ML20082G925
| ML20082G925 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 08/15/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108220096 | |
| Download: ML20082G925 (7) | |
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DUKE POWER August 15, 1991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555
Subject:
McGuiro Nuclear Station Docket Nos. 50-369, -370 Inspection Report No. 50-369, -370/91-13 Reply to a Notice of Violation Gentlemen Pursuant to 10CFR 2.201, please find attached Duke Power Company's responso to Violations 369/91-13-02, 370/91-13-n2 and 369, 370/91-13-03
'for McGuire Nuclear Station.
In addition, this reply also addresses an additional examplo of Violation 370/91-13-02 which was identifiod in Inspection Report No.
50-369, -370/91-17.
Should there be any questions concerning this matter, contact L.J. Rudy at (704) 373-3413.
Very trul yours, N
M M.S. Tuckman LJR/s Attachment xc (W/ Attachment):
S.D. Ebneter Regional Administrator, Region II T.A. Reed, ONRR P.K. VanDoorn Senior Resident Inspector
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McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION
, Violation 369/370/91-13-03:
10 CPR 50, Appendix B, criterion XVI and the licensee's accepted Quality As-surance Program (Duke Power Company Topical Report, Quality Assurance Pro-gram, Duke-1), Section 17.2.16, collectively require that measures be established to asuure that conditions adverse to cuality are promptly iden-tified and corrected.
Contrary to the above, licensee's procedure MMP 1.1, Umergency Work Pe-quents, did not provide adequate quidance to properly assess and prioritivo damage to pressure gauge INDPG5050 which was damt.ged durinq a work activity.
Also, established work practices were inadequate to assure proper evalu-ation.
As a result, the Residual llent Removal (ND) 18 train was inoperaaie when the pump recirculation mini-flow valve, IND-678, was rendered incapable of performing its automatic function.
Manual operation required by emer-gency p:*ocedures would have assured functional operability.
This ir a Severity Level IV violation (Supplement 1).
Response
1.
Reason for Violation:
During the performance of PT/1/A/4204 /01B, Fenidual llent Removal Pump 1B Performance Test, on May 16, 1991, valve IND-67B (Residual llent Re-moval System Pump 1B and lleat Exchanger 1B Miniflow) was inadvertently made inoperable when a flexible cable was pulled out of a junction box connected to pressure switch INDPG5050.
Pressure switch lNDPG5050 provides a signal to open IND-67B.
On May 19, 1991 the action state-ment of Technical Specification 3/4.5.2 was exceeded without appropri-ato compensatory action.
The valve had been inoperable for longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without the knowledge of Operations.
-A work request was written on May 16 to repair the wires pulled out of pressure switch 1NDPG5050 but it was not recognized by Performance personnel at the time that this affected the operability of IND-67B.
The valve was discovered to be inoperable May
.0, 1991, when the ND 1B pump was started.
The separated wires were repaired under another work request and the Residual lleat Removal (ND) system was returned to operable status on May 21, 1991.
2.
Corrective actions taken and results achieved:
a.
The wiring and conduit feeding pressure switch 1NDPG5050 was re-
. paired.
b.
ND pump 1B was successfully tested and declared operable.
c.
This event was reviewed with the personnel involved.
d.
Performance persont.el were instructedLto notify the Operations Unit Supervisor when any problems are discovered with process instrumentation so that OPS personnel are aware of the situation and an operability determination can be performed.
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e.
Performance management personnel initiated action to upgrade the labeling on flow switchen 1NDPG5040, 1NDPG5050, 2NDPG5040 and 2NDPG5050 These new labels will be color coded to indicate these instruments are train related.
3 Corrective actions to be taken to avoid further violations:
a.
Performance Toot Unit perconnel will attend training on appro-priate McGuire Nuclear Station drawings to include MCEE (Elec-trical Schematics) and MC-1499 (Instrument Details).
b.
A communication package will be developed by Design Engineering personnel for all appropriate McGuire Nuclear Station Nuclear Production personnel to inform them of the practice of allowing short sections of non-color coded cable in safety related appli-cations as described in the appropriate installation specifica-
- tion, c.
