ML19350C899
| ML19350C899 | |
| Person / Time | |
|---|---|
| Site: | McGuire  |
| Issue date: | 03/25/1981 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19350C897 | List: |
| References | |
| NUDOCS 8104100139 | |
| Download: ML19350C899 (4) | |
Text
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.'S,.Dd55IFObH COMPANY
' Pow $a Bun.orwo qV 422 Socin Cauncu Srazzi, CnAarortz, N. C, asa4a
- i I * '.3, 3 wlLLIAM O. PARM ER, JR, ss'. Pa March 25, 1981
'"'~ '$^,"3.".ol3 o c io Mr. James P. O'Reilly, Director U.S. Nuclear Regulatory Coinnission
' Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370
Reference:
RII:TJD 50-369/81-03
Dear Mr. O'Reilly:
Please find attached a response to infractions 81-03-04, 81-03-05 and 81-03-07 vhich were identified in the above referenced inspection reports. Duke Power Company does not consider any information contained in this rei. ort to be pro-prietary.
I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge.
V y truly yours O '
- /l.
William O. Parker, Jr.
RWO:pw Attachment l
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810.4100
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o MCGUIRE NUCLEAR STATION RESPONSE TO IE INSPECTION REPORT 50-369/81-03 A.
Technical Specification 6.8.1 requires. in part that tiritten procedures be established, implemented, and maintained for surveillance activities of safety-related equipment. Technical Specification 4.9.4.1 requires in parr that each containment penetration providing direct access from the contain-ment atmosphere to the outside atmosphere be verified closed or exhausting through the containment purge and ventilation systen within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of core alterations.
Contrary to the above, prior to January 30, 1981, no written procedure existed to verify containment integrity during core alterations, and none was bnplemented prior to start of core alterations on January 28, 1981.
Response
1.
Prior to January 30, 1981, no written procedure existed to verify contain-ment integrity during core alterations, and none was implemented prior to start of core alterations on January 28, 1981.
2.
The initial fuel loading procedure did not contain a valve checklist and no periodic test existed to insure that containment isolation valves necessary for Mode 6 were verified closed.
3.
PT/1/A/4200/02C was written to verify containment integrity. This periodic test was performed at 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> intervals by Operations perscenel and verified complete at each shift change by the Reactor Engineer in charge of fuel loading for that shift.
4.
Periodic
- ocedures for verifying containment integrity for Modes 1 through !
_aen written prior to the incident.
5.
It is felt that the station is presently in full compliance.
B.
Technical Specifications 3.9.4.c requires that during core alterations, containment penetrations providing direct access from the containment atmosphere to the outside atmosphere be closed by an isolation valve, blind flange, or manual valve, or be exhausting through operable Contain-ment Purge and Ventilation System, REPA filters, and charcoal absorbers.
Contrary to the above, on January 30, 1981, Valves 1-VX-40 and 1-VX-41, containment air sample line valves were found open, and the pipe cap was not in place.
Response
1.
On January 30, 1981, Valves 1-VX-40 and IVX-41, containment air sample 3
line valves, were found open with their pipe caps not in place.
2.
The initial fuel loading procedure did not contain a valve checklist and I
no periodic test existed to insure that containment isolation valves necessary for Mode 6 were verified closed.
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3.
PT/1/A/4200/02C wra written to varify th:t containment integrity w s established. While performing this PT, a nuclear equipment operator (NEO) discovered VX-41 and VX-40 were open. The NEO closed VX-41 and locked closed VX-40.
4.
Periodic test procedures for verifying containment integrity for Modes 1 through 5 had been written prior to the incident.
5.
It is felt that the station is now in full compliance.
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C.
10 CFR 50 App:ndix B Crit:rion V rcquirco that cetivitico chall be cecompliched in accordance with instructions. Design Engineering Quality Assurance Manual in section HPR-130, " Mechanical System / Restraint Design Drawings, Field Re-visions" specifies in paragraph 2.3 and 3.2 the process by which field re-visions to structural restraint design drawings are to be made.
Centrary to the above, Design Engineering issued structural restraint draw-ing MC-AA-3730 (RO) for restraint R10 of MC 1683-VI.22 with the notation "No Structural or Hardware Changes between MC-1683-VI.22-R10 (R6) and MC-AA-3730 (RO)" when in fact an additional sway bar had been added.
Response
1.
The Notice of Violation addresses an error by a design engineer whereby "No Structural Change" was documented on the Construction Department Record Copy of support / restraint drawing MC-AA-3730 (RO).
2.
This drawing defines a unique support / restraint design for location RIO on piping isometric MC 1683-VI.22. The support / restraint was installed based upon a " Typical" (generic) design but required a hardware change. The hard-ware change required issuance of the design using a unique drawing.
The engineer did not observe that a hardware change had been made on the unique drawing and, to expedite Construction and QC completion, he documented "No Structural Change".
In addition to the design error, Design Engineering workplace procedure MCSRD 5.0 was violated by not having such Record Copy additions documented with two design engineer signatures.
This occurrence, including reportability evaluation, was documented in Design Engineering Design Nonconformance DNC-0009 and Construction Nonconforming Item Report 12727. The support / restraint design was altered to increase the con-crete expansion anchor factor of safety to 4.0 or greater for IEB 79-02 com-pliance. Detailed engineering evaluation, removing conservatisms in load definition and design analysis, showed that the existing installed design (without the structural change) had a safety factor above 4.0.
Hence, the installed configuration was adequate. Generically, there are few situations where Typical designs have been converted to unique designs. A sample review of 396 candidate designs were reviewed for similar situation and problem.
Only 13 designs were Revision 0 unique designs which were converted from previously existing Typical designs.
No reoccurrence of the documentation problem ("No Structural Change") was f ound.
3.
The following corrective actions were defined:
1)
Construction Nonconforming Item Report 12727 was resolved by correct-ing the Record Copy drawing and performing the craft and inspection work. required.
- 2) Design Nonconformance DNC-0009 was resolved by completing specific and generic evaluations noted above and_by counseling the individual involved in proper review and documentation procedures.
4.
Since the item represented an isolated incident, no programmatic changes were deemed necessary.
5.
These corrective actions were completed prior to start of fuel loading on January 28, 1981.
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