ML17056C023
| ML17056C023 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/22/1992 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 9209290047 | |
| Download: ML17056C023 (12) | |
See also: IR 05000220/1992082
Text
Docket No.
50-220
Mr. B. Ralph Sylvia
Executive Vice President - Nuclear
Niagara Mohawk Power Corporation
301 Plainfield Road
Syracuse, New York 13212
Dear Mr. Sylvia:
Subject:
Inspection Report No. 50-220/92-82
This refers to your letter dated August 19, 1992, in response to our letter dated July 30, 1992.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions willbe examined during a future inspection of your licensed program.
r
Your cooperation with us is appreciated.
Sincerely,
Jacque P. Durr, Chief
Engineering Branch
Division of Reactor Safety
9209290047
'720922
ADOCK 05000220
B. Ralph Sylvia
cc w/encl:
J. Firlit, Vice President - Nuclear Support
C. Terry, Vice President - Nuclear Engineering
J. Perry, Vice President - Quality Assurance
Vice President - Nuclear Generation
K. Dahlberg, Unit I Plant Manager
M. McCormick, Unit 2 Plant Manager
D. Greene, Manager, Licensing
J. Warden, New York Consumer Protection Branch
G. Wilson, Senior Attorney
M. Wetterhahn, Winston and Strawn
Director, Power Division, Department of Public Service, State of New York
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
K. Abraham, PAO (30) SALP Reports and (2) AllInspection Reports
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New York, SLO Designee
bcc w/encl:
Region I Docket Room (with concurrences)
C. Cowgill, DRP
J. Yerokun, DRP
L. Nicholson, DRP
S. Greenlee, DRP
W. Schmidt, SRI - Nine Mile
R. Lobel, OEDO
R. Capra, NRR
J. Menning, NRR
D. Brinkman, NRR
DRS/EB SALP Coordinator
D. Holody, EO
RI:DRS
Trapp
Qf
08/3l/92
RI:DRS
Durr
p9fk,
OFFICIALRECORD COPY
= A:RL9282
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h Sylvia
7 NIAGARA
U MOHAWK
NIAGARAMOHAWKPOWER CORPORATtON/NINE MILEPOINT. P.O. BOX63, LYCOMING.NY 13093/TELEPHONE (315) 349.2882
Executive Vice President
Nuclear
August 19, 1992
NlVIP87236
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
RE:
Nine Mile Point Unit 1
Docket No. 50-220
DPR-
Gentlemen:
SUBJECT:
"REPLY TO A NOTICE OF VIOLATION,"AS CONTAINEDINNRC
COMBINED INSPECTION REPORT NOS. 50-220/92-82 AND 50-410/92-82
Attached is Niagara Mohawk Power Corporation's response to the Notice of Violation
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contained in the subject Inspection Report dated July 20, 1992.
We believe that the
corrective actions described in this response
have appropriately addressed
the cause of
this violation and will prevent recurrence.
If you have any questions concerning this
matter, please contact me.
Very truly yours,
B. Ralph Sylvia
Exec. Vice'President - Nuclear
BRS/AZP/Imc
Attachment
XC:
Mr. T. T. Martin, Regional Administrator, Region
I
Mr. W. L. Schmidt, Senior Resident Inspector
Mr. R. A. Capra, Director, NRR
Mr. D. S. Brinkman, Senior Project Manager, NRR
Mr. L. E. Nicholson, Chief, Reactor Projects, Section 1B
Records Management
NIAGARAMOHAWKPOWER CORPORATION
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NINE MILE POINT UNIT 1
DOCKET NO.60-220
"REPLY TO A NOTICE OF VIOLATION,"AS CONTAINED IN
INSPECTION REPORT 50-220/92-82 AND 60-410/92-82
VI LATI N
0-22
2- 2-
1
As a result of an inspection conducted on June 22 - 26, 1992, and in accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2,
Appendix C (Enforcement Policy), the following violation was identified:
Technical Specifications, Section 6.8.1, states
in part that "written procedures
and administrative policies shall be established,
implemented and maintained
that meet or exceed the requirements and recommendations
of Section 5.1 and
5.3 of ANSI N18.7-1972 and Appendix A of USAEC Regulatory Guide 1.33..."
