ML19332C785
| ML19332C785 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/17/1989 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| NYN-89148, NUDOCS 8911280544 | |
| Download: ML19332C785 (11) | |
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" New Hampshire Ted C. F:1 *:cm Senior Vice President and Chief Operating Officer NYN 89148 November 17, 1989 Director, Office of Enforcement United States Nuclear Regulatory Commission l
Vashington, DC 20$55
References:
(a) Facility Operating License NPF-67 Docket No. 50-443 (b) USNRC Ietter dated August 17, 1989, 'NRC Region I Augmented Inspection Team (AIT) Inspection (50-443/89-82) ef the Natural Circulation Test at Seabrook Station Unit l' I
W. T. Russell to E. A. Brown (c) USNRC Letter dated October 25, 1989, ' Notice of Violation l
and Proposed Imposition of Civil Penalty $50,000 (NRC Inspection Report No. 50-443/89-82)* W. T. Russell to E. A.
Brown j
(d) NHY Letter NYN-891335 dated October 31, 1989, 'New Hampshire Yankee Corrective Action Plan,' !. C. Feigenbaum l
to W. T. Russell i
Subject:
Reply to a Notice of Violation
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Gentlemen:
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.In accordance with the requirements of the Notice of Violation and i
Proposed Imposition of Civil Penalty [ Reference (c)), New Hampshire Yankee herein provides its response to the cited violations (Enclosure (1)). New Hampshire Yankee does not contest the proposed civil penalty, and includes herewith (Enclosure (2)) payment in the amount of $50,000.
Now Hampshire Yankee ha9 implemented a comprehensive corrective action
'l plan to ensure that events, such as that described in.he Notice o' Violation, do not reoccur at Seabrook Station.
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Should you have any questioan concerning our response, please contact l
Mr. James H. Peschel, Regulatory upliance Manager, at (603) 474-9521, extension 3172.
Very truly yours, 89)1280544 891117
.4 PDR ADOCK 05000443 PDC Ted C. Feigenbaum
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Enclosures New Hampshire Yonkee Division of Public Service Company of New Hampshire I l P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474 9S21
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. Director, Office of Enforcement November 17, 1989 United States Nucleat Regulatory Commission Page 2 cci Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Commissjon Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Victor Nerses Project Manager Project Directorate I-5 United States Nuclear Regulatory Commission Division of Reactor Projects Washington, DC 20555 Mr. Antone C. Corne NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555
. Y New Hampshire Yankee November 17, 1989 s
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l ENCLOSURE 1 to NYN-89148 i
r REPLY TO A NOTICE OF VIOLATION i
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New Hampshire Yankee f
November 17, 1989 j
REPLY TO A NOTICE OF VIOLATION l
During an NRC inspection conducted on June 28-30, 1989, violations of NRC requirements were identified.
In accordance with the instructions i
provided in the Notice of Violation and Proposed Imporition of Civil a
Penalty forwarded by Reference (c), the NHY response ta each violation is provided below. The total NHY Corrective Action Plan was provided to the NRC in Reference (d),
I Violations A.
10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, appropriate to the circumstances.
The procedures or drawings shall include appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.
10 CFR Part 50. Appendix B, Criterion XI, requires, in part, that a i
test program shall be established to assure that all tecting required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and cerformed in accordance with written test procedures which incorporata the requirements and acceptance limits contained in applicab:e design documents. Test procedureo shall include provisions for assering that all prerequisites for the given test have been met, and test results shall be documented and evaluated to assure that test requirements have been satisfied.
1.
Seabrook Startup Test Procedure 1-ST-22, entitled Natural Circulation Test, Attachment 9.3, Section B.5, sets forth the manual trip criteria for the test, and requires that the test be
. terminated and the reactor tripped if pressurizer water level is i
less than 172.
Contrary to the above, during the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, pressurizer level decreased bel's 172 and the reactor was not tripped by the operating shift se required.
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2.
