ML15239A006
| ML15239A006 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, McGuire, 05000000 |
| Issue date: | 10/10/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| References | |
| NUDOCS 8610230093 | |
| Download: ML15239A006 (25) | |
See also: IR 05000269/1986002
Text
October 10, 1986
Duke Power Company
ATTN:
Mr. H. B. Tucker, Vice President
Nuclear Production Department
422 South Church Street
Charlotte, NC 28242
Gentlemen:
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP), REPORT
NOS. 50-269/86-02, 50-270/86-02, 50-287/86-02, 50-369/86-07,
AND 50-370/86-07
This letter refers to the NRC's SALP Board Reports for your Oconee and McGuire
facilities which were sent to you on June 19, 1986; our meeting of June 27, 1986,
where we discussed these reports; and your written comments dated July 25, 1986,
relative to the reports.
Your written comments concerned the conclusions reached by the SALP Board in the
functional areas of plant operations and fire protection at the McGuire facility.
I have carefully reviewed these comments and discussed with my staff the issues
you raised.
I have concluded that the rating of Category 3 is warranted in the area of plant
operations and is not changed.
My staff will be in contact to set up a meeting
with your staff in the Regional Office, the second week of December.
This is to
discuss your plans for improvement in this area.
The SALP Board had noted an
apparent positive trend and this observation appears to be justified by your
written comments.
It is noted that Duke does not consider that sufficient credit is given for
licensee-identified events.
10 CFR Part 2, Appendix C, the NRC Enforcement
Policy, does state the intent to give credit for licensee programs for detection,
correction and reporting of problems.
The general conditions which these
licensee-identified events must meet are that of a first time occurrence that was
identified through a licensee program or audit which was promptly corrected and
reported. The Region utilizes this guidance in a broad manner and if the event
was not self-disclosing, then credit is given and a violation is not written for
Severity Levels IV or V events.
However, all conditions must be met; not just
identification, but prompt, effective, corrective action and prompt reporting.
A review of the above-noted mitigating factors is completed prior to the issuance
of a Notice of Violation (NOV).
The reasons that an event does or does not
meet the mitigation criterion should be discussed at the exit interview or in
subsequent telephone calls.
I encourage you to respond at the time of response
to the NOV if you believe appropriate credit was not properly given.
6101
361o~~~oo93 0500
Duke Power Company
2
October 10, 1986
Your comments on Nuclear Service Water and system operability were reviewed and
further dialogue is anticipated.
We have reviewed your response, which requests the Category 3 rating in the fire
protection functional area at McGuire be reassessed and assigned a Category 2
rating. Based on this review, we have concluded for the reasons presented in
your July 25,
1986,
response that a Category 2 rating in the fire protection
functional area at McGuire is warranted.
Therefore,
on that basis, we have
revised the staff's analysis and the SALP Board's rating of this functional area
appropriately.
In addition, with respect to the fire protection program violations and devia
tions identified in the subject report, we consider these issues to be valid. It
is recognized that some of the various fire protection issues did occur prior to
the assessment period.
However, the NRC inspection effort and associated inspec
tion documentation with respect to these issues occurred during the subject
assessment period. It should also be noted that your response to Violation B in
the
subject report has been forwarded to the Office of Nuclear Reactor
Regulation (NRR)
for review,
and their review of this issue had not been
completed by the end of the subject assessment period.
Therefore, based on the
incomplete NRR review status, this issue is considered to be valid for the
subject assessment period.
Should you have any questions concerning this letter, we would be happy to meet
with you and discuss the matter further.
Sincerely,
ORIGINAL SIGED n
~L I.801 CiACE
J. Nelson Grace
Regional Administrator
Enclosure:
Appendix to Duke Power Company
McGuire Plant Units 1 and 2
SALP Board Report, Dated
June 19, 1986
cc w/encl:
fT L McConnell, Station Manager
14- 5Tuckman, Station Manager
Service List for McGuire
and Oconee
bcc w/encl:
(see Page 3)
Duke Power Company
3
October 10, 1986
bcc w/encl:
C irman Zech
Smissioner Roberts
Commissioner Asselstine
o6mmissioner Bernthal
Lfemmissioner Carr
JIHe- R. Denton, NRR
tJ--M. Taylor, IE
L-T E. Murley, RI
L-%G. Keppler, RIII
LAR D. Martin, RIV
L,< B. Martin, RV
[. -dA.
Axeirad, IE
LRecords Center, INPO
tRegion II Distribution List C
H-C Resident Inspectors, McGuire
and Oconee
D1ocument Control Desk
%State of North Carolina
IS-t-ate of South Carolina
v.- Clark
-. Pastis, NRR
O- Hood, NRR
A Herdt
T. Conlon
W.
