ML20214G078
| ML20214G078 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/26/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8611250547 | |
| Download: ML20214G078 (3) | |
Text
1 o
DAB DUKE POWER GOMPANY I*.O. HOX 33180 CHAMLOTTE. N.C. 28242 IIA 1,11. TUCKER
,,n gy 37 y
oo OCI 6
...... ~ -
p;,28 September 26, 1986 Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St. NW, Suite 2900 Atlanta, Georgia 30323
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370
Reference:
NRC/01E Inspection Report 50-369/86-19, 50-370/86-19
Dear Dr. Grace:
Pursuant to 10CFR2.201, please find attached a response to the violation which was identified in the above referenced Inspection Report.
Very truly yours, dl4k a
4 Hal B. Tucker JBD/102/jgm Attachment xc:
Mr. W.T. Orders NRC Resident Inspector McGuire Nuclear Station 8611250547 060926 I I PDR ADOCK 05000369 4
O PDR
/gM
/
o; DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION IN INSPECTION REPORT 50-369/86-19 AND 50-370/86-19 Violation 50-370/86-19-02, Severity Level IV 10CFR50, Appendix B, Criterion II is implemented by the accepted quality assurance program documented in Duke Power Company Topical Report, Quality Assurance Program (Duke-1-A, Amendment 9), which in turn is implemented by Station Directive 3.11.0.
Collectively, these documents require that activities affecting quality be
[
accomplished under suitably controlled conditions. Controlled conditions include k
suitable environmental conditions such as adequate cleanliness.
Contrary to the above, in July 1986 two towels were discovered beneath the reactor lower core plate. The undetected entry of the objects into the reactor coolant system demonstrates a failure to accomplish activities affecting quality under suitably controlled conditions such as adequate cleanness.
Responce:
1.
Admission or denial of the alleged violation:
Duke Power admits the violation occurred as stated.
2.
Reason for violation:
The point of entry could not be determined.
However, due to the configuration of the reactor vessel and core support plates, the towels most likely entered through the reactor coolant cold leg inlet pipes and passed downwards into the core support area. The point of entry was probably an open component of a system being maintained during the outage. The component was probably in lower containment. Lower containment is a Level IV cleanliness zone, but the systems associated with the reactor coolant system are Level II and III cleanliness zones. The Level II and III cleanliness zones are required to have a Personnel and Materials Entry Log for the documentation of personnel and materials entering and exiting the cleanliness zone to ensure items are not left in the system being worked on.
A review of approximately 50 outage related work requests involving work that required Level II and III cleanliness zones to be established indicated inadequate documentation of items entering the cleanliness zones.
The Personnel and Materials Entry Logs were documented by item, and quantity when materials such as tools, equipment, or parts were taken into the housekeeping However, rags were listed on the logs as " rags" without a quantity zone.
designation. This has been standard practice in the past.
This resulted in the loss of assurance that rags, taken into the cleanliness zones, were removed at the end of the job.
b 3.
Corrective steps which have been taken and the results achieved:
On July 17, 1986, procedure number MP/0/A/7150/86 " Refueling Canal Cleanliness Watch" was implemented. This procedure is to ensure that the refueling canal is continuously watched to prevent items from being dropped into the Reactor Coolant System (RCS). The watch ensures that all items taken over the canal are tied off, all safety glasses are tied off, items brought into the building are logged in and out, etc.
The watch also ensures that if anything is dropped into the system, it will be removed.
4.
Corrective steps which will be taken to avoid further violations:
Station Directive 3.11 will be re-written to clarify cleanliness program.
The mechanic will be given more direction in his responsibility for implementing the cleanliness program. The directive will be changed to specify that each item brought into a cleanliness zone will be logged in and out.
Mechanical Maintenance training will send a required reading package consisting of Station Directive 3.11.0 and a clarification letter to ensure all maintenance, both supervisory and craf t personnel, are aware of their specific responsibilities concerning this directive.
Each supervisor will be instructed to review all paperwork as it is completed. Also, supervisory field involvement has increased due to programs implemented on September lat. Also, through management meetings, the supervisors will be instructed on the implementation of the cleanliness directive. This will ensure that the program will be implemented correctly.
The refueling procedures' will be changed to ensure that the area under the core plate is inspected before fuel is reloaded.
5.
Date when full compliance will be achieved:
All corrective actions will be completed by January 1, 1987.
_ _ _ _