ML19332D555
| ML19332D555 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/27/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, IEIN-88-051, IEIN-88-51, NUDOCS 8912040140 | |
| Download: ML19332D555 (5) | |
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DuxE POWER Gonem l'.o. Itox 33180 ClLAltLOTTE, N.C. 28242 F
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m, tcp U.S Nuclear Regulatory Commission
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Document Control Desk Washington, D.C.
20555 L
Subject:
Duke Power Company McGuire Nuclear Station Docket Nos. 50-369 & 50-370 r
Mr. A. F. Gibson's-letter dated September 22, 1989 provided NRC inspection i
report numbers 50-369/89-15 and 50-370/89-15.
This report communicated to me 4
(.
the results of the NRC's inspection of the McGuire maintenance program con-ducted June 5 - 9 and June 19 - 23, 1989.
Even though this inspection identi-F fied no violations or deviations from NRC regulations, several weaknesses involving various aspects of our maintenance program and our communications with the NRC were found by the inspectors.
i.
The weakness involving accuracy of information furnished to the NRC was irolated to our May 8,1989 response to Generic Letter (GL) 88-14, and our Licensee Event Report (LER) 88-36, dated December 21, 1988.
Mr. Gibson's y
~ September 22 letter requested a written response addressing the actions I plan to take or have taken to ensure the quality of future submittals.
This letter constitutes my responsc.
LSeveral examples, as found'by your inspectors, of inaccuracies related to our
.GL 88-14 response and our LER #88-36 were documented in the inspection report.
j I will address each one of these specifically in the following paragraphs.
1.
Response to GL 88-14, dated May 8, 1989, Attachment 1. of our response to the generic letter provided details on air quality testing.
The statement is made that air quality testing is performed por a "recently written performance test procedure".
NRC inspectors found that testing was actually'done in accordance with special test procedure
-TT/0/A/9100/294 and the' referenced performance test procedure was not written as of this' inspection since potential acceptance criteria was not finalized ~
-until May 23, 1989.
In response, we have three types of performance test procedures. A "TT" is referred to as a special test procedure, a "1P" is referred to as a pre-opera-tional test procedure and a "PT" is referred to as a periodic test procedure, not performance test procedure.
It was not the intention to imply that the l
air quality testing done at McGuire was done under a "PT".
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- Additionally, it did not seem necessary to include the procedure number in the l
GL 88-14 response.
Therefore, the special test procedure, TT/0/9100/294, was
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in fact a "recently written performance test procedure".
Acceptance criteria and a periodic test procedure. PT/0/A/4453/04 are finall7ed and in place at
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this' time.
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I feel that this-incident was not a case of providing inaccurate information i
but was mostly due to a miscommunication between Duke personnel and NRC b
inspectors of the terminology we use in classifying our test procedures.
In the future I hope that these type of concerns can be resolved in discussions during daily exit briefs or through teleconferences.
2.
Response to GL 88-14, dated May 8, 1989, Attachment 2.
Two concerns were noted on the Preventative Maintenance review conducted by the station.
These concerns are listed on page 45 of the Maintenance Inspection Report.
1he first concern is covered in the following statement.
"These statements implied that the above " critical" A0V's are part of those valves listed in Attachment A.....
Instead, the 56 critical valves were selected from operability considerations and have no accident safety significance similar to Attachment A valves."
Response
Theoriginalsubmi$taltoGL88-14statesthatalistofapproximately56
" critical to operation" valves was selected for enhanced maintenance.
The list of 56 valves selected does include valves from Attachment A.
- However, the station response to this GL item does not reference Attachment A and therefore makes no implications in this regard.
This Attachment is only referenced in the section of the response addressing the Verification of the Instrument Air System design.
The finding also states that safety significance was not considered in the original response.
This appears to be a misunderstanding with respect to our definition of the term " critical to operation".
The valve list was developed from a larger listing of valves that included active, IE, blackout air & ESF valves.
