ML20011D324
| ML20011D324 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/22/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8912260167 | |
| Download: ML20011D324 (5) | |
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Ikke Ibw Company flu B Take PO Bax33198 l'kr />rsident Charlotte, N C 28N2 Nuclear troduction (704)373 4511
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DUKEPOWER December 22, 1989 U. S. Nuclear Regulatory Commission Document Control Desk l
Washington, D.C.
20555 t
Subject McGuire Nuclear Station Docket Nos. 50-369, 370 Inspection Report Nos. 369, 370/89-31 Reply to a Notice of Violation Gentlemen:
Pursuant to 10CFR.201, please find attached Duko Power Cotepany's response to Violation 370/89-31-01 and 370/89-31-02 for the McGuire Nuclear Station.
i Should there be any questions concerning this matter, contact W. T. Byers at (70!.) 373-6194.
Very truly yours,
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Ital B. Tucker WTB144/lcs Attachment xc ' Mr. S. D. Ebneter Regional Administrator, Region II V. S.. Nuc3 ear Regulatory Commission 101 Marir,tta St., NW, Suite 2900 Atlantr., Georgia 30323 Mr. Da.1 llood U. S. Nt.nlear Regulatory Commission Of fice of Nuclear Reactor Regulation Washington, D. C. 20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station
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l8912260167 891222 1
PDR ADOCK 03000369-A Q-PDC
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l McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION Violation Technical Specification 6.8.1 requires that written procedures be established for the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of that Regulatory Guide specifies procedures be established for surveillance tests.
Contrary to the above, as of Septembar 5, 1989, Procedure pT/2/A/4208/02 (NS Valve Stroke Timing - Quarterly on Valve 2NS-18-A) was inadequate in that the procedure did not specify plant condition limitations or caution the operators of the On potential for overpressurizing low pressure systems.
September 5, 1989, valve 2NS-18-A was opened in accordance with that procedure, allowing an overpressuriration of "A" train of the containment spray system and a resulting spill of radioactive contaminated water into the auxiliary building.
This is a Severity Level IV violation applicable to Unit 2 only (Supplement I).
Response
1)
Admission or denial of the alleged violations:
McGuire admits the violation occurred as stated in (voluntary) LER 370/89-10, dated October 23, 1989.
2)
The reason for the violation:
The violation occurred due to personnel oversight.
The personnel reviewing the procedure were concentrating on possible valve alignments which could allow decay heat l
removal (ND) pump discharge pressure into another system.
I Additionally, personnel were concerned with assuring that air would not be introduced into the ND system potentially causing air binding of the pumps and a subsequent loss of ND pooling.
3)
The corrective steps which have been taken to avoid future violations:
i Personnel replaced the gasket on NS HX 2A on September 7, 1989.
Personnel successfully performed procedure PT/2/A/4208/01A, NS Pump 2A Performance Test.
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Procedure PT/2/A/4208/010A, Train 2A NS HX Heat Balance Test, was successfully performed.
Design Engineering performed a component by component analysis of the affected portion of the Unit 2 NS system.
This analysis is documented in calculations referenced in the resulting operability evaluation.
~ Procedures PT/l and 2/A/4208/02, NS Valve Stroke Timing-Quarterly were revised to require that one of the following conditions are met before stroke timing valve NS-18A or valve NS-1B:
1)
Valve ND-1, NC Loop C Discharge to ND System Isolation, and valve ND-2, NC Loop C Discharge to ND System Isolation are closed; OR 2)
NC system pressure is less than 100 psig.
The cover bolts on the replaced NS HX 2A gasket were I
overtorqued to 200 ft-lbs.
The affected portion of the NS system was successfully hydrostatically pressurized to 242 psi.
Operations personnel reviewed this incident with personnel involved and with all shift Supervisors.
Personnel checked the integrity and calibration of the affected NS field instrumentation.
Pressure gauge 2MNOPG5100 was-replaced and pressure switch 2MNSPS5080 was recalibrated.
A walkdown of the affected portion of the NS system was performed and no visible degradations was discovered.
Work requests have been written to overtorque NS HX 2B and Unit 1 NS HXs main gasket covers to 200 ft-lbs.
4)
The corrective steps which will be taken to avoid future violations:
1.
Procedures MP/0/A/7150/69, Containment Spray Heat Exchanger Cover Plate Gasket Removal, will be changed u
to increase the present torque value to 200 ft-lbs.
2.
Station and Design personnel will review ECCS valves and identify system conditions allowable for valve stroke timing and develop a program to produce a McGuire valve reference document for station use.
3.
Based on the results of item 2, Station personnel will upgrade appropriate valve stroke timing procedures.
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Operations personnel will review existing training to ensure that incidents described in PIRs and LERs are covered with appropriate operations personnel.
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Section 9.0 of procedure MP/0/A/7150/69, Containment Spray Heat Exchanger Cover Plate. Gasket Removal, will be changed to verify no external leakage during i
subsequent running of appropriate NS pump by Performance personnel after gasket replacement.
6.
Integrated Scheduling personnel will facilitate a l
r review to evaluate the possibility of balancing day / night refueling outage workload.
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The date when full compliance will be achieved:
Procedure changes from Item 3 will be an ongoing process.
The program under Item 2 will be in place and all corrective actions will be completed by April 1, 1990.
i violation i
10 CFR 50.72(b)(1)(ii)(A) and (B) require that the licensee shall notify the NRC as soon as practical and in all cases with one hour of the occurrence of any event that results in the nuclear power plant being:
1.
in a unanalyzed condition that significantly compromises plant safety, or 2.
in a condition that is outside the design basis of the plant.
Contrary to the above, on September 5, 1989, an event occurred on Unit 2 at 4:09 p.m.,
in which the "A" train of the containment i
spray system was accidentally pressurized to 324 psig which the system design pressure was 220 psig.
The NRC was not notified of the event within one hour as required.
This is a Severity Level IV violation applicable to Unit 2 only (Supplement I).
Response
1)
Admission or denial of the alleged violation:
McGuire denies the alleged violation.
10 CFR 50.72(b)(1)(ii) specifies "Any event or condition during operation that results in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded; or results in the nuclear power plant being.......".
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j The above conditions are not applicable to the event.
The unit was in Cold Shutdown at the time of the event, not in Power Operation.
Additionally, while the system was over pressurized as described above, the only damage was the flange. gasket lerk which was isolable by remotely operated valves.
Additionally, the water that leaked through the gasket contained low levels of radioactive material and was completely contained within the plant.
No offsite release occurred.
The normal hydrostatic test pressure is 150% for design pressure, which would be 330 psig for this section of piping, though it was only tested to 284 psig (the heat
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exchangers have been tested to 345 psig by the manufacturer).
Thus, the event did not occur duribg operation, was not an unanalyzed condition that significantly compromised plant safety, and was not outside the design basis of the plant.
Thus, the event was evaluated at the time and correctly determined to be non-reportable.
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