ML20128D953

Responds to NRC 921201 Ltr Re Violations Noted in Insp Rept 50-443/92-25.Corrective Actions Taken:Airlock Seal Test Surveillance Package Will Be Automatically Computer Generated Every 48 H When Plant Is in Modes 2,3 & 4

ML20128D953
Person / Time
Site:	Seabrook
Issue date:	12/31/1992
From:	Drawbridge B NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128D879	List: ML20128D874 ML20128D953
References
NYN-92-172, NUDOCS 9302100273
Download: ML20128D953 (7)

Text

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eab o k, H 03874 r_eia,a At;Jantic Telephone (603)474 9521 Energy Service Corpo.ation NYN 92172 December 31, 1992 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 Letter dated December 1,1992, 'NRC Region ! Inspection 50 443/92 25,* J. C. Linville to T. C. Feigenbaum (c) North Atlantic Letter dated December 10,1992, " Licensee Event Report (LER) 92 022 00: Non compliance With Technical Specification Surveillance Interval for Containment Air Locks", T. C. Feigenbaum to USNRC (d) North Atlantic Letter dated December 11,1992, ' Licensee Event Report (LER) 92 023 00: Missed Technical Specification Surveillances*, T. C.

Feigenbaum to USNRC

Subject:

Reply to a Notice of Violation Gentlemen:

In accordance with the requirements of the Notice of Violation contained in Reference (b), the North Atlantic Energy Service Corporation (North Atlantic) response to the Notice of Violation is provided as Enclosure 1.

Should you have any questions concerning this response, please contact Mr. James M.

Peschel, Regulatory Compliance Manager, at (603) 474 9521, extension 3772.

Very truly yours, g,,> , r/r Bruce . Draw ridge Executive Direc(to -

Nuclear Production BLD:TGP/ tad Enclosure 9302100273 930203 PDR ADOCK 05000443 G PDR a member of the Northeast Utilities system

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i United States Nuclear Regulatory Commission December 31, 1992 l i

Attention: Document Control Desk Page two STATE OF NEW liAMPSHIRE Rockingham, ss. December 31, 1992 Then personally appeared before me, the above. named Bruce L. Drawbridge, Executive .

Director of Nuclear Production, being duly sworn, did state that he is of the North Atlantic Energy Service Corporation that he is duly authorized to execute and file the foregoing 1 information in the name and on the behalf of North Atlantic Energy Service Corporation and that _the statements therein are true to the best of his knowledge and belief.

Aaw a. &&dd Tracy A. 'DeCredico, Notary Public  !

My Commission Expires: October 3,1995 cc: Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer North Atlantic Energy Service Corporation >

P.O. Box 300 '

Seabrook, NH 03874 MyThomas k Marting.

Regional Administrator -'

U. S. Nuclear Regulatory Commission >

Reg 8on _!

475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate I.3 Division of Reactor Projects U.S. Nuclear _ Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector. ,

P.O. Box 1149 Seabrook, NH ' 03874 3

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i North Aij,,g;c Decernber 33,3997 ENCLOSlfRE TO NYN 9217_2_

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Reply to a Notice of Violation I

During an NRC inspection conducted at Seabrook Station on October 13 November 16, 1992, two violations of NRC requirements were identified. The violations as provided in Enclosure 1 to inspection Report 50 443/92 25 are listed below:

A.

Technical Specification 4.6.1.3.a requires that containment air lock seal leakage be verified at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, when the plant is in mode 4 and the air lock is being used for multiple entries.

Contrary to the above, on November 10, 1992 the containment air lock seal leakage had not been verified for over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the plant had entered mode 4 and the alt lock had been used for multiple entries.

This is a Severity Level IV violation. i B.

Technical Specification 4.0.5.a states that inservice testing of AShiE '

Code Class 1,2, and 3 valves shall be performed in accordance with -

Section XI of the ash 1E Doller and Pressure Vessel Code.

1.

Contrary to the above, on November 12, inservice valve stroke testing of check valves, IA V 8031, 8032, 8033, and 8034, which supply instrument air to the component cooling water system temperature control valves, had not been performed in l Vessel Code. with Section XI of the AhtSE Boiler and Pressure accordance 2.

Contrary to the above, on' November 16, inservice valve stroke testing of the 'A' accumulator isolation valve, SI V 3, had not; been performed in accordance with Section XI of the AShtE Boiler and Pressure Vessel Code.

This is a Severity Level IV violation.

Vlointion A Reason for the Violatiqa-l This event was discussed in Reference (c), Licensee Event Report (LER) 92 No.22 00, North Atlantic has determined that the root cause of the violation is as follows:

l The cause for this event was determined to be the lack of an administrative me

, alert operations staff to perform the air lock scal' surveillance at the completion of long terrn outages when containment integrity has been set, l Operations procedure ON1090.04, i " Containment Entry,"_ provides an adequate administrative mechanism to ensure that this surveillance reactor shutdown. is performed during all phases of power operation and for initial entry following entries are being made This procedure does no_t apply, however, when multiple containment during outages.

The routine surveillance airlock seal test surveillance package,1 hihi 0T001, procedure OX1460.01, 'Altlock Seal Test Containment,"

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4 is normally generated on a weekly basis during power operation, or when specific ally required for a containment entry.

where containment entries are typleally made every two wee of multiple containment entries at the completion of an outage.