Seabrook Startup Test Procedure 1-SI-22, Section 3.0, t
Prerequisites, Step 3.6.7 requires a sign-off confirming the l
avalle 'it.ty of the steam dump, including the atmospheric relief valves. as a prerequisite to the test.
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4 New Hampshire Yankee November 17, 1989 Contrary to the above, prior to the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, Step 3.6.7 war signed off by the Test Director confirming the availability of the main steam
. dump syrtem (includes valve No. MS-0V-3011): however, at the time, the valve was not ready to supp;rt the test because Work Order No.
WR7 WOO 5592 (which requires a ster,ke tert of the valve at normal operating temperature and pressure) was still open.
3.
Seabrook Startup Test Procedure 1-ST-22 Section 3.0, Prerequisites. Step 3.2 requires a signoff confirming that personnel involved with the performance of the procedure have been briefed on the procedure content and informeo of the respective duties.
Contrary to the above, prior to the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, Step 3.2 was cigned off by the Test Director confirming the adegancy of the pre-test briefing; however, the briefing waw inadequats in that one of the two control board operators assigned to assist the shift crew was not briefed on the procedure's reactor trip criteria.
4.
Seabrook Operations Management Manual. Section 1.8 requires that shift evolution briefings shall be conducted for individuals involved in the performance of an evolution.
This: section also states, in part, that complex evolutions requiring close coordination of individuals should include examinations of each individual's specific involvement and.responsibilitf.
Contrary to the above, prior to the performance of Startup Test ltocedure 1-ST-22 on June 22, 1989, the shift briefings were inadequate in that tho briefings were conducted in a fragmented manner and not for the operations crew as a group, and the briefings were not sufficiently detailed.
For example, the briefings did not cover each operator's specific involvement, responsibility, and understanding of the required interfaces and communications.
B.
10 CFR Part 50 Appendix B, Criterion XVI, requires, in part that neasures be established to assure that conditions adverse to quality are promptly identified and rorrected.
Contrary to the above, measures were not adequately established to assure that a condition adverse to quality was promptly identified and corrected as evidenced by the following examples:
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New Hampshire Yankee i
November 17, 1989 i
1.
During the performance of Startup Test Procedure 1-ST-22 on June 22, 1988, the Startup Manager, the Shift Test Director,_and the j
Test Director.became aware of a condition adverse to quality, but failed to ensure that the condition was promptly corrected. The adverse condition consisted of the pressuriser level dropping below the trip criteria specified in the test procedure and the failure of the operations staff to trip the reactor as required.
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Subsequent to the June 22, 1989 failure to promptly effect a manual reactor trip as required by the criterion in Startup Test Procedure i
1-57-22, licensee management did not promptly identify and correct l
associated personnel perforr.ance failures in that management initially made a decision to resume testing without completing a detailed and thorough analysis of the underlying causes of the event and without correcting the related human performance deficiencies.
RESPONSE
-New Hampshire-Yankee does not dispute the violati.ons as stated above.
l Detailed responses for each violation are provided below.
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-Violation A.1 Response 6
The Operating Shift failed to comply with the Natural Circulation Test Procedure, 1-ST-22, by not immediately manually tripping the reactor when the prescurizer level decreased below the test's 172 manual trip' criterion.
L The failute to strictly adhere to the Startup Test Procedure was an unacceptable deviation from NHY' operating policy.
The Operating Shift did not manually trip the reactor because the Unit 1.hift
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Supervisor (USS) misinterpreted the 17Z pressurizer level value specified in the test procedure to be test termination guidance, rather than a reactor trip criterion.
Corrective Action As immediate corrective action, meetings were held with each of the l
shift crews to review the policy on procedure compliance.
L Additionally, the President issued a remorandum to all personnel I
working at Seabrook Station re-emphasizing the requirement that all l
procedures are to be followed, t
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November 17, 1989
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Ntr Hampshire Yankaa developed and issued a comprehensive policy to clearly define procedure adherence requi ements for all NHY activities.