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MErnst
10/A086
October 10, 1986
SERVICE LIST FOR McGUIRE AND OCONEE
Duke Power Company
Duke Power Company
ATTN: Mr. A. Carr
ATTN: Mr. William L. Porter
P. 0. Box 33189
P. 0. Box 33189
Charlotte, North Carolina 28242
Charlotte, North Carolina 28242
Duke Power Company
Honorable James M. Phinney
ATTN:
Mr. R. L. Gill
County Supervisor of Oconee County
Nuclear Production Department
Walhalla, South Carolina 28242
P.O. Box 33189
Charlotte, North Carolina 28242
U.S. Environmental Protection Agency
Region IV
Mr. C. D. Markham
Regional Radiation Representative
Power Systems Division
345 Courtland Street, N. E.
Westinghouse Electric Corporation
Atlanta, Georgia 30308
P.O. Box 355
Pittsburgh, Pennsylvania 15230
Mr. Robert B. Borsum
Babcock and Wilcox Company
J. Michael McGarry, III, Esq.
Nuclear Power Generation Division
Bishop, Liberman, Cook, Purcell
Suite 220, 7910 Woodmont Avenue
and Reynolds
Bethesda, Maryland 20814
1200 Seventeenth Street, N.W.
Washington, D. C. 20036
Manager, LIS
NUS Corporation
Mr. L. L. Williams
2536 Countryside Boulevard
Operating Plants Projects
Clearwater, Florida 33515
Regional Manager
Westinghouse Electric
Office of Intergovernmental
Corporation -
R&D 701
Relations
P.O. Box 2728
116 West Jones Street
Pittsburgh, Pennsylvania 15230
Raleigh, North Carolina 27603
Mr. Dayne H. Brown, Chief
Mr. Heyward G. Shealy, Chief
Radiation Protection Branch
Bureau of Radiological Health
Division of Facility Services
South Carolina Dept. of Health
Department of Human Resources
and Environmental Control
P. 0. Box 12200
2600 Bull Street
Raleigh, North Carolina 27605
Columbia, South Carolina 29201
Saluda River Electric Cooperative,
Inc.
P. 0. Box 929
Laurens, SC
29360
October 10, 1986
ENCLOSURE
APPENDIX TO DUKE POWER COMPANY
MCGUIRE PLANT
UNITS 1 & 2
SALP BOARD REPORT
Dated June 19, 1986
October 10, 1986
1. Meeting Summary
A. A meeting was held at 1:00 p.m.
on June 27,
1986, at Duke Power
Company's Charlotte, North Carolina Corporate office to discuss the
SALP Board Report for the McGuire and Oconee facilities.
B.
Licensee Attendees:
D. W. Boot, President, Duke Power Company (DPC)
W. H. Owen, Executive Vice President, Engineering, Construction and
Production, DPC
H. B. Tucker, Vice President Nuclear Production, DPC
R. C. Futrell, Manager, Nuclear Safety Assurance, DPC
G. W. Hallman, Manager, Nuclear Maintenance, DPC
T. B. Owen, Superintendent, Maintenance, Oconeee Nuclear Station
M. Geddi, Manager, Nuclear Operations
R. Wilkinson, Manager, Nuclear Reliability Assurance
T. L. McConnell, Manager, McGuire Nuclear Station
L. R. Davison, Duke QA, Charlotte
G. W. Grier, Corporate QA Manager
M. D. McIntosh, General Manager Nuclear Support
J. 0. Barbour, QA Manager, Operations
R. B. Prior, Vice President, Design Engineering
R. L. Gill, Licensing, McGuire
R. L. Dick, Vice President, Construction
J. E. Smith, Assistant to Vice President Nuclear Production
J. D. Houston, Manager, CNS
N. McCraw, Compliance Engineer, McGuire
P. Guill, Duke/NPO-Licensing
C. NRC Attendees:
J. N. Grace, Regional Administrator, RII
V. L. Brownlee, Branch Chief, Reactor-Projects Branch 3, Division of
Reactor Projects (DRP), RII
D. Hood, Project Manager, PWR Licensing Division-A, NRR
T. A. Peebles, Chief, Reactor Projects Section 3A, DRP
W. T. Orders, Senior Resident Inspector, McGuire
J. C. Bryant, Senior Resident Inspector, Oconee-B
R
H. N. Pastis, Oconee Project Manager, PWR Licensing Division-B
R
G. E. Edison, Project Directorate No. 6, PWR Licensing Division-B, NRR
A. F. Gibson, Director, Division of Reactor Safety, RII
October 10, 1986
II. ERRATA SHEET -
MCGUIRE SALP
Page
Line
Now Reads
Should Read
15
14
... maintain the SSS fully
... maintain the SSS fully
operational.
operational. In response
to this violation, the
licensee administratively
implemented the standby
shutdown system technical
specifications in August
of 1984.
15
22
... to NRR for review and
... to NRR for information.
approval. Several...
Two items were considered
more...
15
23
... significant...
...significant:
1) the
SSS cabling associated with
the valve operators for
the Unit 1 turbine-driven
auxiliary feedwater suction
valves was located in the
same fire area (Unit 1 Pipe
Chase and Mechanical
Penetration Room) as
redundant Unit 1 changing
pump cables; and 2) control
cables for both redundant
trains of charging pumps
interacted with control
and power cabling for the
SSS in the "B" train
switchgear room. These
items were not provided
with the required fire
protection features,
i.e., either the SSS or
normal shutdown train was
not enclosed within a
three-hour fire barrier.
