ML20214G730

Special Rept:On 870407 & 08,complete 18-month Insp Required for Standby Shutdown Diesel Generator Determined Not to Have Been Performed on Time.Caused by Personnel Error.Work Request Will Be Issued Prior to 18-month Due Dates

ML20214G730
Person / Time
Site:	McGuire, Mcguire
Issue date:	05/13/1987
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8705270157
Download: ML20214G730 (6)

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DUKE POWER GOMPANY P.O. Box 33180 CHARL0rrrE, N.C. 28249 HAL B. TUCKER Tra.srssows vm. .. m (704)073 4831 mm. . o.

May.13, 1987 U.S. Nuclear Regulatory H DeiiniisiiinE0imirelW Desk e- G Commis si on Washington, D.C. 20555

Subject:

McGuire Nuclear-Station Docket Nos. 50-369, -370 Technical Specification 4.7.14 and 6.9.2 Gentlenen:-

Please find ' attached a special report submitted pursuant to Technical Specification (T.S.) 6.9.2 as specified by T.S. 4.7.14. The report concerns a failure to comply with proposed T.S. 4.7.14 af ter August 16, 1984 resulting in a missed commitment.

This event is considered to be of no significance with respect to the health and safety of the public.

Very truly yours .

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dE6 e Hal B. Tucker SEL/52/jgm Attachment xc: Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, GA 30323 Mr. Darl Hood U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Mr. W.T. Orders INPO Records Center NRC Resident Inspector 1820 Water Place McGuire Nuclear Station 8705270157 870513 ~

Atlanta, GA 30339

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PDR ADOCK 05000369 ##

S PDR'.

._ Duke Power Company McGuire Nuclear Station Special Report.

The Complete Eighteen' Month Inspection Required On The Standby Shutdown Facility Diesel Generator Was Not Performed On Time Due To Personnel Error .

Introduction:

During a review of the Preventive Maintenance / Periodic Test computer program,

.a determination was made on April 7 and 8, 1987, that the Standby Shutdown i Facility Diesel Generator preventive maintenance inspection was apparently not performed'within 18 months af ter the February 16, 1984 inspection. A station

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. commitment to comply with proposed Technical Specification 4.7.14 after August 16, 1984 requires that at least once each 18 months, the diesel must be inspected in accordance with procedures prepared from manufacturer's

. recommendations.

Three preventive maintenance activities are recommended by the manufacturer, Cummins Engine Company Inc., to be performed once every 2 years. These three activities were performed only'during inspecticus begun on February 16, 1984 and February 27,'1986. All other preventive maintenance was performed on a frequency recommended by-the manufacturer and more frequently than each 18

• months. The 18 month interval and allowable grace period for the inspection was exceeded by 54 days beginning on January 4, 1986 because the three activities recommended by the manufacturer to be performed on a 2 year

-frequency were not performed at least once each 18 months.

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{ Station personnel completed preparation oi a procedure for preventive maintenance on the Standby Shutdown Facility Diesel Generator during the

. February 27,.1986 inspection, incorporating the three items previously performed only in the 2 ' year inspection into an 18 month inspection. On April 7,;1987, station personnel changed the Preventive' Maintenance / Periodic Test schedule to delete the 1 year inspection work request and incorporate 'an

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s 18 month inspection work request.

Units 1 and 2 were in Mode 1 Power Operations, at 100% power at the time of the discovery.

' This incident has been attributed to personnel arror because station personuel did not write the procedure and change the Preventive Maintenance Program Work i

Request schedule to perform all preventive maintenance inspection activities on the Standby Shutdown Jacility Diesel Generator at least once every 18

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months until after the grace period expired. ,

EVALUATION:

Background

, The Standby Shutdown . Facility (SSF) Diesel Generator (D/G) provides an 4-auxiliary electrical power supply in emergency conditions. This is necessary to ensure that either unit may be brought to and maintained in the Hot Standby

} mode in the unlikely event of a_ fire or sabotage which renders the Control Roo3 and automatic safety systems inoperable.

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,- :One of the requirements of proposed Technical Specification (TS) 4.7.14 is that the SSF D/G be demonstrated operable by performing an inspection at least once each 18 months in accordance with procedures prepared from the recommendations of the manufacturer of the diesel. If the surveillance interval.is exceeded,-rendering the SSF D/G technically inoperable, the action statement requires repairs be effected within 60 days or a report must be submitted to the NRC within 14 days af ter the 60 day period. McGuire Nuclear Station management committed the station to comply with the proposed TS 4.7.14 on August 16, 1984 in a letter sent out to appropriate station personnel.- The letter defined how, and by which group surveillances would be met, based on information from meetings held to discuss the issue with representatives of groups who would be required to_ fully implement the' commitment. (It has been determined since 1984 that these requirements will not be included in a TS, but will be contained in s' separate document with other fire protection i items.)