Based on discussions between Operations, I&E and Design personnel the listing was reviewed and condensed to the valves we felt were most critical to operation of the plant.
The term
" operation" was not meant to imply no safety concerns were included in this
!z evaluation.
The valves included were the ones that the reviewers felt could W
not be adequately controlled by plant personnel in the event of an air supply problem.
The basis of this decision was to include valves whose failure could produce a direct reactor trip or cause a serious plant transient; thus, preventing needless challenging of plant safety systems.
It was felt that this approach did adequately consider safety significance and met the requirements of the GL.
Based on these observations it is felt that with respect to this; finding the response clearly stated the actions taken by the station end that these actions addressed the concerns of the GL.
The second concern is addressed in the following statement.
.... no clarification is included that regularly scheduled filter-regulator PMs were not in place as of this inspection for all valves listed on Attach-ment A."
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', Page 3
Response
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The response to GL 88-14 under the heading of "IAE Maintenance Practice Review" stated that 56 valves critical to operation were identified for enhanced Preventive Maintenance and a completion date of August 1, 1989 was given. Attachment A was not referenced in this section.
Based on the original submittal there was no implication that Attachment A valves would be included in the additional Preventative Maintenance Program.
It is felt that the submittal clearly communicated our program and that this program adequately addressed the concerns of the GL.
3.
Response to GL 88-14, dated May 8, 1989. Attachment 3.
! of our response to the generic letter provided details regarding j
the design verification of McGuire's instrument air system.
During the NRC maintenance team inspection at McGuire, inspectors identified discrepancies in our response regarding the correct capacity for compressors, dryers, and filters in the instrument air system.
After being advised of these dis-crepancies, I feel we acted promptly to clarify and ascertain the accuracy of these parameters. This was done at the plant site and our response was formally corrected in my letter dated June 15, 1989.
As mentioned in your inspection report, the NRC team was able to ascertain that no technical discrepancies were indicated by the above described inaccuracies.
This weakness was caused by personnel error.
The responsible engineer failed to supply the correct parameter values for this instrument air system equipment. Additionally, our subsequent review of the draft generic letter response document, done prior to submittal, failed to identify and correct the discrepancy.
In order to ensure the quality of future submittals, management has discussed this matter with affected personnel.
We have held a meeting to discuss and reemphasize the importance of ensuring accuracy of all information - including numerical data - that goes into our submittals.
Also, the importance of quality reviews of documents prior to submittal has been reemphasized.
In this regard, the station manager has sent a letter to the station's technical staff providing additional emphasis on the complete and accurate review of NRC submittals.
I feel we have an effective program in place to control the preparation and i
review of our submittal documents.
I feel the above incident is isolated in nature and further feel the reemphases we are taking will provide the appropriate level of corrective actions.
Another item discussed in this section of the inspection report involved testing the Main Steam Isolation Valves on loss of air.
At the time of the response to the Generic Letter we stated the MSIVs were verified by test to go to their fail safe position on loss of air.
The interpretation of " loss of air" was called into question. As a result of an NRC Information Notice, McGuire has changed the test methodology and resolved this question as further explained below.
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Information Notice (IN) 88-51 was addressed in May of 1989.
The IN involved plants which were using air assistance in closing MSIV's SM1,3,5,7.
We were using the non-safety air assist in our stroke time testing and not doing a
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fail safe test.
Design Engineering provided an operability statement which stated that the valves did not need air assist to close in the required 5 seconds.
(
Reference:
Duke Problem Investigation Report No. PIR 0-M89-0122)
These valves could not be tested on line.
Performance changed our valve testing procedures to ensure that the stroke timing was done without air assist.
When the valves were tested at the end of U2EC5, September 1989, they failed to close in 5 seconds without air assist.
(PIR 0-M89-0239) Design Engineering then seismically qualified the VI accumulator tanks and associated piping and performance leak tested the VI check valves which would be required to isolate the accumulators.
i The MSIV's are now stroke timed with the " seismically qualified" air assist.
4.