This item was identified
as a violation.
The
actions to correct these
licensee-identified viola
tions were fully imple
mented by September 28,
1984.
Basis for Changes:
Reworded for clarity.
October 10, 1986
Page
Line
Now Reads
Should Read
16
6
...as a deviation. Procedures
..
as a deviation and the
for the maintenance and testing
licensee corrected this
of the emergency lighting units
discrepancy prior to
were available, but were con-
completion of the
sidered inadequate. The
September 1984 Appendix R
licensee committed to revise
inspection. Procedures
the procedures to address the
for the maintenance and
inspectors' concerns.
testing of the 8-hour
emergency lighting units
were available, but were
considered inadequate.
However, the licensee
committed to revise the
procedure to address the
inspectors' concerns.
16
26
...
requirements was somewhat
..
requrements was some
deficient. The SSS was not
what weak initially. This
maintained operational after
was demonstrated by the
turnover to the operational
fact that prior to this
group and a number of other
assessment period, the SSS
plant areas did not meet the
was not maintained opera
Appendix R requirements. The
tional after turnover to
licensee's approach to resolu-
the operational group and
tion of technical fire protec-
a number of plant areas
tion issues indicates an
did not meet the Appendix R
apparent understanding of the
requirements. However,
Appendix R requirements. The
after the licensee recognized
responsiveness .
.
.
the Appendix R concerns
management's Involvement
improved. In addition,
the licensee's approach to
resolution of technical
fire protection issues
indicates an apparent
understanding of the
Appendix R requirements.
The responses .cne
Basis for Changes:
Reworded for clarity.
17
29
3
2
Basis for Change: To reflect the change in the rating of the Fire Protection
area from Category 3 to Category 2. This change was established by the Region II
Regional Administrator based upon a review of licensee comments and discussion
with the NRC staff.
Enclosure 2
15
engine for the SSS emergency generator was out of service on
several occasions.
Surveillance tests on the Unit 1 standb
makeup pump, which is part of the SSS and provides reactor coo ant
system makeup should the normal charging system be unavail
le,
were not conducted between April 1983 and April 1984.
Th boron
water supply to the Unit 2 standby makeup pump was not
erified
for the correct boron
concentration between
March
84 and
September 1984. Surveillance procedure tests for por ons of the
SSS emergency diesel generator were
not availabl
and not
implemented until after September 1984.
Several of the SSS
instrumentation devices for the Unit 1 portion o
the SSS remote
shutdown panel were not properly calibrated.
hese items were
identified as examples of a violation involv* g the failure to
maintain the SSS fully operational.
The inspection also identified a number of areas in which the
licensee failed
to meet Appendix R.
Also,
the
licensee
immediately prior to the Region II in ection identified a number
of items at McGuire which did not
et the Appendix R require
ments. Some of these items are co
idered minor and the licensee
has submitted a deviation reques
with appropriate justification
to
for review
and
appro
1.
Several items were more
significant and the licensee
ook action to correct the discre
pancies.
Cabling to the v
ve operators for the SSS Unit 1
turbine driven auxiliary
edwater pump suction valves in one
plant area and the contro cables for both trains of charging and
auxiliary feedwater sy4 ms in another plant area were in the same
fire area as the re
ant shutdown component cables. These were
not provided with
e required fire protection features, i.e.
either the SSS or# rmal shutdown train was not enclosed within a
three hour fire
rier. This item was identified as a violation.
The
shutdow
elated circuits were reviewed and due to the
availability of the SSS were found to meet the NRC associated
circuits c
cerns for common bus,
spurious signal
and common
enclosure
A revi w of the plant operational procedures identified a number
of c cerns, which were addressed by the Region II Confirmation of
Act'on letter that was sent to Duke on October 9, 1984.
The
I' ensee promptly revised the procedures to address the inspectors
oncerns. A review of the licensee's program indicated that a
well organized, detailed and comprehensive training program was
implemented for the operation and
use of the SSS using the
available procedures.
Also, fire damage control procedures were provided to identify
components needed for cold shutdown and the required restoration
if
any component or associated cabling is damaged by fire.
The
equipment and cabling required by these procedures are controlled
and well maintained-
Enclosure 2
15
engine for the SSS emergency generator was out of service on
several occasions.
Surveillance tests on the Unit 1 standby
makeup pump, which is part of the SSS and provides reactor coolant
system makeup should the normal charging system be-unavailable,
were not conducted between April 1983 and April 1984.
The boron
water supply to the Unit 2 standby makeup pump was not verified
for the correct boron concentration between
March 1984
and
September 1984. Surveillance procedure tests for portions of the
SSS emergency diesel generator were not available and not imple
mented until after September 1984.
Several of the SSS instru
mentation devices for the Unit 1 portion of the SSS
remote
shutdown panel were not properly calibrated.
These items were
identified as examples of a violation involving the failure to
maintain the
SSS fully operational.
In response to this
violation, the licensee administratively implemented the standby
shutdown system technical specifications in August of 1984.