OPS will revise Station Directive 3.1.5, Operations or Operating instructions, to include instructions for all station personnel to contact OPS Control Room personnel if process instrumentation is fovad damaged.
d.
Station Management will review Station Directives and Mainte-nance Management Procedures which define work request. priority baned on operability requirements of station equipment and take appropriate action.
4.
Dates when full compliance will be achieved:
For corrective action a, McGuire will be in full compliance December 24, 1991.
For corrective action b, McGuire will be in full compliance August 24, 1991.
For corrective action c, McGuire will be in full compliance November 1,
1991 For corrective action d, McGuire will be in full compliance September 30, 1991.
Violation 370/91-13-02 '
Example 1:
Technical Specification 6.8.la requires written' procedures to be entab-lished,_ implemented, and maintained covering'the applicable procedures re-commended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which recommends surveillance test procedures.
Test procedure PT/2/A/4200/28B, Step 12.4.4 states " Record initial position of 2 ETB6 ( AFWP 2B), and have Operations rack to TEST OPEN".
Contrary to.the above, on Juno-6, 1991, personnel failed to' follow procedure PT/2/A/4200/28B in that Auxiliary Feedwater Pump -(AFWP) 2A was racked to-TEST OPEN and procedure Step 12.14.4 was signed off for AFWP 28.
This-led to an unplanned start of APWP 2B.'
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.Thir."10 a Severity Level IV Violation applicable to Unit 2 only (Supplement I )..
Response
1.
Reason for violation:
On June 6, 1991, Performance (PRF) pirsonnel were performine PT/2/A/4200/288, Train H Slave Relay Test.
The PRP personnel coordi-nating the test mistakenly communicated to Operations (OPS) personnel to rack out th) breaker for Motor Driven Auxiliary reedwater (CA) Pump 2A instead of :he I t Jr.ker for CA pump 2D as specified by the proce-dure.
Consequently, when Train 2B Slave Relay was actuated in a later procedure ntep, CA pump 2D started and pumped water into Steam Genera-tor 2C and 2D, The OPS p~rsonnel involved did not have specific writ-ten directier.s
- a re ference copy of the PHP procedure when rncking out the broar.or.
2.
Corrective actions taken and renults achieved:
a.
OPS personnel stopped CA pump 2D and took appropriate measures to stabilize levels in Steam Generators 2C and 2D.
b.
OPS management met with personnel from each OPS shift to discuan the event and gather possible corrective actions.
c.
PHP management met with PHP personnel involved and discussed the event.
d.
Appropriate changes were made to PRF Section Directive 1.0, Gov-erning Procedure Compliance, to ensure that PRP personnel will provide a reference copy of the respective procedure to appro-priate personnel performing support activities for procedures.
3.
Corrective actions to be taken to avoid further violations:
a.
Station management will evaluate and make appropriate changes to Station Directive 4.2, Handling of Station Proceduren, to ensure all station personnel performing support activities associated with procedures have a reference copy of the respective proco-dure with them or have the specific procedure steps read to them verbatim when performing the activity.
b.
Appropriate changes will be made to OPS procedure OMP l-2, Use of Procedures, to require OPS pornonnel performing. support ac-tivities to either have a. reference-copy of the respective pro-cedure with them or have the specific procedure steps read to them verbatim when performing the activity.
c.
Appropriate-changes will--be-made-to' procedure PT/1 and 2/A/4200/28A'and B, to specify the proper train when' verifying the "CA AUTO START DEFEAT" -la not selected, d.
Station Management will evaluate the requirementito hold " pre-job" briefings to include all personnel involved for tests or procedures involving station personnel sunport.
4.
Date when full compliance will.be achieved:
McGuire will be in full compliance for action a by December 1, 1991.
For corrective action b, full compliance will bo achieved by November 1*,
1991.
For corrective actions e and d, McGuire will be in full com-pliance by September 1, 1991.
Example 2:
Technical Specification 5.8.1.a requires procedures '
testing activities to be implemented properly.
This event was caused *
+n operator failing to follow the procedural guidance provided for thi i
. and is Leing con-sidered another example of violation 370/1 2s-02, w. 2ch was an unplanned ESF actuation due to a failure to follow procedure.
1.
