ML20010F202
| ML20010F202 | |
| Person / Time | |
|---|---|
| Site: | McGuire  |
| Issue date: | 08/07/1981 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20010F195 | List: |
| References | |
| NUDOCS 8109090491 | |
| Download: ML20010F202 (5) | |
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l DUKE POWER COMPANY
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Powen licammo 422 Sourn Cnuncu Srnent, CnAnwit z, N. G. caa42 2
0 I /i!!C 10 All 10 f f'. y wlLLIAM O. PARMER, JR.
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y, Anta 704 Wer PersiorNT 6,.
373 4083 STCAM PaoovCtION
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August 7, 1981e Mr. James P. O'Reilly, Director U.S. Nuclear Regulatory Commission Region II I
101 Marietta Street, Suite 3100 Atlanta, CA 30303 l
Subject:
McGuire Nuclear Station Dockett Nos. 50-369 Re: RII: MJG l
50-369/81-15 l
Dear Mr. O'Reilly:
Please find attached a response to violations 50-369/81-15-01, 50-369/81-15-02, and 50-369/Gl-15-03 which were identified in the above referenced inspection re-port. Duke Power Company does not consider any information contained in this report to be proprietary.
l I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge.
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Ver truly yours, 1
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' William O. Parker, Jr.
PBN/nsp Attachment l
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s McGUIRE LJCLEAR STATION RESP 0F?E TO IE' INSPECTION REPORT 50-369/81-15 Violation:
50-369/81-15-01, Severity Level V:
10 CFR 50, Appendix B,. Criterion V, an implimented by Duke Power Company Topical-Report,-Quality Auscrame Program, part 17.2.5 requires that activities affecting quality shall oc prescribed by written approved procedures and that the procedures shall be followed. Technical Specification 3.0.* requires that entry into an Operational Mode or other specified condition shall not be mado unless the con-ditions of the limiting conditions for Operations are met without reliance or provD,lons contained in the Action Statements. McGuire Nuclear Station Direc-tive 3.1.4, Conduct of Operations, requires in part that "The Shift Supervisor...
must be cognizant of all operational conditions affecting the safety of the plant... (and)... of all maintenance activities affecting plant operation being performed while he is on duty".
C Contrary to technical specification requirement 3.0.4, on May 8, 1981, while the plant was in an Action Statement due to an inoperable decay beat removal train, the reactor vessel head was torqued down thus changing plant status from Mode (
to Mode 5.
Contrary to Station Directives 3.1.4,;the shift superviso and cc'erol room staff for more than three hours were unaware that maintenance activities in progress had taken the plant from Mode 6 to Mode 5.
Response
1.
On May 8, 1981, the reactor vessel head was torqued down changing plant status from Mode 6 to Mode 5.
At this time, the plant was in an Action Statement due to an inoperable decay heat removal train.
2.
Operations personnel were not fully aware that the head tensioning was complete and did not take the steps necessary to p. event entering Mode 5 without having both decay heat removal trains operable.
In addition, there were no procedures indicating which prerequisites must be met prior to etering Mode 5.
3.
An operating procedure has been written to verify that pr erequsites art met prior to entering tbde 5 from Mode 6.
The bbintenance Procedure" Reactor Vessel Head Removal and Replacement", has been revised 'to require a sign-off by the shif t supervisor prior to tensioning or detensioning the head.
4.
A start-up procedure which outlines the steps necessary to take.the plant from a cold shut down (Mode 5) to 15% full power (Mode 1) had been written prior to the incident.
5.
The station is presently in full compliance.
Violation:
50-369/81-15-02, Severity Level V:
10 CFR 50, Appendix B, Criterion V, as implemented by Duke Power Company Topical Report, Ouality Assurance Drogram, 17.2.5 requires that adequate written, approved procpdures be established, implemented and maintained concerning activities per-taining to safety-related equipment.
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Contrary to the above requirements, on March 30 and April 29, 1981, licensee per-sonnel did not employ.a procedure during maintenance and operation of a solid state protection system.
This resulted in three inadvertent safety injections initia-tions. Also, a review of the applicabic procedures, IP/0/A/3010/07 and AP/1/A/5500/
35 do not appear to provide adequate information to preclude the occurrences had they been used.
Response
1.
On March 30 and April 29, 1981, three inadvertent safety injections were caused by station personnel failing to use a procedure during maintenance and operation of-the solfa 9 tate protection system (SSPS).
2.
During maintenance of the SSPS certain safety injection permissive blocks were cleared from the Train A SSPS logic. When the system was returned to service without the signals blocked a safety injection was initiated.. Personnel should have verified that the blocks were properly inserted before the cabinets were returned to service.
3.