The inspection also identified a number of areas in which the
licensee failed to meet Appendix R. Also,
the
licensee
immediately prior to the Region II inspection identified a number
of items at McGuire which did not meet the Appendix R require
ments. Some of these items are considered minor and the licensee
has submitted a deviation request with appropriate justification
to NRR for information. Two items were considered more signifi
cant:
1) the SSS cabling associated with the valve operators for
the Unit 1 turbine driven auxiliary feedwater suction valves was
located in the same fire area (Unit 1 Pipe Chase and Mechanical
Penetration Room)
as redundant Unit 1 charging pump cables; and
2) control cables for both redundant trains of charging pumps and
auxiliary feedwater interacted with control and power cabling for
the SSS in the "B" train switchgear room.
These items were not
provided with the required fire protection features, i.e., either
the SSS or normal shutdown train was not enclosed within a three
hour fire barrier.
This item was identified as a violation.
The
actions to correct these licensee identified violations were fully
implemented by September 28, 1984.
The
shutdown related circuits were reviewed and due to the
availability of the SSS were found to meet the NRC associated
circuits concerns for common bus,
spurious signal and common
enclosure.
A review of the plant operational procedures identified a number
of concerns, which were addressed by the Region II Confirmation of
Action letter that was sent to Duke on October 9, 1984.
The
licensee promptly revised the procedures to address the inspectors
concerns.
A review of the licensee's program indicated that a
well organized, detailed and comprehensive training program was
implemented for the operation and use of the SSS using the
available procedures.
Also, fire damage control procedures were provided to identify
components needed for cold shutdown and the required restoration
if any component or associated cabling is damaged by fire.
The
equipment and cabling required by these procedures are controlled
and well maintained.
Enclosure 2
16
Eight hour emergency lighting units are provided to mee
the
requirements of Appendix R Section III.J, except for por
ons of
the plant in which the licensee has committed to use
attery
powered hand lights.
However, these hand lights
ere not
available at the beginning of the inspection. This w s identified
as a deviation. Procedures for the maintenance and esting of the
emergency lighting units were available, but w e considered
inadequate. The licensee committed to revise t
procedures to
address the inspectors' concerns.
Communications between the various areas o
the plant in which
local control actions must be taken dur g shutdown operations
using the SSS were deficient.
The lic see has committed to
provide portable radios for use when the
SSS is required.
Portable radios were available, but
mmunications could not be
established between the local con
ol stations and the
facility due to transmission inter erences apparently caused by
plant structures. This was identified as a deviation item.
Based on a review of constr ction documents,
the inspectors
determined that the oil coll
tion system for the reactor coolant
pumps met the requirements f Appendix R, Section 111.0.
In general,
the manage
nt involvement and control in assuring
quality in the impleme tation of the Appendix R fire protection
requirements was som
hat deficient. The SSS was not maintained
operational after t nover to the operational group and a number
of other plant ar as did not meet the Appendix R requirements.
The licensee's a roach to resolution of technical fire protection
issues indicat
an apparent understanding of the Appendix R
requirements. The responsiveness to NRC initiatives are generally
timely, but
ave required repeated submittals on a few items to
obtain acc table resolutions. Fire protection related violations
periodica y occur but do not indicate a programmatic breakdown.
Correct' e action is normally timely and effective.
Licensee
identi ied fire protection related events or discrepancies are
prop ly analyzed, promptly reported and effective action taken.
ffing for the fire protection program is adequate to accomplish
c
e goals of the position within normal work hours.
Fire
4y protection staff positions are identified and authorities and
responsibilities are clearly defined.
Personnel
appear well
qualified for their assigned duties.
The following violations and deviations were identified:
a.
Severity Level III violation involving the failure to provide
the Appendix R Section III.G fire protection and separation
features required for redundant trains of normal
shutdown
system and the dedicated Standby Shutdown System components
'and cabling. (369/84-28)
Enclosure 2
16
Eight-hour emergency lighting units are provided to meet the
requirements of Appendix R Section III.J, except for portions of
the plant in which the licensee has committed to use battery
powered hand lights.
However,
these
hand lights were not
available at the beginning of the inspection.
This was identified
as a deviation and the licensee corrected this discrepancy prior
to completion of the September 1984 Apprendix R inspection.
Procedures for the maintenance and testing of the 8-hour emergency
lighting units were available, but were considered inadequate.
However,
the licensee committed to revise the procedures to
address the inspectors' concerns.
Communications between the various areas of the plant in which
local control actions must be taken during shutdown operations
using the SSS were deficient.
The licensee has committed to
provide portable radios for use when the SSS is required.
Portable radios were available, but communications could not be
established between the local control stations and the SSS
facility due to transmission interferences apparently caused by
plant structures. This was identified as a deviation item.
Based on a review of construction documents,
the inspectors
determined that the oil collection system for the reactor coolant
pumps met the requirements of Appendix R, Section 111.0.
In general,
the management involvement and control in assuring
quality in the implementation of the Appendix R fire protection
requirements was somewhat weak initially. This was demonstrated
by the fact that prior to this assessment period, the SSS was not
maintained operational after turnover to the operational group and
a number of plant areas did not meet the Appendix R requirements.