The NHY policy was issued as part of NBY Procedure 10000 and was incorporated verbatim in the Production Menagement Manual, the Station Management Manual'and the Operations Management Manual.
Training is being provided to Seabrook Station site employees on the enhanced procedure compliance policy.
The initial block of training has been L
completed and the makeup sessions are scheduled to be completed by November 30, 1989. Additionally, Procedure Compliance training will be integrated into the General Employee Training (GET).
Violation A.2 Resronse The step in Startup Test I'rocedure 1-bT-22 das signed off confirming the availability of the Main Steam Dump System because the Startup Test Program did not require that open retests, for applicable worn requests, be reviewed prior to the conduct of a.Startup Test. The Main Steam Dump System was considered to be available by virtue of the fact that the system was used during the Emergency Fecdwater Testing on June 12, 1989, and was used during the June 22, 1989, preparatory activities for the Natural Circulation Test.
Corrective Action The Startup Test Program Description has been revised to become the Power-Ascension Test Program (PATP) and includes a requirement to review open Work Requests and verify that the equipment required to support test activities is operable. The PATP was reviewed by SORC on October 25, 1989, and was issued on November 17, 1989. Training is currently. scheduled to be provided on the PATP procedural requirements for the test crews composed of PATP and Operations personnel, on a one crew per week basis, commencing on December 4, 1989, with completion expected by January 12, 1990.
Violation A.3 Resppas,e, The pre-test briefing given to the crew parforming the Natural Circulation Test was not effective. The reactor trip criteria information was disseminated to the crew members, but the requirement to perform a manual reactor trip at 172 pressurizer level was not discussed with eae.h test crew member and was not fully understood by the entire crew. Additionally, the bcais for the inclusion of the 172 pressurizer level reactor trip criterion was not discussed, nor was it understood by the appropriate personnel involved in the test.
Startup Test Department management and the Shift Superintendent did not ensure thtt all test crew personnel were adequately prepared to perform the test.
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New Hampshire Yankee November 17, 1989 Corrective Action i
The Startup Test Program Description has been revised to beco.ne the l
Power Ascension Test Progran (PATP). The PATP requires that a comprehensitre preshift briefing be provided to all test crew members l
prior to the test crew assuming the shift.
The briefing will ensure that all test crew members will understand the test crito w r
expected plant response and required actions. Additions 11y, the PATP requires that each PATP test procedure include a background document that describes the reason the test is being conducted, the test critoria, test methods and test controls.
6 The PATP has been reviewed by SORC and was issued on November 17, 1989. -The test crews will be trained on the PATP as discussed in the response to Violation A.2.
The individual PATP test procedures are being reviewed and revised to include the above requirements.
The thirteen (13) PATP test procedures, which require test crew training on the simulator, are currently scheduled for SORC review by November 30, 1989.
yiolation A.4 Response The pre-test' briefing given to the crew performing the test was inadequate.
The procedure page containing the reactor trip criteria was disseminated to the test crew' members but was not discussed in detail during the bilefing.
The actual briefing,was inadequate because the briefing was not fornsally presented to the test crew as a whole.
The briefing was not sufficient in detail'and the trip criteria was not discussed with the entire crew.
Startup Test Department management and the Shift Superintendent failed to ensure that all test crew personnel were adequately prepared to perform the test.
1 Corrective Action i
The Startup Test Department has been replaced by the Power Ascension Test Program organization. A PATP Manager has been appointed and given the responalbility for all aspects of the PATP to include ensuring all personnel are trained, briefed and prepared to perform assigt d teste.
The PATP contains a requirement that each PATP test procedure contain a L
briefing document.
The briefing document will be reviewed during the l
approval cycle and will he used to conduct the pre-shift briefing. The L
PATP, Procedure SM 8.1 and the Operations Manegement Manual (OPMM) will I
contain' guidance for all PATP or Operations personnel to raise any i
issue that is not understood or to stop an evolution if they do not understand their responsibilP.ies in the conduct of a test.
