ML20054K342

Responds to NRC Re Violations Noted in IE Insp Rept 50-369/82-08.Corrective Actions:Procedures Revised to State Criteria for Battery Operability Clearly & Revised LER Prepared

ML20054K342
Person / Time
Site:	McGuire
Issue date:	05/28/1982
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054K336	List: IR 05000369/1982008 ML20054K335 ML20054K342 ML20054K346 ML20054K349
References
NUDOCS 8207010444
Download: ML20054K342 (3)

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USNP DUKE Pownu Comwxj;C p, REG'y^"',

, e, y Powra Denmixo 422 Sourn Cunucu Sruzzi. CnAnwriz, N. C. maa sa 82.!!n!3 A8:29 w l L LI A84 O, PA R M E R, J R.

v.c, p.c..o,,, May 28, 1982 rtemo..: . 7e4 Sitees Psoouctiog 373-4083 Mr. James P. O'Reilly, Regional Administrator U. S. Nucicar Regulatory Conunission Region II 101 Marietta Street, Suite 3100 Atlanta, coorgia 30303

Subject:

McGuire Nuclear Station Docket Nos. 50-369

Reference:

RII:PRB 50-369/82-08

Dear Mr. O'Reilly:

Picase find attached a response to violation 50-369/82-06-01 which was identified in the abote -rferenced inspection report. Duke Power Company does not consider any information contained in this report to be proprietary.

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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ry truly yours, se .__. _ g, "

William'O. Parker, Jr.

PBN/jfw Attachment 8207010444 820621 gDRADOCK 05000369 PDR

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i l DUKE POWER COMPANY ,

McGUIRE NUCLEAR STATION Response to I. E. Inspection Report 50-369/82-08 r

Violation 50-369/82-08-01, Severity Level IV:

Technical Specification 3.8.2.3 requires four'dc channels to'be operabic and energized with each channel consisting _of a 125 Vdc bus, a 125'Vdc battery bank, and a full capacity charger. The action statement allows one battery to be inoperable for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the associated bus is energized with an operable battery via operable tie breakers within two hours. In addition, Technical Specification 6.8.1 (a) and (c) requires procedures,to be implemented covering surveillance and test activities of safety-related equipment and - '

procedures listed in Appendix A of Regulatory Guide 1.33.

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Contrary to the above, Technical Specifications 3.8.2.3 and 6.8.1(a) a'nd (c) were not followed in that: >

a. On November 13, 1982 cell 16 of battery EVCB specific gravity was found to be 1.194 and thus below Technical Specification (TS) 3.8.2.3 limit of -

1.195 for operabilit'.yBattery EVCB remained in service for more' than eight hours. During this time, battery. EVCA was on equalizing charge and thus was inoperable.

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b. Instrument and Electrical Procedure IP/0/A/3061/01, by which the. battery specific gravity was tested, requires that the shift supervisor be notified if a parameter is below TS limits; however, on November 13 the shift

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supervisor was not notified of the low specific gravity.

c. Station Directive 2.8.1 requires a complete investigation of all incidents.

The licensee's investigation of Licensee ~ Event Report No.81-181, which-reported the inoperability of battery EVCB on November 14-20, 198F, was not '

• complete enough to detect that the battery was also not operabic on November 13 and that documentation of. events was not complete.

Response

Parts a and b:

1. Duke Power Company agrees that the violation occurred as stated.

2. The closeness of the original reading to the TS limit, confusion over the interpretation of TS Table 4.8-2, and questions as to whether the proper method was used in taking the reading a11' contributed to this incident.

The instrumentation and electrical (IAE) personnel, unsure about the reading, elected not to' contact the shift supervisor. Therefore, the batteries were not declared inoperable, f

3. IAE procedure IP/0/A/3061/01 has been revised to clearly state the

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criteria for battery operability. The procedure also requi.res that the reason for declaring a battery inoperableiand for returning it to operable status be documented. Sign-off steps were added for both the Shift Super-J

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.. . l visor and the IAE Supervisor to ensure they are notified of the status.

Detailed instructions for taking hydrometer readings have also been incorporated into the procedure.

4, Control Room Operators are now required to log the exact reason a system (or piece of equipment) required by TS is removed from or returned to service. Additionally, all individuals involved in this incident have been counseled to ensure that responsibilities in situations like this are both clearly defined and understood.

5. The station is presently in full compliance with Technical Specifications in this area.

Part c:

1. Duke Power Company agrees that the violation occurred as stated.

2. Part C of the violation was a result of insufficient investigative effort even though a great deal of time was spent on personnel inter-views and records review (Shift Supervisor's Log, Unit 1 Reactor Operator's Log, and Technical Specification Action Item Log). There are mitigating circumstances which partially affected the outcome of the initial investigation. The testing of battery EVCB on November 13, 1981, was documented on a work request that covered a periodic test, which was not readily available during the initial investigation. Sub-sequent investigation has revealed that the work request did contain pertinent information which would have prompted further investigation if known at that time. The investigator did not review the alarm typer printout because it was not practical under the time constraints and the amount of printout to be reviewed. Likewise, it too had per-tinent information about placing battery EVCB back in service as operable on November 15, 1981. However, at that time the investigator was confident that the information recorded in the Technical Specifica-tion Action Item Logbook was current and accurate with no reason to suspect otherwise, and that the information obtained from the personal testimonies of those involved were accurate and sufficient.

3. A revised Licensee Event Report is being prepared based on more complete information obtained from subsequent investigations. This report will more accurately reflect the incident and the root causes.

4. All deficient aspects of this Licensee Event Report have been discussed with the investigator and all the members of the investigative group, the McGuire Safety Review Group (MSRG) . Additionally, further training will be given to the MSRG on investigation techniques to aid in achieving better performance.

5. Full compliance with station directives in this area will be achieved upon completion (by July 1, 1982) of training of the MSRG.