However,
after the licensee recognized the Appendix R concerns,
management's involvement improved. In addition, the licensee's
approach
to resolution of technical fire protection issues
indicates an apparent understanding of the Appendix R require
ments. The responses to NRC initiatives are generally timely, but
have required repeated submittals on a few items to obtain
acceptable resolutions.
Fire protection related violations
periodically occur but do not indicate a programmatic breakdown.
Corrective action is
normally timely and effective.
Licensee
identified fire protection related events or discrepancies are
properly analyzed, promptly reported and effective action taken.
Staffing for the fire protection program is adequate to accomplish
the goals of the position within normal
work hours.
Fire
protection staff positions are identified and authorities and
responsibilities are clearly defined.
Personnel
appear well
qualified for their assigned duties.
The following violations and deviations were identified:
a. Severity Level III violation involving the failure to provide
the Appendix R Section III.G fire protection and separation
features required for redundant trains of normal
shutdown
system and the dedicated Standby Shutdown System components
and cabling. (369/84-28)
Enclosure 2
17
b.
Severity Level IV violation involving the failure to rovide
structural steel fire barrier supports with a fire r sistant
rating equivalent to the fire resistant rating
f the
barrier. (369/84-28, 370/84-25)
C.
Severity Level IV violation involving the fail re to perform
periodic surveillance tests on the Standby
utdown System.
(369/84-20, 370/84-17)
d.
Severity Level IV violation for failure
o assure unlocked
fire doors were closed. (369/85-21, 37 /85-22)
e. Severity Level V violation for failu e to remove combustible
liquid penetrant materials from
control
access area.
(370/85-05)
f. Deviation
for the
failure t
provide adequate radio
communication capability betw en local control stations and
the Standby Shutdown Syst
control room.
(369/84-28,
370/84-25)
g. Deviation for the fail
e to provide battery powered hand
lanterns in the contro room for use in plant and yard areas
which do not have t
required eight hour battery powered
its.
(369/84-28, 370/84-25)
2.
Conclusion
Category:
3
3.
Board Recommenda on
The Board not s that a number of plant areas did not meet the 10
CFR Appendix
requirements during the SALP period. However, once
identified hey were properly analyzed and effective action taken.
No change n NRC inspection activity is recommended.
F.
Emergency Pr paredness
1. Anal sis
D ring the assessment period,
inspections were performed
by
egional
and resident inspection
staffs.
These
included
/
observation of two exercises, the conduct of two routine
inspections, and an emergency response facility appraisal.
Routine inspections and exercise evaluations indicated that the
onsite emergency
organization was effective in dealing with
simulated emergencies.
Adequate staffing of the emergency
response
facilities was demonstrated.
Corporate management
appeared to be committed to maintaining an effective emergency
Enclosure 2
17
b.
Severity Level IV violation involving the failure to provide
structural steel fire barrier supports with a fire resistant
rating equivalent to the fire resistant rating of the
barrier. (369/84-28, 370/84-25)
c.
Severity Level IV violation involving the failure to perform
periodic surveillance tests on the Standby Shutdown System.
(369/84-20, 370/84-17)
d.
Severity Level IV violation for failure to assure unlocked
fire doors were closed. (369/85-21, 370/85-22)
e. Severity Level V violation for failure to remove combustible
liquid penetrant materials from a control access area.
(370/85-05)
f. Deviation
for the failure to provide adequate
radio
communication capability between local control stations and
the Standby Shutdown System control room.
(369/84-28,
370/84-25)
g. Deviation for the failure to provide battery powered hand
lanterns in the control room for use in plant and yard areas
which do not have the required eight hour battery powered
emergency lighting units.
(369/84-28, 370/84-25)
2. Conclusion
Category:
2
3. Board Recommendation
The Board notes that a number of plant areas did not meet the 10
CFR Appendix R requirements during the SALP period. However, once
identified they were properly analyzed and effective action taken.
No change in NRC inspection activity is recommended.
F.
1. Analysis
During the assessment period,
inspections were performed by
regional
and
resident inspection
staffs.
These
included
observation of two exercises,
the conduct of two routine
inspections, and an emergency response facility appraisal.
Routine inspections and exercise evaluations indicated that the
onsite emergency organization was effective in dealing with
simulated emergencies.
Adequate staffing of the emergency
response facilities was demonstrated.
Corporate management
appeared to be committed to maintaining an effective emergency
October 10, 1986
III. Licensee Comments:
Licensee comments to the SALP report were provided in the letter from Duke
Power Company to J. Nelson Grace dated July 25, 1986, and are attached.
g
e
DUKE POWER COMPANY
P.O. BOX 33189
HARTrrE, N.C. 28248
BAL B. TUGER
TLPHN
Vamers
-
'-*
'
(704) 373-4601
July 25,
1986
Dr. J. Nelson Grace, Regional Administrator
U.S. Nuclear Regulatory Commission
Region II
101 Marietta Street, NW, Suite 2900
Atlanta, Georgia 30323
Re: IE Inspection Report Nos.
