ML20059N162
| ML20059N162 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/28/1990 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010100179 | |
| Download: ML20059N162 (6) | |
Text
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Duke Ibust Compa:y '
ilu 8 hw l'O Bar33198 Yke President Charlotte, NC 28242 Nucirar 1% duction
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(704)373 4531 DUKE POWER.
September 28, 1990 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.
20555 l
Subject:
McGuire Nuclear Station
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Docket Nos. 50-369, 370 Inspection Report Nos. 369, 370/90-14 Reply to a Notice of Violation Gentletacn t in my letter of September 18, 1990, " Notice of Delay, Reply to a Notice of, Violation" I informed you that Duke Power would provide a response to the subject violation by. September 28, 1990.
Pursuant to 10CFR2.201, please find attached Duke Power Company's response to Violation 369/90-14-01 and 369/90-14-02 for the McGuire Nuclear Station.
Sho'uld there be any questions concerning this matter, contact W. T. Byers at (704) 373 0194.
Very *.ruly yours, b
me llal B. Tucker WTB/241/lcs xc:
Mr. S. D. Ebneter-Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Tim Reed U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation-Mail Stop 9H3 Washington, D.C.
20555 Mr. P. K. VanDoorn
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eo NRC Resident Inspector McGuire Nuclear Station
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9010100179-900P'8' PDR ADOCK'050.'ac -
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No0UIRE FJCLEAR STATION 3
RESPONSE TO VIOLATION I
Violation 369/370/90-14
. Technical specification (Ts) 6.8.1.a requires written procedures to be established, implemented, and maintained covering the 4
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.-
i Appendix A of Regulatory. Guide 1.33 requires in pcrt that appropriate procedures be implemented for performing maintenance on safety-related equipment.
Contrary to the above, on June 21-25, 1990, maintenance procedures for safety-related epulpment were inadequate regarding the control of Emergency Diesel Generator painting ac.ivities in 1
that inadequate instructions were provided concerning what areas on the diesels were not to be painted.
As a result of the inadequacies, paint applied to the fuel racks prevented proper functioning of the linkage and. injector pump plungers.
This resulted in both Unit 1 Emergency Diesel Generators being unable to meet the fill loading requirements of Technical Specifications.
This is a Severity Level III violation (Supplement I).
Response
1.
The reaton for the violation, or if contested, the basis for disputing tne violation:
The event was due to inadequate work control and group interface.
Maintenance (MNT) personnel involved in painting the diesel generators (D/0) did not receive adequate guidance from either Operations-(OPS) personnel who controlled.the D/G or MNT personnel with expert knowledge of the D/0 when painting the engines.
Addit 3onally, the MNT personnel painting the D/G decided among themselves to paint the fuel racks on Unit 1 because the fuel racks were scratched.
The 141nters believed' that they were doing the right thing to do a good job.
2.
The corrective steps taken and results achieved (1)
MNT personnel removed raint from the connections to D/G Governor 1A and 1B.
(2)
OPS personnel completed PT/1/A/4350/02A, D/G 1,'.
Operability Test and PT/1/A/4350/02B, D/0 1B Operability Test.
Page 1
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OPS personnel declared D/G la and 1B operable.
3.
The corrective steps which will be taken to avoid further violations:
(1)
It will be reemphe. sized that NNT paint,.nsulating I
craft and Construction and Maintenance-North personnel.
will be required to notify the appropriate operational-control group personnel of paint activities within the station'for approval prior to performing the work.-
(2)
A contact person or persons with expert knowledge of-the specific equipment involved will be designated'on c11 work requests requiring painting of equipment that could adversely affect plant safety.
(3)
A Functional verification of equipment operability will:
be required to ensure proper condition of equipment that could adversely affect' plant safety, t
(4)
Tasks for painting of major components wi1 separated to that painting will not be 'pe:
on major. components from both safety-related same time.
at the 3
(5)
Appropriate changes will be made to the McGuire Maintenance Management Marual specifying the process to i
control paint tasks.
(6)
All affected MNT personnel will be trained on specifics of the process to initiate paint tasks through existing Employee Training Qualification System programs.
(7)
This event will be covered with all appropriate Ops, MNT and Planning personnel.
4.
