EA-01-032 - Seabrook 1 (North Atlantic Energy Service Corp.)
June 29, 2001
Mr. Ted Feigenbaum
Executive Vice President and Chief Nuclear Officer
North Atlantic Energy Service Corporation
c/o Mr. James M. Peschel
P.O. Box 300
Seabrook, NH 03874
|SUBJECT:||FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION AT SEABROOK (NRC INSPECTION REPORT 0500443/2000-011)|
Dear Mr. Feigenbaum:
The purpose of this letter is to provide you with the final results of our significance determination of the preliminary White finding identified during the subject inspection conducted between November 7, 2000 and January 18, 2001. This inspection finding, which involved the failure to take adequate corrective actions to address degraded components associated with one of the two emergency diesel generators (EDG), was assessed using the significance determination process. The finding was preliminarily characterized as White, an issue of low to moderate safety significance, as noted in the NRC letter dated March 2, 2001, which transmitted the related inspection report.
The finding was identified after a failure of the 1B diesel generator occurred during a 24-hour surveillance test in November 2000. The failure involved the crankcase overpressurizing, resulting in lifting of the crankcase relief cover assemblies, as well as displacement of the crankcase exhauster hose. Subsequent inspection revealed damage to one of the pistons and its cylinder liner as a result of non-uniform thermal growth of the aluminum piston skirt. That growth caused scuffing, scoring, and transfer of aluminum material from the piston skirt to the cylinder liner. The heat generated by the friction (galling) between the skirt and the liner bore, coupled with the hot combustion gas blow-by, eventually ignited oil vapor in the crankcase.
Approximately 5 years earlier, on November 21, 1995, you had replaced the liner for one of the cylinders of the 1B diesel generator due to an out-of-round wear condition. In addition, on April 17, 1999, you replaced a liner for another cylinder in that same diesel generator due to an observed polished finish appearance and lack of crosshatch pattern, which was indicative of heavy wear. However, no condition report was written in either case. As a result of not entering those degraded conditions into the corrective action process, you did not fully evaluate the cause of those degraded conditions to prevent any subsequent recurrence of degraded cylinder liner conditions. This performance issue (failure to place these degraded conditions into the corrective action process and evaluate the cause of the degraded conditions of the emergency diesel generator) was determined to be a potential cause in the 1B diesel generator failure in November 2000.
This performance issue, which also constitutes a violation of 10 CFR Part 50, Appendix B, Criterion XVI, had several other aspects. For example, you also: (1) failed to establish appropriate quantitative or qualitative acceptance criteria for boroscopic inspections of the diesel generator cylinder liners; (2) did not incorporate industry operating experience to modify your diesel generator tests to minimize wear; and (3) did not evaluate the worn cylinder liners replaced during previous outages to determine the cause of the wear.
This issue was assessed using a Phase 3 Significance Determination Process analysis and was preliminarily determined to be White (i.e., an issue with some increased importance to safety, which would require additional NRC inspection). The issue has low to moderate safety significance because emergency diesel generators are an important mitigating system during a loss of offsite power event. Our March 2, 2001, letter also provided you an opportunity to attend a Regulatory Conference or submit a written response to address the finding. You declined a conference and rather, discussed your position in your letter dated April 6, 2001. In your letter, you did not deny that a violation occurred. However, you did contend that this finding was of very low risk significance and should be classified as a Green finding, and that you had taken prompt aggressive corrective action to address the diesel generator failures.
The NRC has evaluated the information developed during the inspection as well as the information you presented in your April 6, 2001, response. The NRC acknowledges that you took corrective action following the 1B diesel generator failure. Your actions included partial disassembly of both diesel generators, replacement of the lubricating oil, and reassembly to the manufacturer's specifications and tolerances regarding cylinder liner finish and piston cleanliness. The reassembly of the 1B diesel generator included replacement of the No. 7 cylinder piston skirt and liner, all main bearings, and the crankshaft. More broadly, the NRC recognizes that you have initiated steps to address the underlying problems that contributed to the diesel failure. These steps include a program to address long term reliability of safety related systems. The NRC will assess the effectiveness of these corrective actions in future inspections.
Based on our evaluation as documented in the enclosed Review of Licensee Response, the NRC has made a final significance determination that the finding should be classified as White, an issue of low to moderate significance. You have 10 business days from the date of this letter to appeal the staff's determination of significance for the identified finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.
The subject violation is cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the violation were also described in detail in the subject inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice of Violation is considered escalated enforcement action because it is associated with a White finding. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. Your response should include details of your program to address long term reliability of safety related systems, as well as steps to assure that identification of conditions adverse to quality, such as the DG-1B problems in 1995 and 1999, are promptly and thoroughly evaluated for cause and are effectively corrected. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public NRC Library).
|Hubert J. Miller
Docket No: 05000443
License No: NPF-86
Enclosure: Notice of Violation
B. D. Kenyon, President and Chief Executive Officer
J. M. Peschel, Manager - Regulatory Programs
G. St. Pierre, Station Director - Seabrook Station
D. Roy, Training Manager - Seabrook Station
D. E. Carriere, Director, Production Services
W. J. Quinlan, Esquire, Assistant General Counsel
W. Fogg, Director, New Hampshire Office of Emergency Management
D. McElhinney, RAC Chairman, FEMA RI, Boston, Mass
R. Backus, Esquire, Backus, Meyer and Solomon, New Hampshire
D. Brown-Couture, Director, Nuclear Safety, Massachusetts Emergency Management Agency
F. W. Getman, Jr., Vice President and Chief Executive Office, BayCorp Holdings, LTD
R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts
M. Metcalf, Seacoast Anti-Pollution League
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
S. Comley, Executive Director, We the People of the United States
W. Meinert, Nuclear Engineer
S. Allen, Polestar Applied Technology, Incorporated
R. Shadis, New England Coalition Staff
Notice of Violation
|North Atlantic Energy Service Corporation
|Docket No. 50-443
License Nos. NPF-86
During an NRC inspection conducted from November 7, 2000 to January 18, 2001, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to prevent repetition.
Seabrook Station Technical Specification 6.7.1.a states, in part, that written procedures shall be implemented. Seabrook Station Administrative Procedure OE 3.1, "Initiating a Condition Report," Rev. 13, requires initiation of a condition report when an unwanted or unexpected condition occurs.
Contrary to the above, when significant conditions adverse to quality were identified on November 21, 1995 and April 17, 1999, involving degraded components in emergency diesel generator DG-1B, the licensee failed to determine the cause of the condition and failed to take appropriate corrective actions to prevent recurrence. Specifically, during the 18 month inspections of DG-1B performed on those dates, cylinder liners revealed heavy wear, as evidenced by an out-of-round wear condition on one liner and a polished appearance and lack of honing (crosshatch pattern) on the inside bore surface of the other liner. Although the No. 10 degraded cylinder liner was replaced on November 21, 1995, and the No. 11 cylinder liner was replaced on April 17, 1999, using work requests, condition reports were not written. As a result, the licensee failed to determine the cause of the degraded cylinder liners consistent with the diesel generator's importance to safety. Therefore, similar degradation went unnoticed until an actual failure occurred to cylinder No. 7, resulting in the failure of DG-1B on November 1, 2000.
This violation is associated with a WHITE Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, North Atlantic Energy Service Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for the violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or its significance, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public NRC Library). If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.
Dated this 29th day of June 2001