50-19/86-02
50-270/86-0
50-287/86-02
50-369/86-07
50-370/86-07
Dear Dr. Grace:
By letter dated June 19, 1986,
NRC transmitted the Systematic Assessment of
Licensee Performance (SALP)
report for Oconee and McGuire.
The period of as
sessment was September 1, 1984 through February 28, 1986. A meeting was held to
discuss this report on June 27, 1986.
Attached please find our comments on the evaluation. As requested, specific
comments have been made in response to the Category 3 rating in the plant oper
ations functional area at McGuire.
Also included are comments on the area of
McGuire Fire Protection, which was also rated Category 3.
Duke requests that a Category 2 rating be assigned to the McGuire Fire Protection
functional area. The fact that only two violations and one deviation are valid
for the entire report period and the fact that no fire protection specialists made
site inspections since September 1984 indicate a more favorable rating in this
area.
Duke believes that on the whole, this SALP adequately represents the quality of
performance at our stations with the notable exception of the characterization of
McGuire plant operations and fire protection.
Very truly yours,
Hal B. Tucker
RLG/74/jgm
Attachmen
nt
Dr. J. Nelson Grace
July 25, 1986
Page 2
xc: W.T. Orders
NRC Resident Inspector
McGuire Nuclear Station
J.C. Bryant
NRC Resident Inspector
Oconee Nuclear Station
Helen Pastis
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Darl Hood
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Page 1
ATTACHMENT I
DUKE POWER COMPANY
-
McGUIRE NUCLEAR STATION
RESPONSE TO SALP REPORT
DATED JUNE 19, 1986
1.
INTRODUCTION
Duke Power Company has reviewed the SALP Report for McGuire Nuclear Station
and, in general, endorses the observations and findings made in the report
regarding McGuire's performance.
Two functional areas of McGuire were rated
Category 3 -
Plant Operations and Fire Protection. NRC specifically
requested a response to the Category 3 rating in the plant operations
functional area. In addition, Duke is providing comments regarding the
Category 3 rating in the fire protection functional area.
2.
RESPONSE TO PREVIOUS SALP REPORT
The SALP Board review for the period May 1, 1983 through August 31, 1984
indicated the following major deficiencies in the Plant Operations functional
area:
1.
Excessive number of reactor trips caused by personnel error.
2.
Notable weakness in procedural compliance; specifically, failure to
follow and properly implement operations and administrative procedures.
3.
Excessive number of personnel errors by Instrument & Electrical
technicians.
4.
Failure to properly and fully implement independent verification of
operating activities.
Duke personnel undertook many actions to correct these deficiencies.
These
are as follows:
(A) "Human Factors" upgrade to I&E Critical Procedures
o In 1983 Biotechnology, Inc. was contracted to develop "Guidelines for the
Development of Nuclear Maintenance Procedures".
A manual was developed, for
the first time, and established a comprehensive guide for deVeloping
procedures. This manual was developed with "Human Factors" concept in mind.
o In 1983 an I&E procedure group was formed initially with two full time
technicians. This group now has three full time technicians and a
supervisor.
Page 2
o In 1984 General Physics was contracted to develop a training course for
procedure writers. To date this training has been given to a limited number
of personnel and has been budgeted for 1986 to train all personnel in I&E.
o During a procedure review conducted from October through December 1984, over
220 procedure changes were implemented requiring approximately 700 man-hours.
o In September 1984, a procedure validation program was implemented. This
program consisted of a team comprised of a design engineer experienced with
"Human Factors", a G.O. maintenance engineer and a I&E technician. The
validation program focused on procedures that were most critical to plant
safety and reliability. An average of one month is required to process one
procedure including rewrite with an estimated 300 man-hour effort.
o I&E management has stressed to all personnel that they are expected to follow
procedures as written and correct any procedures that are in error.
o Approximately 40 procedure changes per month are implemented to correct
procedure errors, revise information, include trouble shooting, broader scope
of testing, and improve procedures. Approximately four new procedures per
month are implemented to upgrade existing procedures, resolve deficiencies or
to include new equipment.
o An estimated 4 man-years will be required to rewrite the 7300 Process Pro
tection and Controliprocedures.
This will be implemented in the near future.
(B)
Independent Verification (IV)
Implementation
o A Nuclear Production Department (NPD) Directive was implemented to establish
"Department" standards on I.V.
o The Administrative Policy Manual (APM) was revised to include a definition of
I.V. and its use in station procedures.
oAn 1983 NPD management held meetings with all station employees concerning
I.V.
o Follow-up meetings were conducted by station management with all station
employees concerning I.V.
o Video tape presentation concerning I.V. and the proper use of station pro
cedures was shown to all station employees.
(C)
Personnel Error Follow-up
o During the months of June and July, 1985,
"Timeout" meetings were conducted
by the Station Manager with all station exempt employees (supervisors)
emphasizing the need to follow procedures and to take time to perform the
tasks correctly.
