ML20059D036
| ML20059D036 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/25/1993 |
| From: | Hampton J DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9311020110 | |
| Download: ML20059D036 (5) | |
Text
1 I
'*~
DaePtwrCompany
' J. W. liwlta Oconee NuclearSte Vice IVesident P.O hu M19
. (803)%3499 OITxe t
Seneca SC2%i9 (803)M3%4 Fax ~
l DUKEPOWER October 25, 1993 U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Subject:
Oconee Nuclear Site Docket Nos. 50-269, -270, -287 Inspection Report 50-269, -270, -287/93-23 Reply to Notice of Violation
Dear Sir:
By letter dated September 24, 1993 the NRC issued & Notice of Violation as described in Inspection Report No. 50-269/93-23, 50-270/93-23, and 50-287/93-23.
Pursuant to the provision of 10 CFR 2.201, I am submitting a written response to the violation identified in the above Inspection Report.
Very truly yours,
'J.
W.
Ha ipton V
cc:
Mr.
S.
D.
Ebneter, Regional Administrator U.
S.
Nuclear Regulatory Commission, Region II
]
i Mr.
L. A.
Wiens, Project Manager Office of Nuclear Reactor Regulation Mr.
P.-E.
Harmon i
Senior Resident Inspector i
Oconee Nuclear Site j
010093 i
P(g]h -
9311020110 931025-f PDR ADOCK 05000269 d
)V.I
~
J
. a eDR vi
Violation 269,270/93-23-01, Severity Level IV
-r
~
Technical Specification 6.4.1.e requires, in part, that the station-shall be operated and maintained in accordance with approved i
procedures. Written procedure with appropriate check-of f lists and instructions shall be provided for preventive or corrective maintenance which could af fect nuclear safety or radiation exposure to personnel.
f Duke Power Company Procedure IP/0/A/3011/013, Change 2,
" Molded Case Circuit Breaker Test and Inspection", requires in Step 10.3 that circuit breaker line and load side cables be marked and I
disconnected for breaker testing.
The procedure requires in Step 10.21 that the cables be connected to the breaker as marked.
Duke Power Company Procedure IP/0/B/0325/003, Change 15, "ICS FWPT Speed Control Calibration", requires in enclosure 11.3.9 that a Bailey Meter Co.
Type 6620255-9 proportional plus integral controller be installed for the Feedwater Valve Differential Pressure Error Controller.
Contrary to the above, these regairements were not met in that:
1.
On May 18, 1993, cables to the circuit breaker in DC motor l
control center 2DCA compartment 3A were improperly connected i
during the performance of IP/0/A/3011/013.
2.
On December 28, 1992, work request 51316L installed a Bailey Meter Co.
type 6620255-10 proportional plus integral controller with limiter for the Feedwater Valve Differential e
Pressure Error Controller on Oconee Unit 1.
i t
RESPONSE TO EXAMPLE A:
l 1.
The reason for the violation, or if contested, the basis for disputing the violation Duke Power Company agrees with the violation, but disagrees with the determination of the cause of.the violation.
Duke j
Power feels the cause of the violation was a failure of the I&E technicians to maintain positive configuration control.-
Maintenance Directive 4.4.13, ONS I&E Configuration Control Work Practices, section 5.5.2 requires that the l
technician should attempt to mark leads :in such a way that, if-necessary, another technician could reconnect the leads using l'
the lead markings".
Contrary to this requirement - the technicians failed to adequately or accurately mark the leads so that they could be relanded correctly.
NRC Inspection Reoort 93-23 states that Ma'intenance Directive 4.4.13 step 5.3.1 requires that a " Component Out of. = Normal sheet" be completed when station I&E equipment is placed 'in an out of normal state.
The report further states that the "Out of Normal Sheet" was not utilized to control the configuration i
i 1
4
+
of the circuit breaker power cables.