The OPMH ano SM 8.1 revisions containing this guidance were issued on November 10, 1989, and November 15, 1989, respectively, c
Additionally, the test crews, composed of PATP and Operation personnel, will be trained on the PATP programmatic requirements and the specific PATP tests as discussed in the response to Violation A.2.
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Violation B.1 Resoonse The failure of Startup Test Department management personnel to ensure that the reactor was promptly tripped was due to an inadequacy in the assignment l
of personnel responsibilities and requirements as defined in the Startup Test Program Description. When the Test Director was avare that the Unit Shift Supervisor knew that the trip criterion had been exceeded, he withdrew from further interaction in order to allow the licensed operators to take the appropriate actions to control plant parameters. The Startup personnel on shift and in the Control Room should have taken prompt action to correct the condition adverse to quality by ensuring that the Operations personne) were aware of the requirement to trip the reactor.
Corrective Action The Startup Test Program Description has been enhanced and revised to become the Power Ascension Test Program (PATP). The PATP includes i
requirements for comprehensive pre-rnift briefings prior to the test-crew assuming the shift to ensure that the crew understands the test I
criterja, expected plant response and required actions. Additionelly, the PATP requires the test procedures to provide additional guidance for terminating the test and exiting the tost procedure when equipment malfunctions occur during testing or test limits are exceedel.
The PATP has been revfewed by SORC and was issued as procedure SM 8.1 on November 17, 1989.
The PATP test procedures are being revised. The thirteen (13) PATP test procedures, which require test crew training on the simulator, are currently scheduled for SORC review by November 20, 1989.
The remaining PATP tast procedures, which do not involve significant test crew interaction (such as data taking procedures), tre currently scheduled for SORC review by December 51, 1989.
The PATP provides explicit guidance for the PATP and Operations personnel regarding test termination and test interruption.
Additionally, the respoualbilities of PATP personnel are defined-including their resprnsibility to ensure that the test is conducted according to the prncedure. Each-test crew will receive training on the PATP and the ino vidual test procedures as discussed in the response to Violation A.2.
The training will include the definitions of responsibilities for each of the personnel on the test crew.
l Violation B.2 Response l
l Subsequent to the reactor trip, New Hampshire Yankee management took action lt to initiate a review of the Natural Circulation Test Procedure and the l
policies on procedure compliance.
However, the NHY management personnel who participated in the 6:00 p.m. cenference call with NRC Region I on June 22nd I
had not completed their analysis of the event and therefore did not yet have sufficient information to completely discuss the procedural non-compliance and the proposed corrective actions.
In addition to being unable at that time to discuss specific details on the procedural inadequacies and the 6
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- t New Hampshire Yankee November 17. 1989 s
NHY managtment did net effectively communicate to the NRC their recognition of the seriousness of the procedure ncncompliance and r
the actions planned to more fully evaluate the event and to prevent recurrence.
Statements made by some NHY personnel, which cupported the actions taken or not taken by the operating crew, were itappropriate and did not represent the NHY procedure compliance policy.
3 Statements made by some NHY personnel, which indicated NHY was considering restarting the reactor prior to the completion and evaluation.of a total event analysis, were inappropriate and did not accurately represent NHY policy or the understanding of the NHY PresJdent.
l Correctiv' Action The Vice President - Nuclear Production was relieved of his duties t
related to Seabrook Station on June 29, 1989.
The position was replaced by the Executive Director - Nuclear Production and staffed on l
July 24, 1909.
The Power Ascension Test Program was revised to require that an Event Evaluation Report be completed prior to recommending reactor restart if
.an unplanned reactor trip should occur during power ascension testing.
Additionally, the Post Trip Review procedure will be revised prior to November 27, 1989, to ensure that humsn performance issues are specifically addressed and any corrective actions are identified as part of the restart readit. ss decision asking process.
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ENCLOSURE 2 TO NYN-L9148 t
s PAYMENT OF CIVIL PENALTY 7A14KEE ATOMIC ELECTRIC COMPANY' CHECK HO.
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