ANSI 18.7-1972, Section 5.3.1, states
in part that "each procedure shall be
sufficiently detailed for a qualified individual to perform the required function
without direct supervision..."
Contrary to the above, on June 24, 1992, it was determined that preventive
maintenance
procedures N1-EMP-GEN-R120 (ac valves) and N1-EMP-GEN-R121
(dc valves) did not provide sufficient detail for a qualified individual to perform
steps 7.5.3., which verified MOV torque switch dial settings.
1.
REASON FOR THE VIOLATION
Niagara Mohawk admits to the violation as written in Inspection Report, 92-82.
A root cause
evaluation was performed which attributed the violation to personnel errors.
These errors
resulted in less than adequate control of Motor Operated Valve (MOV) torque switch dial
settings at Unit 1. The errors identified are as follows:
(2)
Procedures for controlling MOV torque switch dial settings provided insufficient
direction as to the specific information to be recorded by the craftsmen.
Further, the procedures did not adequately identify where the correct torque
switch dial settings are found on the controlling document.
Prior to the event, Preventive Maintenance Procedures
N1-EMP-GEN-R120 and
R121 were revised to require recording actual torque switch dial settings.
Previously, the requirement was to record recommended
and maximum torque
switch settings from the MOV label.
This change was not effectively
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communicated to the craftsmen and their supervisors, nor was training effective
in relating the procedural step change.
(3)
Training did not emphasize the importance of maintaining torque switch dial
settings consistent with controlled engineering drawings.
Further the
significance of maintaining torque switch dial settings was confused by previous
testing to obtain thrust values utilizing the Motor Operated Valve Analysis Test
System (MOVATS).
2.
HE
RE T
E
T A
HAVEBEEN
KENAND HE
E
LT
IEV D
A Deviation Event Report (DER) was initiated as soon as the violation was identified during
the inspection on June 24, 1992.
As part of the DER process
a Root Cause Analysis was
performed.
Concurrent with the Root Cause Analysis, these immediate corrective actions
were initiated:
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An immediate Procedure Change Evaluation (PCE) was issued to clarify and improve
the level of detail in Maintenance Procedures
N1-EMP-GEN-R120 and R121.
An engineering review and maintenance field walkdown of valves in the Generic Letter 89-10 program were initiated, which verified the valves to be operable.
All affected craftsmen and their supervisors were re-trained within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The
training stressed
the significance of maintaining the correct torque switch dial settings,
the procedure inadequacies,
and how the procedure had been changed.
This training
also stressed
the correct control document for torque switch settings is drawing
¹E21.6 F-42124-C.
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THE
ORRE
TIVE
TEP
HAT WILL BE TAKEN T AV ID
F RTHER VI LATI N
The Electrical Maintenance Procedures N1-EMP-GEN-R120 and R121, which were the
primary cause of this violation, have been revised.
The root cause analysis identified an ambiguity in step 7.5.3 of the above p'rocedures,
in that the control drawing referenced (¹E21.6 F-42124-C) states
"RECOMMENDED
TORQUE SWITCH SETl INGS." This statement caused confusion among the craftsmen
when performing the procedure, (it was not clear to them what the torque switch
requirements were).
Therefore, a revision to drawing ¹E21.6 F-42124-C will be issued
to clarify the ambiguity. This will assure configuration control of torque switch dial
settings by clearly stating on the drawing what the correct settings are when
performing step 7.5.3.
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As a final step to prevent recurrence, training lesson plans will'be revised to address
the basis and methods of torque switch dial settings and the importance of maintaining
torque switch dial settings.
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4.
THE DATE WHEN F LL
MPLIAN E WA
A HIEVED
Full compliance was achieved on July 16, 1992 with completion of the following actions:
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Issuing PCEs 423694 and 423693 to Maintenance Procedures
N1-EMP-GEN-R120 and
R121 on June 26, 1992.
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On July 16, 1992, prior to startup of the unit, all discrepancies
identified by
walkdowns or reviews were resolved and all valves in the GL 89-10 Program Plan were
determined to be operable.
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