADDCK 05000443 i g PDR I l

r United states Nuclear Regulatory Commission January 13,1994 Attention: Document Control Desk Page two i

ec: Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 '

Mr. Richard Laura NRC Senior Resident inspector l P.O. Box 1149 Seabrook, NH 03874 l

'I I

l 1

REPLY TO A NOTICE OF VIOLATION NRC Inspection Report 94-24 [ Reference (b)], described two apparent violations regarding the design control and corrective action aspects of emergency bus undervoltage testing at Seabrook Station.

North Atlantic Energy Service Corporation (North Atlantic) provided information on these apparent violations at an enforcement conference held on December 5,1994 [ Reference (c)]. In a letter dated December 16,1994 [ Reference (d)], the NRC maintained the violation on corrective action, retracted the apparent violation on design control, and added a new violation on the adequacy of procedures. North Atlantic's response to these violations is provided below.

1. Description of Violations A. Seabrook Technical Specification 6.7.1 requires that written procedures be established, implemented, and maintained covering the procedure of Appendix A of Regulatory Guide 1.33, Revision 2. Section 8 of Appendix A on survei'iance test procedures requires that a procedure, appropriate for the circumstances, be developed for emergency power testing.

Contrary to the above, since entering the initial operating mode 4 on December 2,1988 to October 20,1994, the emerger.cy power bus loss-of-voltage and degraded voltage surveillance test procedures were not appropriate for the circumstances. The procedural inadequacies briefly disabled the protection system during testing, which was beyond the design basis. The procedure performed a trip actuating device operational test on a system designed for a functional test only.

This is a Severity Level IV violation. (Supplement I).

B. 10 CFR 50, Appendix B. Criterion XVI, requires that nonconfomiing conditions are promptly identified and corrected to preclude repetition.

Contrary to the above, since December 9,1987 to October 20,1994, multiple opportunities existed for licensing, engineering and maintenance personnel to identify and correct an incompatibility between the design basis and the licensing basis for the emergency electrical busses loss of voltage protection circuits. The licensee identified in Request for Engineering Services88-119 the potential disablement of the protection circuits during testing, which was beyond the design basis of the plant and a nonconforming condition. Similarly, on or about April 13,1993, the licensee performed an electrical distribution safety functional assessment and identified the emergency bus undervoltage scheme testing as an issue. Further, on or about December 9,1993, the licensee wrote SIR 93-109 to address tDe monthly disabling of the loss-of-voltage circuits when installing and removing the test block.

This is a Severity Level IV violation. (Supplement 1).

II. holv to Violations North Atlantic does not contest the issues stated in these violations as they are consistent with and further substantiate our prior conclusions and previously initiated corrective actions regarding needed enhancements for both station procedures and the Corrective Action Program. In this regard, prior to issuance of these violations, North Atlantic had recognized these opportunities for improvement and was in the process of developing and implementing appropriate corrective actions.

1

A: Procedurc Violation As described in LER 94-16-00 [ Reference (e)], and as supplemented in LER 94-16-01 [ Reference  ;

(f)], North Atlantic self-identified that the emergency power bus loss-of-voltage surveillance procedure briefly created a condition prohibited by the Technical Specifications. The root cause for this was determined to be the acceptance of inappropriate Technical Specification requirements regarding emergency bus undervoltage protection. A contributing cause was the misinterpretation of Technical Specification 3.3.2, Table 3.3-3, Action 18 as it applied to undervoltage protection functions. The following describes the interrelationship of the design basis, Technical Specifications, and the undervoltage surveillance procedures, as they relate to this issue.

The original design basis for the undervoltage testing scheme at Seabrook Station, as approved by the NRC in the SER, included a functional test to be conducted during refueling outages. Bypass indication specified by Regulatory Guide 1.47 was not necessary since testing was not intended to be conducted more frequently than once per year. Subsequently, Nonh Atlantic submitted proposed Techdcal Specifications based on Revision 4 to the Standard Technical Specifications. This submittal included a Trip Actuating Device Operational Test (TADOT) during refueling outages. The existing undervoltage circuitry was capable of accommodating the performance of a TADOT. In response, the NRC provided Revision 5 of the Standard Technical Specifications to North Atlantic, which changed the TADOT from refueling to monthly. North Atlantic accepted these Technical Specifications and failed to l identify the change of the TADOT from every refueling outage to monthly. Nonh Atlantic subsequently  ;

misinterpreted the requirements of Technical Specification 3.3.2, Table 3.3-3, Action 18, and developed procedures that allowed portions of the undervoltage protection circuitry to be briefly disabled during testing. However, undervoltage protection was provided for a design basis event involving a loss of offsite power during the brief disablements. At that time. North Atlantic believed that the brief disabling of portions of this circuitry was acceptable per Action 18 of the Technical Specifications.