Page 3
o A letter, signed by the General Manager, Nuclear Stations, and by the Station
Manager, was given to each exempt employee in the above "Timeout" meeting and
explained. The letter clearly established our work philosophy at McGuire,
placing high quality, error free work and nuclear/personnel safety over and
above plant schedules. The letter was subsequently explained to the hourly
personnel by their immediate supervisor.
o In 1985, the average rate of personnel error LERs was 1.67/month. Through
April, 1986, the average rate is 0.75/month.
(D) Meetings with New Hourly Personnel
o Meetings are conducted by the NPD General Manager Nuclear Stations with new
hourly personnel emphasizing Operational Quality, Professionalism and
Procedural Compliance.
(E) Abnormal Plant Event Meetings
o Abnormal Plant Event Meetings were initiated in June 1984 to discuss the
plant events with station management, determine the root cause of the event
and to establish actions to preclude reoccurrence.
(F) Station Goals Established
o A station goal has been established to keep the reactor trip frequency at
least below the industry average and desirably to rank in the upper quartile
of all commercial units in operation for greater than 3 years.
o From August 31, 1984 to September 13, 1985, there have been two reactor trips
on Unit 1 and twelve on Unit 2. Of these trips, there were no personnel
error related trips on Unit 1 and only three trips on Unit 2 attributed to
Apersonnel error.
o From September 13, 1985 to May 16, 1986 there have been:
5 Reactor Trips on Unit 1
0 caused by NPD personnel error
0 caused by CMD/vendor personnel error
6 Reactor Trips on Unit 2
0 caused by NPD personnel error
1 caused by OMD/vendor personnel error
(G) Additional Followup Actions Taken (As of 5/16/86)
o On March 20, 1986, the Station Manager again encouraged strict adherence to
defined programs and directives.
Page 4
o The Station Manager met with all Line and Staff personnel on March 26, 1986
and discussed the following:
(1) The need to be very conservative and thorough in making operability
determinations.
(2) The urgent need to assure compliance with our Tech Spec Surveillance
requirements.
(3) The need for line supervision to observe and enforce strict adherence to
safety practices and station procedures.
In summary, Duke believes that positive results have been achieved as a result of
actions taken over the past two years at McGuire.
3.
PLANT OPERATIONS
The SALP Board noted a continued weakness in the plant operations functional
area. The basis for the Category 3 rating is the Board's concern about the
number of violations which occurred and particular concern that apparent
operational deficiencies associated with the nuclear service water system
would not have been promptly identified or corrected without NRC involvement.
Duke has prepared responses that are broken down into three areas: Reactor
Trips, Violations, and Nuclear Service Water System Operability. We believe
that while the Category 3 rating may have been justified, we do believe that
an improving trend is being observed. The actions taken in response to
events that occurred during the previous SALP report period are already
providing positive results. We believe that the SALP report should reflect
the positive trends in plant operations that occurred during the report
period.
Reacdor Trips
In a response to the previous SALP, Duke stated that a number of efforts were
underway to reduce the number of reactor trips at McGuire. It appears that based
upon a review of the number of trips that have occurred at McGuire, that positve
results are being obtained:
Number of Reactor Trips
1982
1983
1984
1985
1986*
McGuire Unit 1
16
15
5
5
2
McGuire Unit 2
--
11* *
18
11
2
- through 06/30/86
- -*McGuire Unit 2 was not commercial for full year.
Page 5
The cause breakdown for reactor trips is as follows:
1984
1985
1986*
Personnel Error
20%
6%
0%
Procedural Deficiency
20%
13%
25%
Component Failure
47%
69%
75%
Other
13%
13%
0%
- through 06/30/86
Violations
A portion of the basis for the Category 3 rating is the number of violations in
the plant operations functional area. The Board identified eleven violations and
one deviation in this area. Duke has reviewed the identified violations and notes
that of these eleven violations, Duke filed LER's in five instances where the
violation incident was identical to the reported incident and four instances where
the LER is identical to one or more of the multiple examples of incidents used to
support the violation. In all but two instances, NRC/RII responded to our viola
tion response, which referred to the previously submitted LER, by stating the
response was acceptable and the implementation of corrective actions would be
examined during future inspections.
In the other two instances, no response has
been received.
It is also noted that all of these violations are Level IV.
Duke considers that the NRC should give some credit for licensee identified
events. In this instance, it appears that a majority of the items cited were
licensee identified. These licensee identified items became cited violations
which then were used by NRC as a portion of the basis of the Category 3 rating.
Nuclear Service Water System
A major contributor to the Category 3 rating is the Duke response to the apparent
operational deficiencies associated with the nuclear service water system. The
dialoque between Duke and NRC on this concern has been extensive.
We do not
intend to raise all relevant facts previously provided to NRC. However, a few
comments are noteworthy.
Duke notes that on page 4 of the report, third paragraph, states that "extensive
interaction with NRC management transpired to agree upon the condition that
cross-connecting the two units'
RN systems was an unreviewed situation..."
On the
contrary, Duke did not agree that the situation was an unreviewed safety question.
We did agree to return the system to a normal lineup.