Station personnel initiated Preventive Maintenance Program Work Requests (PMP WRs) close to the time of the distribution of the letter to perform monthly, semi-annual, 1 year, and 2 year preventive maintenance inspections. The specific tasks to be performed were defined on the work requests and the manual from the manufacturer of the SSF D/G was referenced. No procedure for

• any of the work was written at the time the PMP WRs were initiated. The preventive maintenance inspection (PMI) intervals set up under the PMP WRs differ somewhat from the frequencies stated in the Cummins Engine Company, Inc. manual. Cummins representatives agreed verbally in discussions with station personnel that daily and weekly PMIs specified in the manual were unnecessary for the D/G at McGuire because of the very limited number of hours of run time the D/G receives. The representatives also concurred with station personnel that the crankshaft end clearance would only need to be checked once every 2 years for the same reason.

The McGuire Preventive Maintenance / Periodic Test (PM/PT) computer program uses

a different calculation to determine a due date for a Periodic Test (PT) than

!~ for Preventive Maintenance (PM) work requests. The pts are usually items l required to meet a regulatory commitment. The commitment is normally

! identified in the surveillance field-on the description screen of the PM/PT

program for that PT work request. The PMP WRs on the SSF D/Gs were not i designated as pts and no commitment reference was included in the surveillance field for these work requests.

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Description of Incident t

l On February 16, 1984, station personnel began work under a work request to

! perform a 2 year PMI on the SSF D/G. The work included three items

i. recommended by the manufacturer to be performed on a 2 year frequency as well l as repeating other preventive maintenance performed more frequently. The

three items performed only on the 2 year PMI were to check the crankshaft end clearance,-turbocharger bearing clearance, and vibration dampers.

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! In the letter issued to station personnel on August 16, 1984 which required

( compliance with proposed TS 4.7.14, station personnel were credited with the

February 1984 PMI (letter reads January 1984 for unknown reasons) on the SSF

[ .D/G as having initially fulfilled the requirements of step 4.7.14.1.c of the I

proposed TS. The letter also charged Maintenance personnel (MNT) with the

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responsibility for performing the PMI during the next outage with a procedure to be written prior to use. MNT either routed the actual proposed TS and attached letter to MNT responsible for SSF D/G maintenance (MNT. Engineer A) or by some other means informed him that he was to write the PMI procedure and ensure compliance with the commitment. . The date the assignment was made could not be determined during this investigation as no documentation was retained by MNT.

f-i MNT Engineer A recalls receiving the assignment to write the procedure, but does not recall any emphasis being placed on a deadline. He was busy with other projects at the time he was assigned the procedure and did not consider

, it to be of high enough priority to take precedence over the other work j already in progress. Shortly after the August 16, 1984 commitmentlto perform the maintenance on an 18 month frequency, the first PMP WR (semi-annual PMI) on the SSF D/G was automatically generated on August 29, 1984; the monthly and

, one year PHP WRs followed. MNT Engineer A is unsure of whether he initiated the PMP WRs before or after he received the assignment to write the procedure, but-remembered that he had planned to set up the program based on the i manufacturer's recommendations long before the implementation of the proposed

! . TS.

4 In February 1986, the first 2 yeLr PMI initiated with an automatically issued PMP WR was begun. MNT Engineer A informed the MNT crew performing the work that he was in the process of issuing a procedure for the SSF D/G PMis. The MNT crew had completed the work by referencing the manufacturer's manual as

! directed by the work request. The procedure, MP/0/B/7400/66, was approved on j March 19, 1986. MNT completed documentation of their work on the enclosure of l the new procedure and closed out the work request. The procedure addressed three PMIs to be performed on a monthly, semi-annual, and 18 month frequency.

The 18 month inspection included a requirement to perform all of the steps specified in the monthly and semi-annual sections, and all of the steps formerly performed during inspections every year and every 2 years under PMP i

WRs. No changes in frequency were made to the PMP WR after the issue of the

new procedure changing the inspection frequencies. The MNT crew performing i

the 2 year inspection did not question the difference in the procedure and work request frequency specified.

