ML20094M473
| ML20094M473 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/25/1992 |
| From: | Hampton J DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9204010002 | |
| Download: ML20094M473 (9) | |
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DUKCPOWEn March 25, 1992 1
U.S.
Nuclear Regulatory Conninsion Attention:
Document Control Desk Washington, DC 20555
Subject:
Oconoo Nuclear Station Doc':ot Non. 50-269, -270, -287 Inspection Roport 50-269, -270, ~287/92-03 Reply to Notico of Violation Dear Sirs By lottor daced Februar'; 27, 1992, the NRC isnued Inspection Hoport No. 50-269/92-03, 50-270/92-03, and 50-287/92-03 with a Notico of Violat.lon.
Pursuant to_the provision of 10 CFR 2.201, I am submitting a written response to the violations idontifled its the above Inspect.1on Report.
Very truly yours, J. W.
Itampton cc:
Mr.
S. D. Ebnetor, Regional Administrator U.
S.
Niiclear Reoulatory Comn.lssion, Region II 101 Marietta Stroot, NW Suito 2900 Atlanta, GA 30323 Mr. L. A. Wiens, Project Manager Office of Nuclear Recator Regul'ation-U. S.. Nuclear Regulatory Commiss.lon One White Flint North, Mail Stop 9H3 Washington, DC 20555 P. E. Ilarmon Sonior Rouldent Inspector Oconoo Nuclear Station i
92o4o20o02 92o323
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YinDtListn_?&hDJL10lO2-03-QL_S2yn;1ty_L9221. IV Technical Sp...fication 6.4.1 requires that the station bo oporated and maintained in accordance with approved proceduros.
0porating Proceduro OP/0/A/1107/03A, Charging Standby Bussas From Leo Steam Station, Stop 3.2.3 requires that a Loo gas turbino be started por section 3.0 of the Leo steam Station Emergency Power or Backup Power to oconco procedure.
Contrary to the above, OP/0/A/1107/03A was not followed in ( st. on January 13, 1992, Stop 3.2.3 wan not performed and the vconeo Standby Bussos woro connected to the Lee scation switchyard rather than an isolated Leo gas turbine resulting in an unquallflod power source being connected to the standby bussos.
BESMH6Ea t 14 The reason for the vio.lation, or, if contosted, the basis for disputlag the violations The reason for this violation was a
failure to follow e
procedure.
Tho was duo to the operating crow-misinterproting tha intent of stop 2.3 of Enclosure 3.3 of OP/0/A/1107/03,100 KV Power Supply.
This procedure was the
" controlling proceduro" for the charging of tho Standby Bussos (SBas) from Loo Steam Station.
The crow mistakenly assumed that since they were not supplying omergency power to the SBas, and since they woro just energizing the SBBs fer a test of the associated protectivo
- relays, (for PT/7/A/610/1C, ONS Emergency Power Switching Logic Standby Bus. i t. 2 Voltage Sensing Logic) that the isolation-of the gas-turbino at-Loo Stec.m Station was not required.
The stop in OP/0/A/1107/03 requiring that the Leo steam Statton gas turbine be isolated was, therefore, datormined to be "Not Applicable" ( N/A) -- and documented as such.
Although the necessity for isolating a Lee Gas Turbine to onorgizo the SBBs for any reason was pointed oue during training in the - past, none of the proceduros specifically stated that this isolation was necessary.
2.
The corrective stops that have been taken and the results achieved:-
The SL1-and SL2 breakers were opened to restore the SBBs to full operability immediately af ter the SBB degrauntion-was renitzod.
OP/0/A/1107/03,100 KV' Power Supply, was -revised, adding Limit and Procaution utops specifically describing the conditions under which the SBBs may be energized from-the 100 KV lino.
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Violation 92 03-01 Pago Two The operating crew involved has reviewed the stopu necessary for determining that a proceduro stop is N/A.
The approval lovel for determining that a proceduro stop is N/A was raised to tho shif t Supervisor or UnA t Manager 1o',01 for the duratioi4 of the Unit 2 refueling outago.
The use of provisions allowing the operators to datormir.o if a stop is N/A and to perform a procedure "Out of Sequenco" (OOS) has boon discusced with the Operations Shift Supervisora.
Emphasis on not changing the intent of the procedure with an N/a or OOS was clearly communicated.
