ML20101G705
| ML20101G705 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/15/1992 |
| From: | Mcmeekin T DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206260246 | |
| Download: ML20101G705 (4) | |
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Duke herr Company T C htmum McGuire Nackar Generation ikpartment lice President 12idO Hners Ferry Rved(AfGotA)
(704)S75 4 800 Hur,tersa!k. NCl Mil N985
. (704)S754809 fax DUKE POWER June 15,1992 U.S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 2055
Subject:
McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50.369 and 50-370 inspection Report No. 50-369, -370/ 92-1*-02 Gentlemen:
NRC Inspection Report No. 50-369, -370/ 92-11-02 resulted in Vlotation 92-11-02, concerning implementation of the modification process. The ori0 nal responte dated June 18,1991 stated that an i
addendt.m to that response would be submitted if further corrective actions were identified by an MSRG inplant review to be completed by 9/1/91.
That review was completed and resulted in additional corrective actions. Shortly after those recommendations were made, Duke Power reorgant;:ed to such an extent, that a new modification process needed to be developed. The MSRG recommendations were coasidered when the new NSM process was drafted.
The first draft of the modification process was completed May 28,1992. A final document is expected by August 1,1992 with fullimplementation by September 1,1992.
Attached is a description of the event tnal led to the violation, and coriective actions to prevent future occurrences.
For questions please contact Larry Kunka at (704) 875-4032.
Very truly yours, pc T. C. McMeekin
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I xc: Mr. S.D. Eb'1eter. Regional Administrator j
U.S. Nuclear Regulatory Commission, Region ll 101 Marietta St. NW, Suite 2900 Atlanta, Georgia 30323 1
4 Mr. Tim Reed, Project Manager j
U.S. Nuclear Regulatory Commission j
Office of Nuclear Reactor Regulation j
Washington; D.C. 20555 l
Mr. P.K. Van Doorn j
NRC Senior Resident inspector i
McGuire Nuclear Station i
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. Document Control Desk June 15,1992 Page 4 MCGUIRE NUCLEAR STATION 4
RESPONSE TO NOTICE OF VIOLATION i
Viglation 339/370/91-11-02 Technical Specification 6.8.1a requires written procedures to t,0 established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, 4
Revision 2, February 1978, which includes general plant operating and administsalive procedures.
Operations Management Procedure (OMP) 1-11, operations Modification Implementation Process, requires contial room drawings be red marked until final drawing updates are implemented upon.
implementation of modifications to assure that operators are aware of plant configuration.
d Contrary to the above, operations personnel failed to follow OMP 1-11 relative to red marking the appropriate drawing for modification M6022264. This iailure led to disabling of the diesel generator halon system when the breaker was opened for another modification.
i This is a Severity levet IV t'!olation applicable to Unit 2 only (Supplement 1).
4
Response
1.
Reason for V6olation:
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Drawing was not red-markeu because of confusion between OPS and Projects personnel wherein ops personnel thought the work had not been completed yet.
2.
Corrective actions taken and results achieved:
The drawing was properly red-marked immediately upon discovery and a fire watch was established in the D/G room.
3.
Corrective actions to be taken u :r.vid further violations:
Following are each of the MSRG recommendations and corresponding actions.
1)
RECOMMENDATION Establish an independent formal review process for NSM packages; a formal follow-up to ensure the appropriate and necessary changes have been identified and implemented (procedures, training, database updated, appropiinie e,gt. anrf olhar programs.)
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- Docurhent Control Desk 4
June 15,1992 Page5 HESPONSE An independent review by someone outside of the effected group may not be effective because the expertise about proce' lures, training, database updates, appropriate drawings, and other programs resides within the efMcted group.
Instead, rely on the technical expertise of sections to properly evaluate modification packages. Recent emphasis on procedural adherence and the following two recommendations will improve review accuracy.
2)
RECCMMENDATION Establish a formal departmental program defining individual and group responsibilities as applicable to the NSM Implemen?ation Process.
RESPONSE
A new NSM manual has been drafted and will be implemented by September 1,1992.
The new manual combines several programs that previously were separate. It comprehensively explains the problem identification, design and implementation phases, it was developed and will be supported by three different station groups; System Engineering-Station Problem Reports (SPR)
Component Engineering-Minor Modifications (MM)
Project Management Group-Nuclear Station Modifications (NSM) l 3)
RECOMMENDATION Station Superintendents and Projects Services Representatives should meet and discuss the needs of the affected stations groups in relation to the NSM Pre-Implementation Process and NSM Process, in general. During the review it was learned that there was no formal training given when the initial NSM Program was implemented.
RESPONSE
Training aboe: the new NSM Manual is scheduled to begin in June 1992. All groups that are part of the modification process are expected to complete the training by September 1,1992.
In addition to the above, the new process requires implementing procedured before functional testing instead of when declarect enerab!e.
l 4.
Full compliance will be achieved by September 1,1992.
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