On Mareb 24, 1987, a regularly scheduled meeting was held to discuss the PT program. At this meeting, a list of TS references was distributed which had I

been generated from a review of the PM/PT program as a corrective action from a previous incident report. Planning personnel were asked to review the list to ensure that all appropriate TS references were included in the FM/PT

, program. The SSF D/G proposed TS was included on the list.

During the course of this review on April 7th and April 8th,1987, Planning 1 personnel discovered that the SSF D/G PMP WRs were not designated as pts in i the PM/PT program and no commitment reference was listed in the surveillance i field for these work requests. Planning personnel changed the 2 year PMI to

an 18 month PMI, deleted the PMP WR for a 1 year PMI, and added proposed TS I

4.7.14 as a reference in the surveillance field for the 18 month PMI. Upon checking the work request history, Planning personnel discovered that the

, complete PMI was not performed between February 16, 1984 and February 27, 1986, indicating that the surveillance interval of 18 months plus the grace period had been exceeded by 54 days.

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Conclusion

_ The' 18 month comunitment interval was. technically exceeded because the PMP WR was not set up scheduling all SSF D/G PMI items to be performed at least once every 18 months prior to the January 4, 1986 late date; however, between February 16, 1984 and February 27, 1986, all SSF D/G PMIs were performed at least'as frequently as agreed upon with manufacturer's representatives or as specified in the Cummins Manual, MCM 1301.02-0058 002. The work is documented on completed work requests. The three inspection items which were not performed every 18 months or more frequently were the turbocharger bearing inspection, crankshaft end clearance measurement, and vibration damper inspection. The manufacturer recommends these activities be performed once every 2 years.- ' These activities were performed in February cf 1984 and February of 1986. MNT had therefore attempted to ensure adequate preventive maintenance according to manufacturer's recommendations was performed on the SSF D/G, but had not complied with the specific commitment to 18 month intervals.

MNT Engineer A is assigned a personnel error for this incident. - The' station commitment on August 16, 1984 requires that an inspection be performed at least every 18 months in accordance with procedures generated from manufacturer's recommendations.- The writing of the procedure for the PMIs was-assigned to MNT-Engineer A sometime after the August 16, 1984 letter was issued mandating compliance with the proposed TS 4.7.14. Although there is no documentation available to pinpoint the exact date of the assignment MNT Engineer A and other MNT Supervisory personnel believe that he probably received notification to write the procedure well before the expiration of the grace period on January 4,1986.

MNT Engineer A did not change the frequencies of the PMP WRs even af ter 'the procedure to perform the PMIs was completed. Until the discovery of the problem by Planning personnel on April 7, 1987, the frequencies for PMIs on the SSF D/G stood at 1 month, semi-annual,1 year, and 2 years for the automatic issue of PMP WRs. No 18 month PMP WR existed until April 7, 1987.

It is not considered to be relevant by personnel involved in this incident-l that the PMI was not performed during the next outage after August of 1984 as l specified in the letter committing the station to the proposed TS. Although I MNT apparently did not raise the question at the time, there are no logical, i traceable reasons why it would have been necessary to schedule the 18 month l PMI only during an outage. SSF D/G PMIs are routinely performed when one or

i. both units are in power operation, l'

This incident is not reportable to the Nuclear Plant Reliability Data System.

i A review of past McGuire reports revealed several incidents of missed periodic tests due to personnel error; therefore, this incident is considered to be recurring. The circumstances are somewhat unique in that the requirement to 1 perform the periodic test'in this case was part of a proposed commitment rather than an approved commitment.

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. Corrective Actions:

Station personnel ensured that a PMP WR to perform the inspection in its entirety be automatically issued prior to 18 month surveillance due dates.

The work request is designated as a PT and proposed TS 4.7.14 is referenced in the PM/PT computer program for that Work Request.

Safety Analysis:

The Standby Shutdown System (SSS), of which the SSF D/G is a component, exists to mitigate the effects of an accident already in progress. Inoperability of the SSF D/G would only reduce the capability to mitigate the effects of an event which disabled normal and emergency shutdown systems and rendered the Control Room uninhabitable.

Although the SSF D/G would have been considered inoperable from the January 4, 1986 late date to February 27, 1986 because an 18 month inspection was not performed in its entirety, the SSF D/G was inspected according to the manufacturer's recommendations during the time the surveillance limit was exceeded until the PMI was performed. The SSF D/G should have therefore fulfilled its design function had an accident occurred during this time period.

There were no personnel injuries, personnel overexposures, or releases of radioactive material as a result of this incident.

The health and safety of the public were not affected by this incident.

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