ML20216G885
| ML20216G885 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 09/11/1997 |
| From: | Hebert J Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-309-97-06, 50-309-97-6, JRH-97-199, MN-97-103, NUDOCS 9709160083 | |
| Download: ML20216G885 (3) | |
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MaineYankee ACLI ABLE EL ECT RIC_ TY SINCE 1972 I
329 BATH ROAD
- BRUNSWICK, MAINE 04011 * (207) 7984100 l
September 11,1997 MN-97-103 JRH 97-199 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk Washington, D.C.
20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo, dated August 14,1997, Notice of Violation for NRC Inspection report 50-309 / 97-06
Subject:
Reply to Notice of Violation Associated with NRC Inspection Report No. 50-309/97-06 Gentlemen:
The attachment to this letter provides Maine Yankee's reply to the Notice of Violation contained in reference (b). Included in this response is the reason for the violation, corrective actions / actions to prevent recurrence and the full compliance date.
Please contact us should you have further questions regarding this matter.
Very truly yours, M 9-bames R. Hebert, Manager
- Regulatory Affairs Depanment JVW i
Enclosure 3
c:
- Mr. Hubert Miller Mr. Richard A. Rasmussen Mr. D. H. Dorman Mr. Patrick J. Dostie Mr. Uldis Vanags 9709160003 970911 PDR (4 DOCK 05000309 G
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e REPIN TO NOTICE OF VIOL ATION YlDlalluni A.
Technical Specification 5,8.2 requires,in part, that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33,(Rev. 2), dated February 1978. Regulatory Guide 1.33, (Revision 2), dated February 1978, recommends in Appendix "A", Section 3, Procedures for Startup, Operation, and Shutdown of Safety Related PWR Systems, that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared for safety related systems.
- 1. hiaine Yankee Procedure OP l-11-8, Refueling Water Storage Tank (RWST) Makeup, Recirculation and Purification, step 6.3.4, requires valve CPU-9 from the Refuel Cavity to be shut, and valve CPU 24 from the RWST to be opened, prior to starting pump P-8, to place the RWST in the " Recirculation Purification Mode."
Contrary to the above, On June 28,1997, an operator incorrectly opened valve CPU-9 instead of CPU-24, to place the RWST in " Recirculation Purification Mode," thereby causing approximately 10,000 gallons of water to be unintentionally diverted from the upender pit to the RWST.
- 2. Maine Yankee Procedure 1-17-4, Cavity Draining, Step 6.3.25, requires that valve CPU-2 be opened prior to starting pump P-8.
Contrary to the above, on June 26,1997, an operator failed to properly open suction valve, CPU-2, prior to starting pump P-8, causing the pump to trip on low suction pressure.
Maine Yankee Response:
Maine Yankee agrees with this violation, the two examples above were due to lack of attention to detail resulting in human performance error. The first example lead to an inadvertent transfer of 10K gallons of radioactive water to the Refueling Water Storage Tank, in both cases the equipment was properly labeled and the operators were using the correct procedure.
LNUMN;97103 WPD
immediate Corrective Actions:
The immediate corrective action in both cases were to stop and evaluate the pioblem, correct the valve position, and to ensure the sequence of events were well understood before proceeding.
Actions taken to the speci0c events are as follows:
(1) Transfer of 10K gallons to the RWST - When the operators identined the RWST level was increasing the SOS directed P-8, RWST recirculation pump be stopped. The incorrect alignment was identified and corrected and was second verined by another operator. The RWST recirculation was restarted.
(2) CPU-2 mis-valving - The operators immediately determined P-8 had tripped off. The operating crew stopped and re-evaluated their line-up. CPU-2 was determined to be out of position. CPU-2 was re-positioned and the evolution continued. P 8 was designed to trip on low suction pressure to protect the pump. This mis-valving was discussed at the next day's briefing.
When upper management became aware of the events on the following business day (Monday),
an Operations Department stand-down was imposed. The only Operations activity allowed was that required to maintain the plant in a safe condition. Both operators involved were disqualified and given remedial training before being allowed to go back on shift 100% peer verification was imposed during the stand-down.
Corrective Actions Taken to Avoid Fitrther ViolatlDE An root cause evaluation team was established to evaluate these two events and similar human performance enors in Operations. As a result of that Root Cause Evaluation, several additional actions were taken to prevent future errors as follows:
(1)
Implemented self-checking and pee /r verification procedure.
(2) Operations Management presented their expectations on procedure use and knowledge to all Operations personnel prior to assuming the shift (3) Operations developed a package of applicable procedures for operators to review prior to assuming shift.
(4) Both NPOs involved were counseled and trained in proper valve alignment techniques IAW procedure 1-200-10 and Lesson Plan AO-L-1.7 and the principles of Stop Think Act and Review (STAR).
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(5) M,aine Yankee applied a STAR simulator in the training of all Operations Department personnel.
Bill Compliance Datel Full compliance was met on June 30 when the Operations stand.down was initiated and sufficient actions were put in place to prevent reoccurrence.
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