EA-98-073 - Seabrook 1 (North Atlantic Energy Service Corp.)

April 1, 1998

EA 98-073

Mr. Ted C. Feigenbaum
Executive Vice President and Chief Nuclear Officer
Seabrook Station
North Atlantic Energy Service Corporation
c/o Mr. Terry L. Harpster
Post Office Box 300
Seabrook, New Hampshire 03874

SUBJECT:

NOTICE OF VIOLATION (NRC Inspection Report No. 50-443/97-08)

Dear Mr. Feigenbaum:

This letter refers to the NRC inspection conducted between December 7, 1997, and January 31, 1998, at the Seabrook station, the results of which were discussed with you during an exit meeting on February 12, 1998. During the inspection, apparent violations of NRC requirements were identified, as noted in the inspection report sent to you with our letter, dated February 27, 1998. On March 24, 1998, a Predecisional Enforcement Conference (conference) was conducted with you and members of your staff to discuss the related violations, their causes, and your corrective actions.

Based on the information developed during the inspection, and the information provided during the conference, three violations of NRC requirements are being cited and are set forth in the enclosed Notice of Violation (Notice). All three violations involve the failure to promptly identify and/or correct conditions adverse to quality at the facility. Collectively, these violations represent a significant lack of attention toward licensed responsibilities since opportunities existed, in each case, to correct these adverse conditions sooner; yet appropriate actions were not taken. At the enforcement conference, you acknowledged these concerns, noting that a complacent attitude may have contributed to these failures. You also recognized the need for greater operational focus, and more aggressive follow up, by staff at the station.

In one case, in November 1996, your staff identified potential leakage (in the form of boric acid residue external to the fire protection pipe wrap material) from stainless steel piping in the vicinity of the "B" Residual Heat Removal pump suction relief valve (RC-V-89). However, this condition was not promptly corrected, despite opportunities to do so. Specifically, the pipe wrap material was not removed until December 5, 1997 to identify the source of the residue, even though several individuals, including engineers, supervisors, and maintenance and health physics technicians, had been aware of this condition. In addition, while your staff had made plans to remove insulation and inspect this section of piping during the June 1997 refueling outage, this work activity did not occur. Although a system engineer recognized that the piping had not been inspected, on or about June 15, 1997, and informed his supervisor, no adverse condition report was generated, and actions were not taken to remove the insulation and inspect the pipe prior to the start-up on June 26, 1997.

In another case, the control building air conditioning (CBA) compressors, used to cool critical instruments within the control room following a postulated accident, were degraded resulting in multiple compressor failures since 1993, including some instances when both subsystems were inoperable at the same time. However, action was not taken until December 1997 to address the root causes for the compressor failures, despite prior opportunities to address this problem. Specifically, your staff completed an engineering evaluation in 1994 (to address a 1993 CBA compressor failure), and that evaluation resulted in development of a design change request to correct the root causes for the compressor failure. Those causes included: loss of bearing lubrication caused by refrigerant contamination of the lubricating oil; and/or refrigerant slugging to the cylinder piston assembly. Although the modification was scheduled to be implemented in the third quarter of 1996, it was delayed several times and not implemented until after another CBA compressor failure on December 16, 1997. In each of the prior cases when the compressors failed, your corrective actions focused on component replacement rather than correcting the root causes of the failures.

In the third case, in November 1997, the NRC observed that a caution tag on the control switch for the Positive Displacement Charging Pump indicated that the pump could trip after starting due to an oil leak from the pump's sensing line. Although this leak challenged the reliability of the pump, a component important to safety, your plans did not include repair of the leak until after installation of a modification to relocate the pressure switch. However, in October 1997, the plans for the modification were canceled without resolving this adverse condition.

Failure to correct these conditions sooner indicates a decline in your performance with respect to analysis of root causes of problems, as well as implementation of appropriate corrective action. This concern was previously highlighted in my January 23, 1998, letter transmitting the latest SALP report to you. In that report, the NRC noted that operators and engineering personnel did not aggressively pursue resolution of degraded conditions on equipment important to safety. Given the number of examples of this problem, despite opportunities to correct the conditions, the violations represent a significant regulatory concern. Therefore, these violations have been classified in the aggregate as a Severity Level III problem in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem. Your facility has not been the subject of escalated enforcement actions within the last 2 years. Therefore, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty. Credit is warranted for corrective action because, at the time of the enforcement conference, the actions taken to improve the corrective action process were considered prompt and comprehensive. Your corrective actions included, but were not limited to:(1) creation of a multi-disciplined team to look for problems at the facility; (2) retention of a contractor to address the broader issues of improved root cause analysis and corrective actions; (3) conduct of meetings with all employees to communicate management expectations regarding these issues and the need for improved operational focus; (4) addition of an engineer to each shift to assist with ensuring appropriate configuration control; (5) retraining of staff; (6) lowering of the threshold for classifying equipment as degraded.