Reason for violatio't:
On June 28, 1991, Operations (OPS) Periodic Test (PT) group personnel were performing PT/2/A/4350/01B, Bus Lines Protection Relay System Test.
The OPS PT personnel performing the control room portion of the test mistakenly placed the " BUS 2B TRANS TRIP CHANNEL 2 RCVR TEST" key switch in the " TEST" position instead of the " BUS 2B TRANS TRIP CHAN-NEL 1 RCVR TEST" key switch as specified by the procedure.
When the OPS PT group personnel in the switchyard placed the " BUS 2B TRANS TRIP CHANNEL 1 TRANS TEST" key switch in test and depressed the " TEST" pushbutton as directed by the procedure, a trip signal was sent to
" BUS 2B TRANS TRIP CHANNEL 1".
The trip signal caused Bus-2B Genera-t i tor Breaker to open and 6900 volt Bus 2TB and 2TD to swap to their al-ternate power source as designed.
An Engineered Safety Features Actuation occurred when Diesel G 3erator (DG) 2B automatically started due to a momentary undervoluage spike, when busr 2TB and 2TD swapped to their elternate power scurce.
2.
Corrective actions taken and results achieved:-
OPS personnel stopped DG 2B and returned all systems to normal status.
3.
Corrective actions to be taken to avoid further violations:
a.
OPS personnel will evaluate the need_to make proceduru, changes to PT/1 & 2/B/4350/01B to enhance procedure usability.
b.
OPS personnel will evaluate the need to-change transfer trip switches labels to make them less confusing and easier to read.
c.
OPS management will review chis event with OPS personnel as an-other examp3 of insufficient attention to detail.
4.
Date when full.compatance will be achieved:-
For corrective-actions a and b, McGuire will be in-full compliance No--
_j vember 1, 1991.
i McGuire will be in full compliance.for corrective action c, September 30,'1991.
' Violation 369/91-13-02:
Technical-Specification 6.8.1.a requires written procedures to be estab-lished, implemented, and maintained covering the applicable procedures re--
commended in Appendix A of Regulatory Guide 1.33,LRevision 2, February 1978,
-which recommends procedures for performing maintenance.
-- c i
. Work' requests (WRn) 98379 and 98380 required that touch up painting of the stops of the annulus doors be performed as necessary, but gave no further
. instructions for painting other parts of the annulus doors.
/
Contrary to the above, craft personnel failed to adhere to the approved W'.<s while painting the annulus doors.
Instead of painting only the stops, oa the WRs required, the whole door was painted necessitating the annulus doors being held open.
This rendered both trains of annulus ventilation incpera-ble.
This is a Severity Level IV Violation applicable to Unit 1 only (Supplement 7).
Renponse 1.
Reason for violation:
The craf t personnel performing the painting were of the riindset that touch-up paint meant to paint the
,,.ttre door surface to do a good
<=J job.
This was a preconceived idea present becacau of past job experi-ence.
Therefore, when they made a decision to paint the whole door and frame, the appropriate contact person was not consulted.
The di-rections to close the doors behind them, were-interpreted by the craft person acting as supervisor to be a reminder to close the doors after painting them, not a requirement to not hold the doors open while painting.
For this reanon the acting supervisor did not relay these instructions to the personnel performing the painting.
2.
Corrective actions taken and results achieved:
a.
Planning (PLN) management reemphasized requirements for planning work requests requiring painting of equipment to appropriate PLN personnel, b.
A meeting was held between Maintenance (MNT) Paint Craft person-nel, PLN personnel and MNT management involved to discuss the circumstances surrounding the event and planned corrective actions in an effort to resolve problems with control of paint activities and prevent recurrence of similar events.
3.
Corrective actions to be taken to avoid further violations:
This event will be covered with all appropriate Operations, MNT a.
and PLN personnel, b.
The McGuire Maintenance Management Manual will be reviewed and appropriate changes made to the specified process to control paint tasks.
c.
MNT management personnel will provide a list of appropriate group contacts with expert knowledge of equipment involved to PLN personnel for use on work requests involving paint activ-ities.
4.
Date when-full compliance will be achieved:
McGuire will be in full compliance for corrective action a and b, Sep-tember 15, 1991.
For corrective action c, McGuire will be in full compliance November 1,
1991.
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