Station management met with the individuals involved stressing the severity of the incidents and the absolute necessity.of following procedures.
To prevent a re-occurrence of this type of incident all procedures governing work (either testing or maintenance on the SSPS) ware revised to include specific steps detailing the proper method of returning the system to service. Each of the steps include a sign off for the technician. The steps concerning the permissive block invertions includes a sign off for the control operator as well as the technician.
Additionally the 0, eration procedure, ECCS Actuation during plant shutdown, was modified to include inserting the permissive blocks as a part of the recovery proces".
4.
All planned corrective actions have been imalemented.
5.
The station is presently in full compliance.
Violation:
50-369/81-15-03, Severity Level V:
Technical Specification 6.8.1 requires that written procedures be established, im-plemented and maintained for safety-related activities, including administrative control of safety-related equipment.
l Contrary to the above, on April 24, 1981, the waste monitor tank discharge flow monitor required by Technical Specifications 3.3.3.8 was removed from service for calibration without executing procedure OP/0/B/6200/44.
Radwaste Chemistry Pro-cedure for Component Removal from and Restoration to Service. Procedure OP/0/A/
6100/09, Removal and Restoration of Station Equipment was inadequately implemented in that the flow ~ monitor was incerrectly identified as not safety-related, there-fore the portions of the procedure for safety-related equipment were not implemented, and the subsystcm was not removed from service. As a result, a discharge from the waste rantior tank was initiated without the knowledge that the system was operable only wi th compliance with the Action Statement.
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Response
1._ On April 24, 1981, the waste monitor tank discharge flow monitor required by Technical Specification 3.3.3.8 was removed from service for calibration with-out executing procedure 02/0/B/6200/44, Radwaste Chemistry Procedure for Component Removal from and Restoration to Service. As a result, a discharge from the waste monitor tank was initiated without the knowledge that the system was operable only with compliance with the Action statement.
Contrary to statements in the Notice of Violation, this flow monitor, while Technical Specification related, is not a safety related piece of equipment.
2.
On January 21, 1981, a work request was written to implement a modificatian requiring the installation of a Foxboro 557 square root extractor to the transmitters of the flow rate measurement device on each waste monitor tank f A" and "B").
The flow gauges and the chart recorder. were to be changed from logarithmic to linear scales.
This work was in progress prior to the date of the occurrence but it did not hamper the operability of the liquid waste disposal system.
The planning section issued preventive maintenance work requests to perform the regularly scheduled preventative maintenance / periodic testing (PM/PT) on both loops. They failed, however, to stipulate that clearance to begin the work was to be given only by a member of the Radwaste Chemistry group.
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This requirement was supposed to be incorporated into all preventive mainten-ance work requests involving radwaste systems.
l The supervisor responsible for performing this work, identified this problem l
and notified the radwaste supervisor.
It was agreed to perform the two PM/PT's l
following completion of the modification work request.
i Two technicians reporting to work on the evening shift.of April 24, 1981, l
found the two work requests laying on their supervisor's desk and decided to perform there PM/PI's. They received clearance to begin the work from the Shift j
supervisor on du'y.
They disconnected the flow transmitter for the waste monitor j
tank (WMT)-B pump discharge flow but were unable to complete the calibration l
because of the modification work in progress. They left the work area, but I
failed to reconnect the flow transmitter. Meanwhile, radwaste chemistry, unaware of the aforementioned work by the technicians, was making preparations to d!scharge WMT-B by radwaste procedure OP/0/B/6200/35, Revision.1.
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By procedure, the Health Physics technician monitored the liquid waste chart recorder; the radwaste technician operated the throttle valves; and the Nuclear Equipment Operator (NEO) started the pump. After the discharge was in'itiated the Health Physics technician informed the NE0 that the chart recorder indi j
l cated no flow. The operator immediately started back tracking the flow signal.
He checked the flow gauge at the panel to insure it was not isolated, and then went to the flow cransmitter root valves and found them open. Next, he traced the impulse lines to the flow transmitter and discovered that the valves at the equalizatioc block were closed. On further investigation he determined that the transmitter was isr. lated and being worked on.
The release was terminated and it was calculated that approximately 270 gallons of water had been discharged.
3.
The Radwaste Chemistry Procedor3 for discharge from the waste monitor tank has been revised to include verification of the operability of flow instru-i -
mentation required by Technical Specifications.
In addition, all preventive maintenance _ work requests involving radwaste systems have been changed to
require that clearance to begin work be given only by a member of the Radwaste Chemistry group.
!r:9 4.
Procedures governing the discharge of waste to the environment from all systems have been modified to include verification of the operability of flow instru-mentation required by Technical: Specifications.
5.
The station is presently in full compliance.
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