Therefore, in view of these corrective actions, I have been authorized, after consultation with the Director, Office of Enforcement, to not propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

In addition to these three violations, the inspection report identified another apparent violation related to your opening of the safety injection test header return isolation valve SI-V-131 (between August 6 and 8, 1997, and between October 21, 1997 and December 6, 1997) for the purpose of redirecting reactor coolant isolation check valve leakage to the primary drain tank to prevent the undesired boron dilution of the SI accumulators. The NRC previously issued to you a Notice of Violation on September 23, 1997, for deviation from procedural requirements, without proper approval as required by the technical specifications. Since your subsequent analysis indicated that this action did not render the 'A' Safety Injection pump inoperable, no further violation is being cited.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. 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 placed in the NRC Public Document Room (PDR).

Sincerely, ORIGINAL SIGNED BY WILLIAM L. AXELSON FOR Hubert J. Miller Regional Administrator

Docket No. 50-443
License No. NPF-86

Enclosure: Notice of Violation

cc w/encl:
B. Kenyon, President - Nuclear Group
J. Streeter, Recovery Officer - Nuclear Oversight
W. DiProfio, Station Director - Seabrook Station
R. Hickok, Nuclear Training Manager - Seabrook Station
D. Carriere, Director, Production Services
L. Cuoco, Senior Nuclear 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 General Counsel - Great Bay Power Corporation
R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts
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

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NOTICE OF VIOLATION

North Atlantic Energy Service Corporation Seabrook Station

Docket No. 50-443 License No. NPF-86 EA 98-073

During an NRC inspection conducted between December 7, 1997, and January 31, 1998, for which an exit meeting was held on February 12, 1998, three violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies , deviations, defective material and equipment, and nonconformances 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 preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Contrary to the above, measures were not established to assure that significant conditions adverse to quality were promptly identified and corrected, and the causes of the conditions were determined and corrective action taken to preclude repetition. Specifically,

1. Between November 1996 and December 5, 1997, a condition adverse to quality existed involving leakage from stainless steel pipe in the vicinity of the "B" Residual Heat Removal pump suction relief valve (RC-V-89), and this condition adverse to quality was not identified until December 5, 1997, despite prior opportunities to do so. Specifically,

a. In November 1996, the licensee had been aware of the existence of boric acid residue external to pipe wrap material on the piping. However, the licensee did not remove the pipe wrap material to positively identify the source of this residue until December 5, 1997 even though engineers, supervisors, and maintenance and health physics technicians had been aware of this condition.

b. During the June 1997 refueling outage, the licensee planned to remove the pipe wrap material and inspect this section of piping. Although a system engineer determined, on or about June 15, 1997, that this work activity did not occur and informed his supervisor, an adverse condition report was not generated, and actions were not taken to remove the insulation and inspect the pipe prior to the start-up on June 26, 1997. (01013)

2. Since 1993, a condition adverse to quality existed involving degradation of the control building air conditioning (CBA) compressors, used to cool critical instruments within the control room for up to thirty days following a postulated accident, which resulted in multiple compressor failures. Corrective action was not taken until December 1997 to address the root causes for this condition, even though prior opportunities existed to address this problem. Specifically, the licensee's staff completed an engineering evaluation in 1994 (to address a 1993 CBA compressor failure), and that evaluation resulted in development of a design change request to correct the root cause(s) for the compressor failure. Those causes included: loss of bearing lubrication caused by refrigerant contamination of the lubricating oil; and/or refrigerant slugging to the cylinder piston assembly. Although the modification was scheduled to be implemented in the third quarter of 1996, it was delayed several times and not implemented until after another CBA compressor failed on December 16, 1997. In each of the prior cases when the compressors failed, the licensee's corrective actions focused on component replacement rather than correcting the root causes of the failures. (02013)

3. In November 1997, the NRC observed that a caution tag on a pressure switch for the Positive Displacement Charging Pump indicated that the pump could trip off from starting due to an oil leak from the pump's sensing line. Although this leak challenged the reliability of the pump, a component important to safety, the licensee's plans did not include repair of the leak until after installation of a modification to relocate the pressure switch. However, in October 1997, the plans for the modification were canceled without resolving this adverse condition. (03013)

These violations represent a Severity Level III problem (Supplement I).

Pursuant to 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, D.C. 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 each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (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 Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other actions as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. 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.

Dated at King of Prussia, Pennsylvania
this 1st day of April 1998