Emergency Procedures
' of our response to Generic letter 88-14 contained a discussion of our review of the loss of instrument air abnormal procedures for McGuire.
The maintenance team inspection report indicated no clar.fication was provided in our original generic letter response concerning problems associated with the VG/VI Station blackout header at McGuire.
The inspection report seems to question our statements on the validity of the loss of instrument air abnormal procedures, since subsequent revisions due to the VG/VI interface were not included.
This can be attributed to the fact that our original response to GL 88-14 was prepared prior to the January 20, 1989 date referenced for the procedure revisions.
Additionally, we feel the revisions made to AP/1 and 2/A/5500/22 in response to the VG/VI interface problem were conservative in nature.
This change was made to ascertain diesel generator operability at the time, not to correct a perceived procedural weakness.
We feel the validity of this procedure was not dependent on the inclusion of the January 20, 1989 revisions.
The VG/VI interface at McGuire was discussed with NRC officials in detail at an enforcement conference held at Region II headquarters on April 28, 1989.
We believe the description of the loss of instrument air procedure contained in our response to GL 88-14 is indeed accurate.
l 5.
LER 369/88-36 At the time this LER was submitted, December 21, 1988, the 125 psig figure was valid.
McGuire Operations personnel later determined that a less restricted l
pressure range was needed to allow sufficient operating flexibility.
Therefore, the pressure range for opening the valves was originally written as 105-130 psig.
This was later changed to 105 psig in the change to the AP that was written on January 20, 1989 and approved on January 30, 1989.
Operations personnel did not realize this procedure change would invalidate a commitmont made to the NRC in the December 21 LER 369/88-36.
Station management has I
cautioned personnel about the importance of maintaining compliance with commitments made to the NRC in any manner.
Also we are trying, in an informal manner, to use procedure margin notes to track the source (LER, Bulletin, GL,
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Inspection Response, Etc.) of commitments made to the NRC, Finally in the-future, our station safety review group (writers of the station LER;s) will try not to use specific values such as this whenever possible.
The LER was supplemented on' July 7,1989.
This revision corrected the dis-crepancies identified in the maintenance inspection report, i
We attempt to write our statements in a manner that will be clearly understood from the NRC perspective. We will continue this practice and the weaknesses i
identified will help us in this regard.
In addition, we strive to communicate clearly verbally.
We-are disappointed that the inspectors did not understand our intentions during the course of the inspection when these weaknesses were initially discussed.
In conclusion, I feel the actions we have taken,-as described above, will adequately address these weaknesses.
It is our goal to provide completely accurate submittals to the NRC. We welcome the NRC initiatives in this area and ask that all the weaknesses identified in this maintenance inspection report become items for followup action in future inspections.
Very truly yours, Wt H. B. Tucker Attachment-i 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 Hood U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.
20555 Mr. P. K. VanDoorn i
NRC Resident Inspector McGuire Nuclear Station i
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e iAediological Services, Inc.
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hurch Street W -08057 to the quality assurance inspection of packaging and transporta.
ies at Wastinghouse Radiological Services, Inc. conducted by Messrs.
d J. Jankovich of this Office and by Mr. J. Furia of the NRC Region 1 p22-25,1989.
Ied during the inspection and our findings are discussed in the en.
- t. -Four items of nonconformance with U.S. Nuclear Regulatory HRC)requirementswereidentifiedduringthecourseoftheinspec.
bnconformances are listed in item 4 of the inspection report. With e nonconformances, please provide, within 60 days from the date of written explanations or statements describing corrective actions, nned, the dates when the corrective actions will be completed, and en to preclude recurrence.
e with 10 CFR Section 2.790 of the Comission's regulations, a copy er and the enclosed inspection report will be placed in the NRC ent R:om.
ave any questiens about this inspection, we will be pleased to with you.
Sincerely, Original Signed by CagmES E. L'ACDON Charles E. MacDonald, Chief Transportation Branch Division of Safeguards (kdnas and Transportation, NMSS k[""$[ hC/67 eport.
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