ML20006A770
| ML20006A770 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/15/1990 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GDW-90-24, MN-90-08, MN-90-8, NUDOCS 9001300172 | |
| Download: ML20006A770 (5) | |
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RELIABLE ELECTRICITY FOR MAINE SINCE 1972 EolSON DRIVE. AUGUSTA, MAINE 04330. (207) 622 4868 t.
January 15, 1990-
.l MN-90-08 GDW-90-24 i
i UNITED STATES' NUCLEAR REGULATORY COMMISSION.
-Region I
' '475 Allendele Ruad King ~of Prussia,: Pennsylvania '19406 Mr. William T. Russell, Regional Administrator l
~ Attention:
References:
.(a). License No. DPR-36 (Docket No. 50-309)
L (b) USNRC Letter to Maine Yankee dated December 14, 1989 Inspection Report No. 50-309/89-18 l.
Subject:
Response to Notice of Violation - Inspection Report No. 50-309/89-18,
. Resident. Inspection Including PR-A-2 and TK-109 Activities L
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Gentlemen:-
n The attachment to this letter provides Maine Yankee's response to the Notice L*-
- of-Violation contained in Reference (b).. For completeness, we have restated the l
-violations-with-our responses following. We discussed this matter with members of F
.your staff during a meeting at Region I on January 9, 1990.-
Should you have any questions on this matter, please contact us.
Very truly yours, kh/JY G. D. Whittier,' Manager Nuclear Engineering and Licensing GDW:SJJ
Attachment:
Response to Notice of Violation c:
Mr. Eric J. Leeds fMr.0.Cornelius F. HoldenDoc ment" Control::De,skgg n
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NOTICE OF VIOLATION A 10 CFR 50, Appendix B, Criterion V specifies that activities affecting quality shall be prescribed by and accompTished in accordance with instructions, procedures, or drawings which include appropriate criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the'above, on October 16, 1989, maintenance supervisors assigned f
to replace corroded nuts on Pressurizer Spray Flow Control Valve PR-A-2 did so without verifying accomplishment of important activities, in that they.
undertook the work without equipment safety tags and without appropriate component identification or verification of component isolation. They then-erroneously removed an uncorroded nut from unisolated Pressurizer Spray Flow Control: Valve PR-A-1, degrading but not breaching the primary coolant pressure boundary.
MAINE YANKEE RESPONSE A
-Routine inspection while shutdown identified boron buildup on valve PR-A-2.
A Discrepancy Report (DR) was initiated with a high priority to replace the nuts.
Initial discussions between the Maintenance Section Head and the Plant Shift Superintendent (PSS) resulted in concurrence that isolation was adequate to effect repairs and safety tags would not be utilized.
This decision was considered appropriate, because the valve is located in a high radit. tion _ area and placement of tags would result in additional dose.. Also, the = valve would be-isolated and the packing nuts (2) would be replaced one at a time, always keeping one nut in place to secure the packing follower.
Under these conditions not using safety tags was considered acceptable under 1
Maine _ Yankee's tagging procedures. Subsequent to the above, the PSS reconsidered and ordered PR-A-2 to be tagged out. This decision was not conveyed to the Maintenance Supervisor, p
Maintenance supervisors went to the work site to begin working on PR-A-2.
1 The supervisors did not anticipate er look for valve safety tags assuming none were hung. One nut was replaced and they encountered an obstruction precluding replacement of the second nut. They retreated to confer with the Engineering Department and determined they had worked on the wrong valve.
Corrective action was later conducted on the correct valve by other Maintenance workers. A Human Performance Evaluation System (HPES) review was conducted after this event.
1.
Immediate corrective steps which have been taken and the results achieved:
The gland follower nut was replaced to restore the valve to its original condition.
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1 2.3 Corrective-steps which.will be taken to avoid further violations:
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-A.
The Plant Manager held a plant-wide meeting to describe the incident and its significances and to discuss future corrective:
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action.
B.
A management' directive was issued to suspend all work without the use of safety tags without the approval of worker's supervisor, the on-shift Plant Shift Superintendent, on-shift-Nuclear Safety i
Engineer. and the Industrial' Safety Director.
C.
The two maintenance supervisors who conducted the work received-disciplinary suspensions.
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The White Tagging (Safety) procedurc 0-14-1'will be revised to require tagging for work conducted on an energy source that could.
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-cause injury to personnel or plant equipment.
Exceptions will be 1
specifically listed in the procedure or formal review and approval
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of the cognizant Supervisor, Plant Shift Superintendent, Nuclear.
Safety Engineer and where available, the. Industrial Safety a
' Director.
This. procedure change will be completed by February 8, 1990.
3.
Date when full compliance was achieved:
Full compliance was achieved on October 16, 1989 coincident with restoration of-the gland follower nut.
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NOTICE-0F VIOLATION B 10 CFR 50,' Appendix B, Criterion XVI specjfies 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 t
determiaet and that corrective action is taken to preclude repetition.
Contrary to'the above, corrective action as a result of. the August 21, 1989 overfill of the Resin Storage Tank and subsequent seepage of contaminated water to.the yard area was ineffective at precluding repetition as evidenced by a similar occurrence on October 19, 1989.
MAINE YANKEE RESPONSE B.
Following the August 21, 1989 overfill of the resin storage tank, a Human Performance Evaluation System (HPES) review was performed by the Operations Department.
Recommendations for corrective actions were approved and were in the process.of being implemented. Operations management made a conscious decision to proceed with the October 19, 1989 resin-transfer as the evolution involved removing contents from the tank, and it was believed that an 3
overflow event could not occur.
The transfer proceeded smoothly until the positive displacement pump started to have difficulty moving the resin slurry. The operators introduced primary water into the pump suction and lubricated the pump bearings to keep the pump from binding.
The operator. lubricating the pump was sprayed with grease when the grease gun was disconnected from the grease fitting. The supervisor's attention was drawn to the operator and away from monitoring the tank level.
Primary water was still aligned to the pump suction and the tank overfilled, c
'l.
Immediate corrective steps which have been taken and the results achieved:
Immediate corrective actions taken were to stop the overflow by securing th.e primary water source. Tha spill wu contained and the amount of activity released to the storm arain was calculated as described in the inspection report.
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.1 Corrective steps which will be taken to avoid further violations:
2.
Following this event, all further transfer evolutions were terminated until the following short-term correstive actions are completed:
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a.
Implementation of policy changes to require a supervisor be assigned to resin transfer operations, and to require such transfers be planned and scheduled.
i b.
Departmental procedure changes resulting from the review of the j
October 19 overfill.
c.
Repair inoperable indicating lights in the resin transfer system.
The majority of short-term ' actions have been completed ar,d resumption of resin transfers from TK-109 is anticipated prior to the end of January of 1990.
Long-term actions are under evaluation and actions to be taken remain to be scheduled.
The long-term actions include human factor type
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improvements and technical improvements to the installed systems designed to enhance reliability and operability. The Plant Manager will brief the NRC Resident inspector of plans for resolution of the long-term corrective actions.
3.
Date when full compliance was achieved:
Full compliance was achieved on October 20, 1989, with the cleanup of the spill and the cessation of resin transfer operations.
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