Page 6
The SALP report notes that extensive interaction between NRC and Duke occurred
during the SALP report period. In fact, such interactions continued through April
1986 and are still continuing. By letter dated June 27, 1986, NRC issued inspec
tion report 50-369/85-38 and 50-370/85-39 which identified several violations
relative to the nuclear service water system. As the report is under NRC review
for possible enforcement action, no response has been requested. Once the NRC
review is complete, Duke will respond appropriately.
NRC states in the SALP report that "prior to NRC involvement the licensee was not
vigilant with a program of performance monitoring of the RN system to detect early
signs of fouling."
Duke notes that McGuire was performing all technical specifi
cation surveillance requirements and monitoring in response to IE Bulletin 81-03.
Duke initiated efforts beyond regulatory requirements in inspecting the component
cooling heat exchangers beginning in late 1984 and in developing a Performance
Monitoring Program. While in hindsight, it might be concluded that Duke should
have been more vigilant, such actions were not indicated at the time of the early
events.
It appears that the fundamental concern identified by NRC is the determination of
system operability. This is evident through a review of several incidents at
McGuire, particularly the Auxiliary Building Ventilation concern and the operation
of McGuire Unit 2 with two valves open (NV-141, -142) and inoperable in addition
to the nuclear service water system concerns.
Throughout the past year, both Duke
and Region II Staff have had extensive discussion regarding operability. It is
Duke's position that to avoid numerous unnecessary transients on nuclear units, we
think it is responsible to maintain the option to expeditiously test before
declaring a system inoperable due to minor concerns. If we believe a system or
component is operable, but have concerns related to it, we will take whatever
actions are necessary, in a timely manner, to resolve the concerns and confirm
operability. These actions include additional testing, engineering calculations,
and inspections, as appropriate. However, if we believe that a system or compo
nent is not operable, Duke vill, as we have in the past, take actions as provided
in technical specifications and expeditiously correct the problem. On ten occa
sions during the SALP report period, McGuire units were either shutdown or held at
lessethan full power as a direct result of a system being inoperable in accordance
with' the requirements of technical specifications.
Duke is taking actions on two fronts to improve implementation of the operability
definition. First, Duke in concert with other interested utilities is actively
supporting an industry initiative to improve technical specifications. One of the
identified problem areas is the application of the definition of operability.
This area was identified by both the industry and by a report dated September 30,
1985 prepared by the Technical Specification Improvement Project of the NRC. Duke
continues to actively support resolution of this issue on an industry-generic
front.
Second, Duke is developing a department directive that will provide additional
guidance to all applicable personnel regarding operability concerns.
Page 7
This directive vill address the means by which a determination of operability or
inoperability for a structure, system, or component should be made. It will also
include examples, based on past experience where such determination has already
been made.
In the near future, Duke would be pleased to discuss this directive
with NRC Staff.
We believe that the process by which operability concerns are
addressed is an important issue in which agreement between NRC and industry is
needed.
4.
FIRE PROTECTION
A second Category 3 rating was provided by the Board in the Fire Protection
functional area. Duke disagrees with this rating on two counts. First, the
Board states that a number of plant areas did not meet the 10 CFR Appendix R
requirements during the SALP period.
On the contrary, nearly all items
listed as violations were corrected prior to or at the beginning of the
report period.
Second, a Category 3 rating indicates that both NRC and
licensee attention should be increased. However, it is noted that Duke has
maintained a high level of attention to Fire Protection at McGuire while NRC
has reduced its attention.
We agree that' such a reduced level of NRC atten
tion is acceptable for McGuire and request a Category 2 rating.
With respect to the number of areas that did not meet the 10 CFR 50 Appendix
R requirements during the SALP period, Duke has reviewed the five violations
and two deviations identified. Four items, as discussed below, were in
compliance for essentially the entire SALP period.
(Item identification is the same as in the SALP report):
A.
Response:
The Level III Violation was identified and corrected by Duke
prior to the SALP Report period. Full compliance (including final
documentation) was completed by September 28, 1984.
B.
Response:
This issue is still under review. A meeting was held with
Region II and ONRR on June 10, 1986 to discuss. As a result, there is
indication that the violation will be withdrawn upon receipt of addi
tional information for an ONRR review.
C.
Response: Although identified during the period on the report, noncom
pliance was for past events.
The Standby Shutdown System Technical
Specification which resolved this issue was implemented administratively
in August, 1984.
G.
Response:
The noncompliance for the battery powered lights was identi
fied and corrected during the September, 1984 inspection.
For the remaining three items, D, E, and F, Duke considers these to be the
only examples that "did not meet the 10 CFR Appendix R requirements during
Sthe SALP period".
Page 8
Considering the mitigating circumstances as stated above, it would seem that
a Category 3 rating was not warranted. Additionally, since items D, E, and F
were cited in September 1984, February 1985, and April 1985, respectively, an
improving trend should be noted in the SALP report.
In summary, Duke requests that a Category 2 rating be assigned to the McGuire
Fire Protection functional area. The fact that only two violations and one
deviation are valid for the entire report period and the fact that no fire
protection inspections have occurred since September 1984 indicate a more
favorable rating in this area.