ML20247L697
| ML20247L697 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/19/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906020237 | |
| Download: ML20247L697 (4) | |
Text
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~ DUKE POWER GOMPAhT -
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- P.O. BOX 33189 '
s CHARLOTTE, N.o. 28242 "HALH. TUCKER Tetnenown 1
vms passmewr (704) G73-4531 -
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May'19,'1989 U. S. Nuclear Regulatory Commission Document Control-Desk-Washington, D.C.
20555L 1
' Subj ect: McGuire Nuclear Station Docket Nos.-50-369, 370 Inspection Report ~Nos.. 369,'370/89-05 i
Reply to a Notice of Violation Gentlemen:
Pursuant to'10CFR.201, please find attached Duke Power Company's response to
- i 4
' Violation _369, 370/89-05-02 for the McGuire Nuclear Station.
Should there be any questions concerning this matter, contact W. T. Byers at,
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'(704) 373-6194.
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Very truly yours,;
'M k k Hal B. Tucker WTB53/lcs-l l
Attachment xc: Mri S. D. Ebneter Regional Administrator, Region II
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U. S. Nuclear Regulatory Commission
' f 101.Marietta St., NW, Suite 2900
-Atlanta, Georgia 30323 I
Mr. Darl Hood-i
-U. S. Nuclear. Regulatory Commission Office of Nuclear Reactor Regulation
' Washington, D. C. 20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station
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j McGuire Nuclear Station Response to Violation Violation 369(370)/89-05-02 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A. requires that procedures be written and implemented for maintenance on equipment that can affect the performance of safety-related equipment.
Contrary to the above, McGuire procedure MP/0/A/7600/06, Kerotest Y-Type Globa Valve Corrective Maintenance, was not properly implemented in that " hold points" were skipped without performing the required actions, obtaining the required signatures, or changing the procedure prior to continuing with work on IVG-40, DG Starting Air Tank 1B2 Drain Valve.
This is a Severity Level IV (Supplement I) violation and applies to Unit 1 only.
Response to Violation:
1.
Admission or denial of the violation:
McGuire admits the violation occurred as stated except that personnel were working on IVG-38 (DG Starting Air Tank 1A2 Drain Valve) not IVG-40 (DG Starting Air Tank 1B2 Drain Valve) 2.
Reason for the violation if admitted:
The violation is due to personnel error. The Mechanical Maintenance personnel involved have successfully completed the Mechanical Maintenance Orientation Training Program.
In the Mechanical Maintenance Orientation Training Program, the proper use of procedures is covered as a topic, emphasizing the importance of step by step compliance as well as providing the necessary documentation at HOLD points prior to proceeding to the next step. The Mechanical Maintenance Technicians did not perform the required actions in proper sequence on the assumption it was acceptable to complete these steps at a more appropriate time, as long as they were completed prior to reassembling the valve. This has been identified as an isolated incident involving personnel error and not a procedure related problem.
Procedure MP/0/A/7600/06, "Kerotest Y-Type Globe Valve Corrective Maintenance" is technically correct and the steps involved in this incident, 11.8.1 and 11.8.2, will continue to be required.
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3.
Corre_ctive steos which have been_taken and the results achieved Mechanical Maintenance Supervision has discussed this incident in detail with the Mechanical Maintenanea Personnel involved. The importance and responsibilities associated with implementing proceduras in a step by step manner and providing the necessary documentation at HOLD points prior to proceeding to the next stap was emphasized as well as the manner in which the affected procedure was violated.
Based on this discussion the Mechanical Maintenance personnel have stated they now have a full understanding for proper use of procedures.
4.
The corrective steps which will be taken to avoid future violations:
The Mechanical Maintenance Department will continue to provide Mechanical Maintenance Orientation Training for McGuire Mechanical Maintenance employees who are required to use station procedures as well as non-assigned Duke employees or Contract personnel coming in to support outage /non-outage related maintenance activities and who are also requirnd to use station procedures.
The Mechanical Maintenance Department has developed a Mechanical Manual Section 5.0 "Use of Procedures" which will be incorporated into the Mechanical Maintenance Orientation training lesson plan to enhance the topic on Use of Proceduras.
The Mechanical Manual Section 5.0 "Use of Procedures" provides guidelines / requirements and responsibilities associated with the proper use of station procedures. This document will ensure a more consistent method for using station procedures. Training will be developed and given to:
- Mechanical Maintenance Technicians
- Mechanical Maintenance Supervision
- Mechanical Maintenance General Supervision
- Nuclear Section Manager
- Mechanical Maintenance Employee Training and Qualification personnel
- Maintenance Engineering Services personnel 5.
The date when full compliance will be achieved:
Duke employees not assigned to McGuire's Mechanical Maintenance Department and/or Contract personnel coming in to support outage /non-outage related maintenance activities and who will be required to use station procedures will receive Mechanical Maintenance Orientation Training prior to performing maintenance activities. This training will be identified and scheduled as appropriate.
9 Training on the new Mechanical Maintenance Section 5.0 "Use of.
Procedures" will be targeted short term towards
- Mechanical Maintenance Supervision
- Mechanical Maintenance General Supervision
- Nuclear Section Manager
- Mechanical Maintenance Paployes Training and Qualification personnel
- Maintenance Engineering Services personnel Training for these personnel will be completed by July 5, 1989, prior to the 1989 Unit 2 Refueling Outage.
Training on the new Mechanical Maintenance Section 5.0 "Use of Procedures" will be targeted long term towards
- Mechanical Maintenance Technicians Training for these personnel will be completed by December 31,
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