ML20058L246

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Responds to NRC Re Violation Noted in Insp Rept 50-309/93-17.Corrective Actions:Two Electricians Counselled Immediately on Procedure Adherence & Discussions Held W/ Affected Contractor Mgt on 10CFR Requirements
ML20058L246
Person / Time
Site: Maine Yankee
Issue date: 12/09/1993
From: Hebert J
Maine Yankee
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JRH-93-254, MN-93-114, NUDOCS 9312160210
Download: ML20058L246 (4)


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EtliIidE EL ECT AICITY SINCE 1972 4.

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  • AUGUSTA, MAINE 04330 + (207) 622-4868 l

December 9, 1993 i

MN-93-114 JRH-93-254 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated November 12, 1993, Motor-0perated Valve Inspection 50-209/93-17

Subject:

Inspection Report 93-17: Response to Notice of Violation, Failure to Follow Procedures Resulted in Damage to the Safety-Related Motor-Operated Valve HSI-M-42 Gentlemen:

The attachment to this letter responds to the Notice of Violation contained in.

Reference (b). In the attachment to this letter, we have restated the violation and-provided our response.

We have addressed o" actions taken and those planned to prevent recurrence.

Please contact us should you have any questions regarding this matter.

Very truly yours, 140012 NO dJames R. Hebert, Manager Licensing & Engineering Support Department JVW/ jag c:

Mr. Thomas T. Martin Mr

.l. T. Yerokun Mr. E. H. Trottier Mr. Patrick J. Dostie i

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a Notice of Violation:

Our'ing an NRC inspection conducted on September 17-21, 1993, a violation of NRC -

requirements was identified. 'In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C (1993), the violation is stated below:

Technical Specification 5.8.2 states, " Written procedures shall be established, implemented and maintained covering the activities referenced below":

The applicable procedures recommended in Appendix "A" of Regulatory Guide a.

1.33 (Rev. 2), February, 1978."

Regulatory Guide 1.33, Appendix A, Step 9.8 states, in part, " General procedures for the control of -maintained, repair...should be prepared before reactor operation is begun."

Maine Yankee Procedure 5-18-5, Rev. 7, "Limitorque Operator Overhaul (SMB-0 through SMB-4)." Step 5.15.7.9 requires that the torque switch setting be at "I and 1" prior to reinstalling the torque switch in the actuatcr.

Contrary to the above, on September 21, 1993, maintenance contract electricians did not reset the torque switch to "I and 1" prior to installation, resulting in damage to HSI-M-42 "B" train HPSI header stop, a safety-related valve in the safety in.iection system.

Maine Yankee Response:

As described in NRC Inspection Report No. 50-309/93-17 motor operator valve HI-M-42 "B" Train HPSI header stop valve was damaged following an overhaul of the motor operator.

This occurred while the plant was in a refueling mode and HPSI was not required to be operational. The problem was immediately detected and resolution completed prior to plant startup and HPSI required to be operational.

The operator overhaul was to be performed in accordance with Maine Yankee Procedure 5-18-5, "Limitorque Operator Overhaul (S0B-0 through SOB-4)".

Investigation performed by Maine Yankee revealed that Step 5.15.7.a of Procedure 5-18-5 was not performed as written. Work was being performed by two contract electricians working under the direction of Maine Yankee Maintenance supervision. Step 5.15.7.a required the electricians to reset the torque switch to settings of "I and 1" for both the open and closed direction.

The electricians installed the torque switch into the operator, leaving the settings in their as-found condition.

This action of installing the torque switch in the as-found condition caused the torque switch to 3

become reloaded and thus allowed the operator to overthrust the valve, causing the actuator adapter plate bolts to strip and bend the valve stem.

Maine Yankee has determined the root cause to be failure to follow the procedure.

This was an error in performance on the part of the two contract electricians.

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Immediate Corrective Actions:

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The following immediate corrective actions were taken:

Immediate counseling of the two electricians on procedure adherence.

Reviewed the Maintenance Expectations Document that both electricians had reviewed and signed, and re-emphasized their individual responsibility to follow procedures.

Both electricians received disciplinary action.

Special meetings were held with Maine Yankee electricians and all Maintenance contractors to discuss work order and procedure adherence responsibilities and consequences if not followed, Special focus provided on 10CFR Part 2, App. C.,

relative to " willful violations", 10CFR Part 50, Section 50.5, Deliberate Misconduct, and Section 50.9, Completeness and Accuracy of Information.

Corrective Actions Taken to Avoid Further Violation:

To avoid further violations, the following long-term corrective actions were or will be taken:

Discussions were held with the affected contractor management on 10CFR requirements and implications if not followed.

The contractor management has been issued a letter to disallow payment for work resulting from the damage by this incident.

A meeting was held between Maine Yankee Management and the Maine Building Trades Business Agents with cor. tractor Management to discuss the individual workers responsibility of following procedures and 10CFR requirements and implications as noted above in immediate corrective actions.

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Maintenance Management is working jointly with craft personnel to modify its work order / procedure expectations document, to ensure that all workers clearly understand the requirements of procedure adherence and potential for disciplinary action for non-adherence.

We plan to revise the document by 01/31/94.

Contractor training will be revised to include information on 10CFR requirements and Maine Yankee expectations of workers prior to the next refueling outage, currently scheduled for March,1995.

Maintenance supervision has been cautioned via memo that contractors working under them must adhere to procedures and work orders, and they must periodically remind them of their responsibilities.

Maintenance Department craft personnel will also be advised of the 10CFR requirements and possible consequences to the company and. individuals by 12/31/93.

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,4 Full Compliance Date:

-Fuli compliance was achieved on September 22, 1993, at approximately 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, when the motor operator was completely rebuilt and Procedure 5-18-5, "Limitorque Operator 1

Overhaul (S0B-0 through SOB-4)", was completed satisfactorily.

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