Duke Power disagrees with this determination because Maintenance Directive 4.4.13
,step 5.3.1 further states that a " Component Out of Normal Sheet shall be completed when station I&E equipment is placed in an out of normal state and such placement is not documented in a procedure."
The procedure that the technicians were i
using, IP/0/A/3011/013, documented the placing of the leads in an out of normal state.
IP/0/A/3011/013 step 10.3 states
" Mark and disconnect cables on both ' Load' side and 'Line' side of breaker as applicable".
Since the procedure documented this out of normal state, it was not required to document the circuit breaker power cables on an "Out of Normal Sheet".
As a separate portion of implementing this procedure, the technicians properly documented the disconnection of the shunt trip wiring leads on an "Out of Normal Sheet" as required by Maintenance Directive 4.4.13, since this was not documented in the procedure.
2.
The corrective steps that have been taken and the results achieved:
Duke Power Company's Significant Event Investigation Team was initiated.
i The reversed leads were corrected in the 1ADA input breaker circuit #2 breaker.
1ADB, 1ADC and 1 ADD were inspected for correct polarity.
No problems were found.
l 3.
The corrective steps that will be taken to avoid further violations-7 a)
Maintenance Directive 4.4.13 will be r' vised to provide l
more specific guidelines for marking J eads and associated termination points.
Affected I&E personnel will receive training on these guidelines.
b)
Procedure IP/0/A/3011/13, Moldad Case Circuit Breaker Test and Inspection, will be revised to improve post maintenance testing.
c)
I&E, In conjunction with other groups, will investigate possible enhancements to the Post Maintenance Testing
)
(PMT) program.
These enhancements will focus on'the implementation process of the PMT program.
r t
Items a) and b) will be completed by December 15, 1993.
Item l
c) will be completed by June-30, 1994.
4.
The date when full compliance will be achieved:
l Duke Power Company is in full compliance.
4
'}
A
.n
I
-i i
?
?
RF.SPONSE TO EXAMPLE B:
i 1..
T'he reason for the violation, or if contested, the basis for disputing the violation:
. The cause of the improper module replacement was determined to be a management deficiency, lack of procedure.
There'was no procedure that specifically directed the actions necessary for the replacement of the ICS modules.
The existing procedure did not give adequate guidance to check fully the module throughout its range ensuring the lack of or the existence of an output limiter card.
3 In addition, modules of both types (with and without output limiter cards) were maintained under one Duke inventory control number.
Some modules had been modified (output-limiter cards removed) and returned to storage-without any identifying codes, tags or numbers.
2.
The corrective steps that have been taken and the results achieved:
Duke Power Company's Significant Event Investigation Team was initiated.
A work order was issued to investigate the problem with the i
feedwater-pump control circuitry on Unit 1.
An inappropriate j
output limiter card was found and removed; the module was functionally tested satisfactorily.
Work orders were issued to check Units.2 and 3 for the output Limiter card.
r A review was conducted of Integrated Control System (ICS) and Non-Nuclear Instrumentation modules to verify that output limiter cards did not exist in those modules specifically requiring no output limiter card.
Procedure IP/0/B/325/03, ICS FDW PT Speed Contro.i Calibration, was revised to test the Bailey ICS modules in st,..h a manner to l
ensure that an output limiter card does: not exist unless specified by procedure.
3.
The -corrective : steps that will be taken to avoid further violations:
a)
I&E will develop a' generic training and qualification
+
guide for the ICS to include training on the different module part numbers and their associated component-functions.
This will be completed by December 15, 1993.
I l
3 i
b)
Commodities and Facilities, with assistance from I&E, will develop a system to identify Bailey ICS modules in l
stock that have the same part number.
Once identified, each Bailey ICS module with a unique manufacturer part number will be assigned an individual MMIS number.
This will be completed by February 19, 1994.
i c)
As noted in the response to Example A, the implementation process of the Post Maintenance Testing (PMT) program will be reviewed for possible enhancements.
4.
The date when full compliance will be achieved:
Duke Power Company is in full compliance, i
l
.i 4