Corrective Actions Pertainina to Procedure Violation

1. Nonh Atlantic has revised the undervoltage test procedure to perform a TADOT without disabling the existing protection circuitry. This revised testing methodology, which fully meets regulatory requirements, is described in NRC Resident Inspection Report 94-24.

2. North Atlantic is currently developing a design change to modify the undervoltage relay cases where appropriate to enhance testing capability. North Atlantic notes that this design change will only make it easier for technicians to properly perfonn testing, and it is not necessary to satisfy any regulatory requirements.

3. North Atlantic will submit a License Amendment Request to clarify Technical Specification 3.3.2, Table 3.3-3, Functional Units 9a and 9b, and Action 18.

4. North Atlantic had previously initiated the Procedure Upgrade Program (PUP). This is a substantial, resource intensive initiative that will improve the quality and accuracy of procedures.

Initial planning for PUP began in the fall of 1993, and the program is currently undergoing pilot testing and will be fully implemented in January 1995. The PUP will specifically include a review of safety significant surveillance procedures for conformance with the Technical Specifications and the plant design.

The procedure review will be prioritized according to the following attr.~outes:

2

Nuclear and personnel safety significance.

Complexity of the procedure.

Frequency of performance.

Consequences of error while performing the procedure.

l Amount of negative feedback from the end users. 1 llistory of problems with the procedures. I

5. Nonh Atlantic will also revise the PUP program documents to clearly delineate where Engineering resources will be t.tilized in the review process.

B. Corrective Action Program Violation North Atlantic believes that the emergency bus undervoltage testing issue could have been resolved

]

in a more expeditious manner. North Atlantic has determined that this issue was not previously resolved ,

due to both an improper interpretation of the Technical Specifications and lack of aggressive and timely ]

implementation of the Corrective Action Program. Specifically, during the reviews associated with the  !

previous opportunities to identify and correct this discrepancy, it was not recognized that disabling j portions of the emergency bus undervoltage scheme during testing created a condition prohibited by the Technical Specifications. In fact, disabling this circuit for testing purposes was supported by the literal  ;

requirements of the Technical Specifications. It was not until North Atlantic personnel questioned the  ;

intent of this specification that it was recognized that its requirements were intended for undervoltage circuitry with a 2 out of 4 logic, and not a 2 out of 2 logic that is utilized at Seabrook. North Atlantic  !

believes that the self-identification of this issue is representative of the positive cultural changes that have I recently taken place at Seabrook Station. It demonstrates a good safety perspective and a questioning attitude on the part of Seabrook Station personnel. j Notwithstanding these positive cultural improvements, more aggressive and timely implementation of the corrective action program could have provided a second barrier to ensure more expeditious i resolution of this issue. This ;s consistent with North Atlantic's prior conclusions regarding the Corrective j Action Program. Specifically, prior to the identification of this issue, North Atlantic had been developing i

improvements to the Corrective Action Program to specifically address similar concerns. These improvements are described below. )

l Corrective Actions Pertainine to Corrective Action Program Violation t I

1. North Atlantic will continue to implement the Corrective Action Program with the current low threshold level to ensure that appropriate items are reported to management. North Atlantic Managers, at the Group Manager level will be held accountable for ensuring that items are reported in a timely manner and for ensuring that significant corrective action documents are completed in a timely manner.

2. North Atlantic will also revise the Corrective Action Program. The Occurrence Review Committee (ORC) will be restructured to create an ORC with more technical skills. The ORC will meet daily, or as required, to review Corrective Action Documents and determine which documents are significant. The significant items will receive detailed review and analyses, while the lesser items will be trended by the ORC. ORC will ensure significant issues are evaluated in a timely manner by setting the appropriate priority, similar to that used for work requests. ORC ,

will also utilize trending to identify reoccurring events that may require further evaluation.

l l

3 1

1

I

~ ' ' Additionally, ORC will review proposed corrective actions contained in draR evaluations to ensure that they are appropriate.

North Atlantic believes that these improvements to the Corrective Action Program, in conjunction ,

with the aforementioned positive cultural changes, will enhance the effectiveness of the program and ,

. preclude recurrence of similar issues in the future, i

111. Additional Corrective Actions Additional corrective actions relating to the failure to satisfy the undervoltage testing Technical Specification surveillance requirements are described in LER 94-016-01 [ Reference (f)).

IV. Date When Full Compliance Will Be Achieved  ;

t North Atlantic is currently in compliance with regulatory requirements.

)

t i

l 4

.- . - .. - _ _ .-. _ . _ .