ML20245A249
| ML20245A249 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/05/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906210169 | |
| Download: ML20245A249 (5) | |
Text
"
.r-i DUKE PowEn GOMPANY l
P.O. HOX 33189 CHAltLOTTE, N.C. 28242 l
HALU.TUCKEH retep3ione vms enemm*"'
(704) 373-4531 MUESL9lAN rROlm0 TION June 5, 1989 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Subj ect: McGuire Nuclear Station Docket Nos. 50-369, 370 Inspection Report Nos. 369, 370/89-02 Reply to a Notice of Violation Gentlemen:
Pursuant to 10CFR.201, please find attached Duke Power Company's response to Violation 369, 370/89-02-01 for the McGuire Nuclear Station.
Should there be any questions concerning this matter, contact W. T. Byers at (704) 373-6194.
Very truly yours, i
i llal
. Tucker WTB61/lcs j
Attachment j
xc:
Mr. S. D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Darl llood U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station 6
0
_ _a
{
McGuire Noclear Station Easponse to Violations Violation 369(370)/89-02-01 A.
Technical Specification 6.8.1.a requires written procedures to be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2 February 1978.
2 Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Section 9.a, states in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned, and performed in accordance with written procedures, documented instructions, or drawing appropriate to the circumstances.
Contrary to the above:
1.
On February 15, 1989, a maintenance crew was observed working on Work Request number 13468 without following the appropriate procedure. The procedure, MP/0/A/7400/04, Diesel Generator Cooling Water Heater Circulating Pump Removal and Replacement.
approved 3/15/88, was still enclosed in the work package when work was being performed. Action being taken by the mechanic involved pump disassembly which was not part of the approved procedure.
2.
On February 15,1989, a maintenance crew was observed performing work with inadaquate preplanning and an inadequate procedure or inadequate documented instructions. Work Request number 501439, was to cover the removal and replacement of the 2B diesel fuel injector 'O' rings, using procedure number MP/0/A/7400/16 Diesel Engine Cylinder Head Corrective Maintenance, Change 14. The procedure used was too broad in scope for the work being performed. Written direction was not provided to specify specific steps to be followed to complete the task. After work had started, a special tool, not identified in the required tools section of the procedure, was identified by a supervisor as being needed for the task. The supervisor provided oral direction to the workers on use of the tool.
It was also determined that the fuel line from the fuel pump to the injector would have to be removed prior to injector removal. The procedural steps covering this line removal were not found in the procedure until after'the removal of the first injector.
Adequate documented instructions were not provided for a task demonstrated to be beyond the normal skill of the craft.
This is a Severity Level IV Violation (Supplement I).
7
(/,
Response "to Violation Example 1:
1.
Admission or denial of the violation:
The violation is admitted as stated.
2.
Reason for the violation if admitted:
The reason for part of the violation was that the procedure being used,MP/0/A/7400/04, required breaking of the pump piping flanges to remove the pump. These flanges were not attached directly to the pump but had several feet of piping included between the pump and the nearest flange. What the personnel did was to break the motor base bolts loose and proceeded to pull the pump from the discharge casing leaving the flanges attached. The procedure they were tuing did not cover breaking motor base bolts and the procedure to cover removing the discharge casing bolts (MP/0/A/7400/05) was not used.
The personnel involved did this due to the problems they encountered from initially trying to remove this pump and their past experience working on a pump of this type. Based upon their experience, the personnel knew the simplest way to remove the pump was to break the discharge head bolts as they did. The personnel did not use the procedure they needed (MP/0/A/7400/05) and the one they were using (MP/0/A/7400/04) needed changes to be correct.
3.
Corrective steps which have been taken and the results achieved:
A major process change was performed on Procedure MP/0/A/7400/04 on February 15, 1989 to allow the pump to b3 removed as required.
The incident was discussed with the individuals involved.
Personnel were informed they were not to deviate from this or any other procedures, except as permitted by MMP 5.0.
The resetits have been an improvement to procedural adherence where needed and the overall organization is aware that procedural adherence is expected at all times.
Specific criteria must be met in order to deviate from a procedure. This criteria is given in MMP 5.0.
The Station Manager has conducted sessions with line and staff personnel which specifically dwelled on adherence to procedures as a clear and constant expectation.
A corporate program emphasizing professionalism is being shown at McGuire and includes behavioral descriptions of a professional developed by a group of McGuire personnel. The first expectation of a professional referenced is to " follow procedures". One overall message of the professionalism information is the unwavering dedication to fulfilling expectations with quality and integrity.
A McGuire Safety Review Group In plant Review of selected Maintenance procedures found diligent adherence to every step, and a conscientious review to enhance the quality of the procedure program. The Maintenance division is also reviewing
7
+
-,...p
,and enhancing their procedure program to clarify, procedures and
~.to eliminate discrepancies'in' procedures.
' 4 '.
The corrective steps which will be taken to avoid future
' violations:
- As stated.above, management has been. involved in' making everyone aware of what is expected in procedural adherence and appropriate actions.if they do run.into a procedural problem. All' personnel are aware that procedures are not guidelines 3but are how we have
. committed to perform maintenance on iomponents and that strict adherence to: procedures is required.
5.
The date when full compliance will be achieved:-
While'the training of personnel is.an ongoing process, McGuire' Nuclear Station is presently.'in full compliance.-
Example 2:
1.
Admission or denial of the violation
.The violation is admitted as stated.-
2.
Reason for the violation if admitted:
l The job being performed was not a high frequency job.
The l
l
_ personnel performing the job were familiar with this particular job but had not-performed it recently. The personnel did review-J the procedure, MP/0/A/7400/16, and knew'the steps to be performed but failed to pick up all required special tools needed~to perform the job. Also, the procedure being used was J
inappropriate to perform the job.
/
3.
Corrective stens which have been taken and the results achieved:
The personnel involved in this incident have been counseled on the importance of adhering to procedures. Additionally,') dip 5.0, which details the required criteria for deviating from a procedure, was put into effect May 8, 1989.
As discussed in the response to Example'1 above, McGuire is placing immediate emphasis on adherence to procedures. This is resulting in' increased' procedural compliance. Maintenance is
~!
also reviewing and enhancing their procedure program as_ discussed-
~
above.
4.
The corrective steps which will be taken to avoid _futuIg,)
j violations:
i
(
Due to the inadequacies of the procedure being used for this particular job. the-procedure will be changed to incorporate this j
type of job without requiring special supervision. This upgrade I
will.be made tc the procedure to incorporate removing the i
injector fuel oil lines,-and using the.special. tool to remove 1
injectora from'the. cylinder head.
__ _ _ 2_ -
- r. ~,
'.-yj g, ;[ a
,.l'*
' 5.. The date when full compliance will be~ achieved:
The procedure change will be implemented by July 1, 1989.
5 6
.)
- k J
, ll,
- l
--_-_..__:-__O