Corrective Actions North Atlantic Upon discovery, the personnel identified following actions were taken:this violation during the review of surve .

1 1.

Upon determination the that Technical Specification 4.6.1.3 surveillance later been exceeded, a leak test was immediately performed on the personnel This hatch.

test demonstrated that containment integrity was not compromised.

2.

Operations actions with theManagement operating crews.reviewed this event, the root cause, and the correctiv 3.

North Atlantic- initiated evaluation for this event. a lluman Performarce Enhancement System (HPES) incorporated in the corrective The recornmendation from the HPES evaluation are recurrence.- actions and the corrective actions to prevent Corrective Actions to Prevent Recurrence North Atlantic's corrective actions to prevent recurrence include the following:

1.

The airlock seal test surveillance package,1 MM 0T001, will be computer generated every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when the plant is in MODES 2,3, and This 4 automatical will ensure that the air lock seat surveillance is performed at least every 7 i whenever containment entries are made while in these modes, this action will be completed by January 15, 1993. it is anticipated that 2.

remind operators of the containmentA status board has been installe <

surveillance status. hatch status and the containment air lock 3.

A Training Development Request (TDR) will be initiated to ensure that this e reviewed with Operations shift crews during pre outage trainingItsessions. . is anticipated that this TDR will be issued by January 15, 1993.

4 the air lock leak rate after each air lock usage.The person service.

North Atlantic will evaluate the return of this system to service.This Date of Full Comoliance The immediate corrective actions taken by North Atlanti Technical Specification 4.6.1.3.a. c resulted in compliance with Additionally, the longterm corrective These actions were completed ~ on November 10, 1992.

compliance with this Technical Specification. actions described above will casure continued 2

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Violation 11 Reason for the Violation i

! North Atlantic has determined that the root92cause .

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The root cause of not testing the Inservice Test of the Instrument es-Air che

! during the second refueling outage has been identified as personnel error .

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times of various Primary Component Cooling Wa n

! accordance with procedure OX1412.11, 'PCCW System Cold Shutdown Va

{ Included in this procedure is the open and close exercise of the Instrum .

IA.V 8033. air supply isolation check valves, IA V 8030, IA V 8031, backup IA V 8032 i

, and These check valves are in the piping between Instrument Air Loo j

and Loop B and the backup nitrogen supply cylinders which provide t

nitrogen Dypass Valves, to the PCCW Temperature Control Valves and PCCW Tempe

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The -initial procedure OX1412.11 surveillance testing performed during the second refue required stroke time limits.was unsatisfactory when two PCCW valves exceeded their time since the effect of repairs on the remainder of the test valves which initially failed were repaired and successfully tested The .

instrument air check valves were tot included in the retest surveillance- Howeve i

j surveillance was not annotated to indicate that it was a partial surveillanceThe

. If it had i been so annotated the ' retest coordinator or Work Controle Superviso I

been a retest of alerted the failedto valves.the fact that the surveillance was to be performed 1

tested . quarterly as requireIn addition, it was determinec that these I submitted to the NRC on Marc y the North Atlantic inservice Testing Program as I

the first refueling outage to allow perfonnanceP ant modifications were installed during inappropriately listed in proce ur f the testing. These valves were i

• a and were therefore tested on a cold u i t e see ad f lin ou 1, from the first refueling outage being during the first refueling outage.ge, these check valves were only tested o 2.

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' .been identified as a procedure deficiency.The root e has cause of valves should have been coded as' being required for Cold SbuidownTh However, it

! was erroneously coded as an event-driven surveillance. .

existing checklist. programs would have identified this surveillance on the MODE i

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,C.ntrective Action North Atlantic surveillance personnel packages. identified the events listed in Violation B during of the revi Upon discovery, the following actions were taken:

1.

The Inservice Testing of Instrument Air check valves IA.V 8030, IA.V 8 IA V 8032. IA.V.8033 and Si accumulator isolation valve SI.V 3 was perform the same day it was identified that the tests had been missed (November 1 1992, respectively). All valves were tested satisfactorily. ,

Corrective Actions to Prevent Recurrence North Atlantic's longterm currective actions will include the following:

1.

Testing of the Instrument Air check valves will be included in the Station Proc for performing quarterly valve operability tests.

January 30, 1993. This is expected to be completed by 2.

shutdown surveillance.The Inservice Testing of the SI accumulator isolatio This is expected to be cornpleted by March 31, 1993.

3.

The concept of proper documentation of partially completed surveillanc be stressed to operators and retest personnel during the first phase of 199 requalification training. This is expected to be completed by March 1,1993.

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" Partial RTS*

surveillances. stamps will be provided to make it easier to identify partial This is expected to be completed by January 30, 1993.

5.

The method for writing / changing RTS's when changed will be reviewed and appropriate changes made, procedures are written, rev completed by June 30, 1993. This is expected to be 6.

North progratu Atlantic will investigate adding a screen to the Action Statemen entered. to provide a list of sur 'eillances required when an action statement is This is expected to be e ompleted by June 30, 1993, 7.

The method of developing, revis ng and changing procedures which implem Inservice Testing program will be reviewed and appropriate changes expected to be completed by Junc- 30, 1993. .

This is made Dnte of Full Comnllance The immediate Technical corrective Specification 4.0.5.a. actions taken by North Atlantic resultedwith in comoliance will ensure that the probability of recurrence of this type of even .

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