The f act that non-conditj onal proceduro otops whj ch are truly not applicable nood to be reviewed very closely was also emphasized.
An inplant review was initiated by the Oconoo Safety Review y
Group. This review concerns Operations' uso of the provisions allotted for datormining that a stop is F /A or that a stop can be performed out of sequence.
Since these are administrative tools used to implement procedures, the of fectivevoss of thoso controls will bu assessed. Results of the inplant review will be used to ovaluato the extent of any weaknesses, J n addition to proposing any administrative changea. to Operations curront policios.
3.
The corrective stops that will be taken to avoid further violations:
A training package will be issued for review by all liconned operators with emphasis on the proper use of procedures including the process for determining whether a procedure _stop is N/A.
4.
The date when full compliance will be achloved:
The training package will be issued.y June 1, 1992 1
~ Violation 24.9,2 7 0,2 8 7 / 9 Pc'ij-02. Severtty Level IV Technical Spocification 6.4.1 requires that tho station be oporated and tr a intained in accordance with approved procedures and that appropriate writton instrisctions bo provided for activltion involving nucicar safety.
Proceduro OP/0/A/1503/09, Documentation of Fuel Assemblies and/or componont Shuffle Within a Spent Fuel Pool, controls the movonont of fuel assemba.las and control olomonts within tho spent fuel 2001.
contrary to the above, proceduro OP/0/A/1503/09 was inadequato_in
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that it did not contain guidance or procautions against moving a j
fuel assembly containing a control olomont to the holddown spring replacoment storage rack location.
This resulted in damage to a Unit 2 fuel assembly and control rod on January 29, 1992.
HMPONSE:
1.
The reason fo the violation, or, if contested, the bnais for disputing thn violation:
Failuro to follow proceduro - PT/0/A/750/04 is the controlling procedure for movement of fuel assemblies / control compononts for fuel assembly holddown upring repl coment.
it clearly l
j states that the control componout be removed from the fuoi assembly prior to placing the fuel assembly in a spent fuel pool (SFP) rack location containing a podestal.
OP/0/A/1503/09 - does -not con tta ln an i
Inadequate - proceduro adequato procedural step or lim!.t and precaution to pravant a fuel assembly with component to be placed ir et SFP - rack location containing a pedestal.
2.
The corrective stops that havo been taken and the results achieved:
l The damaged control rod was replaced with a now control rod.
t The fuel rods from the damaged. fuel assembly cago rcro ial t.ra sonical.l y tested and oddy current tested following removal from tho damaged cago.
The fuel rods were placed into.
a now fuel assembly cage.
The engineer responsible for:the twistake has been counsolled-and trained for awareness of.the importanco~ and necessit.y to i
operato.trom <:entro111ng procodures.
No damage was identitied-in any of the fuel rods.
Following a rocago of the fuelecods, the fuul assembly tras placed into the core fc.c Unit 2 Cycle 13 operation.
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Violation 92-03-02 Page Two OP/0/A/1503/09 was revised to precludo use of this proceduro for mo"ing fuoi asserabiles for repair, inspcction, etc.
3.
The corrective steps that will be taken to avoid further violations:
D&W is studying various options to reduce the size or height of the podestal from 12 inchos to 4 inches, to provido for adequate clearance betwoon the budge mast and 'uol assembly control component.
Procedures that control movement of fuoi assembiles in the SFP or that should address control of fuel assettbly mcmement in the SFP will be reviewed for instructional completeness and syncrgistic intor-relationship, especially as regards this event.
Special attention will be placed on making each proceduro (that requires -SFP fuel moves) stand alona !n addressing those moves.
Changes to these procedurer will be made en appropriate and documented using this violation as refernnce.
Instructional awareness training uili be conducted for the Reactor Engincors f or those procedures identiflod, espue.ia13.y in rogords to the controls that the proceduttus contain P
concerning cove?lopment of fuel assembly moves.
4.
'1ho date when full compliance will be achioved:
December-31, 1992-3 t
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Violation 269/92-03-OL Soy _nyl ty Lov_g1 IV Technical Specliication 6.4.1 requires that the station be operated arid maintained in accordance with approved procedurou.
