05000369/LER-1982-012, Forwards LER 82-012/03L-0.Detailed Event Analysis Encl

Forwards LER 82-012/03L-0.Detailed Event Analysis Encl

ML20049J500
Person / Time
Site:	McGuire
Issue date:	02/26/1982
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20049J501	List: 05000369/LER-1982-012, Forwards LER 82-012/03L-0.Detailed Event Analysis Encl 05000369/LER-1982-012-03, /03L-0:on 820119,routine QA Audit of Fire Protection Sys Test Found Three Valves Marked Not Accessible & Had Not Been Checked.Caused by Personnel Error.Periodic Test Performed & Valves Found in Correct Position
References
NUDOCS 8203180282
Download: ML20049J500 (3)

LER-1982-012, Forwards LER 82-012/03L-0.Detailed Event Analysis Encl

Event date:
Report date:
3691982012R00 - NRC Website

text

.

L.

DinI$%odr.nCoMiwxy Ptswru 15uimssq 422 S(>UT I Cucucu STuxET, Cil AHwTTE, N. C. 26M.!

J IMP S njg, 4 3 WILLIAM O. PAR M E R, J R.

February 26, 1982 Tra ~ e c:^aca

• m e.

..o s,... e.cox v.o m-4o s a Mr. James P. O'Reilly, Regional Administrator g

U. S. Nuclear Regulatory Commission

,9 Region II O) s 101 Marietta Street, Suite 3100 g

Atlanta, Georgia 30303 3

4 W D 171982r>-

L tw v 'umew )

Re: McGuire Nuclear Station Unit 1

ui.ac [

7,,8 f','

Docket No. 50-369 k'/ K[

Dear Mr. O'Reilly:

Please find attached Reportable Occurrence Report R0-369/82-12. This report concerns T.S.4.7.10.1, "The Fire Suppression Water System shall be demonstrated operable:...b. at least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position."

This incident was considered to be of no significance with respect to the health and safety of the public.

Very truly yours, t/

/

William O. Parker, Jr.

PBN/jfw Attachment cc: Director Records Center Office of tbnagement and Program Analysis Institute of Nuclear Power Operations U. S. Nuclear Regulatory Commission 1820 Water Place Washington, D. C.

20555 Atlanta, Georgia 30339 Mr. P. R. Bemis Senior Resident Inspector-NRC McGuire Nuclear Station 82O3180282 820226 PDR ADOCK 05000369 OFFICTAL cony S

ppg f

d [/ Sht lf f

DUKE POWER COMPANY McGUIRE NUCLEAR STATION REPORTABLE OCCURRENCE REPORT NO. 82-12 REPORT DATE: February 26, 1982 FACILITY: McGuire Unit 1, Cornelius, NC IDENTIFICATION: Failure to Meet Surveillance Requirement For Fire Protection System DISCUSSION: The January 19, 1982, routine quality assurance audit of the periodic test, " Fire Protection System Monthly Test", found discrepancies on the surveillance documentation for November and December, 1981. The completed system line-up verification sheets indicated that three. valves were "not acces-sible".

The purpose of this periodic test is to satisfy Technical Specification 4.7.10.1.b, which insures the fire suppression water (RF) system is operable every 31 days by verifying ite valves are in their correct positions.

It provides no exception for valves inaccessible due to high radiation fields. At the time of. discovery the unit was in mode one at 50% power. During the period since the valves were last verified on October 22, 1981, the unit had been at various power levels up to and including 100%, with outages from November 15 to November 25 and from December 2 to January 2.

The valves involved are located in the " midget hole", which is a room in the Auxiliary Building that adjoins the unit one reactor building.

Radiation levels here can.be.high in some loca-tions due to the nature of various process lines present. The valves involved have the following functions: Auxiliary Building Elevation 716 feet loop isola-tion, Auxiliary Building Elevation 733 feet hose station supply isolation, and supply to room 600 sprinkler system.

The position of these valves was not verified because Safety Assistant "A", who performed the periodic test in November and December, 1981, checked with Health Physics prior to inspecting the valves and was encouraged not to enter the area unless necessary. Radiation levels present would have resulted in an external dose probably less than approximately 5 mR.

Since the valves were inaccessible as determined by the safety assistant, "not accessible" was written on the test's data sheet, but was not noted on a discrepancy sheet. The Shift Supervisor was not notified that the surveillance requirement could not be met and that appli-cable action statements would have to be observed.. These mistakes are due to a lack of understanding of periodic testing fundamentals resulting from a lack of training received by the safety group. This incident is determined to be due to Personnel Error.

Immediate corrective action consisted of verifying the valves in their correct positions as documented by the periodic test. This was completed on January 22, with the valves found in their correct position.

EVALUATION: A basic misunderstanding of the significance of Technical Specifi-cation Surveillance Requirements for the RF system played a major role in this incident. When the safety assistant performing the test in November and December was told he should not enter the room unless necessary, he assumed the valves were inaccessible. This was not the case. The term " inaccessible" in the

~s Report No. 82-12 Page 2 Technical Specifications is interpreted by the station as meaning an individual would receive an external dose greater than approximately 100 mR.

Health physics estimates a dose of less than 5 mR would probably have been received while verifying these valves. L'nder extreme circumstances, it is possible a dose of 20 mR might have been received, which is not enough to justify calling the valves inaccessible. However, Technical Specification 4.7.10.1.b has no provisions for inaccessible valves. The safety assistant was relying on his memory and got this Technical Specification confused with Technical Specification 4.7.10.4.a (Fire Hose Stations).

It is important to understand the meaning of inaccessible in Technical Specifications to insure a surveillance requirement that has provi-sions for accessibility is not missed because the ALARA program discourages performing the surveillance.

Marking a particular surveillance item "not accessible" constituted changing the periodic test without initiating a procedure change form or without rewrit-ing and reapproving the test.

Discrepancies discovered in performing a periodic test must be listed on a discrepancy sheet and signed off as resolved by a station supervisory staff member within the group responsible prior to approving the procedure as completed.

Another important aspect of this incident was that the Shift Supervisor on duty when this missed surveillance was discovered was not notified to make a Techni-cal Specifications Action Items Logbook entry.

The RF system was technically inoperable because the 31 day surveillance of verifying the valves in their correct positions had not been done in approximately 90 days. The Technical Specification Action Statement requires steps to be taken at various times after the RF system is ieclared inoperable, and the mechanism to document when it is declared inoperable and when various actior.s are necessary is the Logbook. The Shift Supervisor should have been notified of the date and time the Quality Assurance Audit Group discovered the deficiencies in the periodic test. Accepted station practice dictates that the group responsible for the particular surveil-lance item is responsible for informing the Shift Supervisor.

SAFETY ANALYSIS

The valves involved were found locked open which is consistent with Technical Specifications. Thus, assuming they had not been both closed and later reopened without authorization between October 23 and January 22, the RF system was able to perform its design function if needed although the sur-veillance was not met.

It is significant that the valves are locked open.

It would take deliberate action on someone's part to close the valve because a key would have to be obtained and the lock removed before closing the valve. This eliminates the possibility that someone touring the Auxiliary Building would indiscriminately close the valve.

CORRECTIVE ACTION

Immediate corrective action was to begin performing the periodic test on January 21.

It was completed on January 22, with the valves found in their correct position. Training in the areas of Technical Specifi-cations and Station Directives requirements for periodic testing will be com-pleted by March 1.

Training coiering applicable station directives is currently being developed. Technical Specification requirements will be discussed by the station Projects and Licensing Engineer.