The date when full compliance will be achieved:
I McGuire will be in full compliance 1/1/1991.
g violation 369/370/90-14 Technical specification (TS) 6.8.1.a requires. written procedure to be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory luide 1.33, requires'in part that administrative procedures be implemented for log entries.
station Directive 2.8.2, operability Determination, paragraph 5.1.3, requires components which fail to meet quantitative acceptance criteria of TSs be considered clearly inoperable upon Page 2 i
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initial discovery and that the start of a TS Action Statement begins at the point 3 decision is reached on operability.
i operations Management Procedure 2-5, Technical Specifications Action Item Logbook, paragraph 6.5, requires that all entries should be made in chronological order at the time of occurrence or when knowledge of the occurrence is first obtained.
contrary to the'above, on June 26, 1990,.
diesel generator 1A inoperable upon failure of the dieselthe Licensee loggad' generator.to meet quantitative faceptance criteria approximately 40 minutes after the occurrence and logged diesel generator 1B inoperable approximately 24 minutes after knowledge of an inoperable condition.
This is'a severity Level IV violation (Supplement 1).
Response
4 r
1.-
. The reason for the violation, or if contested', the' basis for 3
disputing the violation i
l The reasons for the violation will be reported for each EDG,-
1A and 1B, with a clarification to the violation for the IB EDG.
(1)
When the 1A EDO failed to attain the required voltage in f 11 seconds at $':05 AM, the affected SRO unit supervisor (US) was dispatched to the scene.
The US in conjunction with an Icetrument and' Electrical group (IAE) supervisor and the operations SRO unit manager 7
(UM) conducted an investigation to determine the' reason 4
for the deficient voltage.
The SRO shift supervisor (SS) remained in the control room and received periodic updates from the US on the scene.
At 10:00 AM the Ss declared the 1A EDG inoperable after he felt-the event was sufficiently examined by the US and the IAE supervisor.
This was in error as the 1A EDG should have been declared inoperable at ' 9:20 AM when it was identified that acceptance criteria for a successful start was not met and paint overspray was identified as a potential major contributor to the event.
During the ongoing investigation prior to declaring the 1A EDG inoperable at 10: 00 AM the 125 thought that the SS had previously declared the EDG inoperable.
AoftheIBE UM recommended.an axamination
' fue ks.
Evaluation of the 1A EDG had revealed that Paint overspray on the fuel racks was still suspect to the slow start, but it was believ*d that a mechanical problem in a single fuel 4
injector was the probicm for the 1A EDG fai At 11:10 AM, paint was noted on the fuel pump rack and connections to the 1B EDG governor.
Operatiet.s L
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' felt that the 1B EDG was not in its normal material l
condition, and being that the paint everspray was suspect on the 1A EDG, it was decided to return the 1B EDG to its original condition. -The intent of the i
removal of the 1B EDG from service was to be conservative.
Instead of going'through a longer process of testing the 1BLEDG and cleaning if necossary, it'was decided to tag the 18 EDG out of service ~through our normal Memoval and Restoration procedure.
After tagging the 1B EDG, it would be cleaned and ratestad before declaring. operable.
The.
repair of the 1A EDG-fuel injector was estimated to i
take 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The cleaning of the 1B EDG was estimated r
to take two hours to remove the paint overspray.
Since F
1A EDO was still-capable of. lo::4ing to ~ 3500 KW, the decision was made to clean the 1B EDG and return it to its original ~ condition.then tag out the 1A EDG and-repair its fuel pump an,d clean off any remaining paint.
At 11:34 AM, the control power breaker for the 1B EDG J
4 was opened and this EDG wke logged inoperable in accordance with our Removal and Res*, oration procedure.
Our intent was to. be conservative when taking the 1B 4
EDG out of service for cleaning of the fuel racks.
In hindsight, the'lB EDG should have been declared i
inoperable at 11:10 AM When the-decision war made to clean this EDO.
2.
1me corrective steps taken and the results achieved:
This event was discus _ sed with an SRO staff representative from each operations section during a staff meeting hold on 7/18/90.
McGuire Station Directive 2.8.2 (Operability Determination) was referenced and personnel were cautioned to make operability determinations in a timely manner.
This event was discussed with an SRO representative from each shift crew during the 9/14/90 shift supervisor meeting conducted on a monthly basis by operation. management.
The SRos were directed to refer to McGuire Station Directive 2.8.2 (Operability Determination) when operability issues arise.
Specifically, paragraph 5.1.3 was referenced and it reads:
"a system, subsystem, train, compenent,,or device fails to meet quantitative acceptance criteria assumed in
' safety analyses which are specified in a licensing document such as the FSAR, Technical specifications, or NRC commitment letter" and is therefore clearly inoperable.
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3.
The corrective steps which will be taken,to avoid further violations:
No additional corrective actions are planned for this event.
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The date when full compliance will be ac.hihved:
Full compliance was achieved on 9/34/90.
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