Maintona!.co Proceduro MP/0/A/1720/10, Syste.a/ Component Hydrostatic Tes,
requires that loosened instrument test too fittings bo t!qhtoned and indopondently verified prior to returning instruments to service.
Contrary to the abo'ce, on January 27, 1992, the Unit i reactor coolant makeup pump pressure and flow instruments wore returned to service after a hydrostatic test without the test toes being tinhtc. nod resulting in a test too cap blowing of f when the pump was t
started for performance testing.
The procedure steps verifying that the.est teos'had been tightened had been signed off in the procedare cs having been accomplished.
ILEEPONSE:
1.
The reason for the violation, or, if contested, the basis for disputing the vjolation.
Personenol returning the associated la9trumentation to service took inappropriato actions while pe:lorming the task.
They did not havn a copy of the. procedure with them while they woro returning instrumentation to servico and there1 ore overlooked tightening the test too caps because they had bean loosened instead of being removed. Af ter the personnel exited the work area, they signed the procedure off as if they had tightened the caps.
2.
The corrective steps that have baan taken and the results achieved:
Becausa this was a violation of approved work practicos portaining to c:ntrol of ongoing
- work, appropriate disciplinary action was administered to the individuals involved. The individuals were counseled about the importance of having procedures, which require sign-of f, with them at all times.
The requirement 'of signing-steps as they are accomplished was also stressed.
3.
'The correctivo steps that will be taken to avoid further violations:
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This incident will be covered in I&E continuing training which will give others the benefit - of reviewing the pcor. work practice 9 that were used.
ILE will provide additional training on component verification and independent verification ~as part of continuing training.
i Viointion 92-03-03 2
Pago Two i
In addition, Maint.onanco Proceduro MP/0/A/1720/10, Systum/
i Component Mydrostat.tc Tout will be revised to require that I
tes t.
too caps be completely tomoved dur!ng isolction of ins t.rumenta tion.
j 4.
The date when full comp.iiance will'bo achieveat The above it.orus will be implemented by the beginning of the i
Unit 3 End Of cycle 13 F.ofueling Outago, currently scheduled j
to begin.'ely 15, 1992.
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Technical Specif ication 6.4.1 requires that the ntation bo operated and maintained in accordance with approved procedures.
Maintenance Directivo 7.5.3, Work Request Implementation, requires that disconnection /roconnection of wiring be documented and independently verified on Section V of the work request " Additional Shoot".
Contrary to the above, on January 12, 1992, Maintenance Directive 7.5.3 was not followed during the performance of work request 91020832, Perform Diagnostic Test on 2HP-26, in that wires were disconnected / reconnected and replaced during the performance of tho 1
i work roquest and not proporly documented and independently veriflod on Section V of the work request.
RESPON1Et 1.
The reason for the vialation, or, if contested, the basis for diuputing the viole. tion:
The personnel involved f ailed to follou the requiromants of Maintenancc Directive 7.5.3 uhich requires the documentation and independent vorification of disconnected / reconnected loads.
The InE technician should have obtt.it.ed a correctis, action work request and procedure to perform the replacement of tho fuses and jumper wiro.
A contributing cause in the violation was the fact that changes in the VOTES Testing Program prior to the outage permitted some repairs withaut the nood to initiato a corrective action work request.
2.
The corrective stcpd that have boon taken and the resulte achieved; Work request 51357L was written to replace the jumpor that was lunta11ed.
Engineering reviewed test data to determine potential damage to valve 2HP 2G.
The results of the engineering review indicated no damago and no further testing waa required.
-I&E work teams and managers were notified of this iacident and the requirement to adhere to processes and procedurou for documenting work in the field was strassed.
Formal counseling. was given to the two I&E technicians involved in the work activities.
This counseling related to the f ailure of the technicians to document work activities as required by established work control procedures.
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Violation 92-03-04 Page Two 3.
The corrective stops that will be taken to avoid further violations:
I&E and Component Engineering personnel will review the VOTES testing procedaros and processes.to further define the corrective maintenance activition permitted by the VOTES testing program.
This review will more clearly define the permissibio corrective activitics in the VOTES Prevec'tvo Maintenanco program for the technicle.ns accomplichtug the work.
Where appropriato, revise the documet.ts and prcaido necessary training prior to the next refueling cutage.
4.
The date when full compliance will be achtevo,1:
Full compliance will be achieved by July 1, 1992.
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