ML20058D116
| ML20058D116 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/17/1993 |
| From: | Hampton J DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312030061 | |
| Download: ML20058D116 (4) | |
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MeEbuer Contany J Wlirwu Oconee NuclearSite lice hesident T0 Bax H39 (8033z63499oma serwca SC:9679 (803pt63%4 Fax DUKEPOWER November 17, 1993 1
U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 l
Subject:
Oconee Nuclear Site Docket Nos. 50-269, -270, -287 Inspection Report 50-269, -270, -287/93-24 Reply to Notice of Violation i
Dear Sir:
By letter dated October 19, 1993 the NRC issued a Notice of Violation as described in Inspection Report No. 50-269/93-24, 50-270/93-24, and 50-287/93-24.
i Pursuant to the provision of 10 CFR 2.201, I am submitting a written response to the violations identified in the above Inspection Report.
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Very truly yours,
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?,?l.> iYo>
J. W. Hampton i
cc:
Mr.
S.
D.
Ebneter, Regional Administrator U.
S. Nuclear Regulatory Commission, Region II Mr.
L. A. Wiens, Project Manager Office of Nuclear Reactor Regulation Mr.
P. E. Harmon Senior Resident Inspector Oconee Nuclear Site f
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i 30007 J t
9312030061 931117 DR ADOCK 05000269 fI eDR
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- Violation 287 / 93 - 2_4 -pL_Seyerily_Lgyal_J32 i
10CFR50, Appendix B, Criterion XI, Test Control, requires that a test program be established to assure that all testing required to j
demonstrate that structures, systems, and components will perform satisfactorily in
- service, is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design
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documents.
k Contrary to the above, an adequate post modification test program was not established on the Unit 3 Load Shed Channel I circuitry following the performance of Modification Package TN/3/A/1426/OO/0, resulting in the incorrect wiring of the load shed channel 1 slave relay in switchgear 3TD going undetected and the channel being inoperable from March 1987 to August 1993, i
l RESP _ON.S E :
1.
The reason for the violation, or if contested, the basis for disputing the violation:
At the time this modification was installed, a testing plan was not required as part of the modification planning.
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standing test procedure was used to verify that the circuit functioned properly, and independent verification was used to verify proper installation.
Because power was available from the switchgear bus at all times, the circuit performed as expected during the test.
The installation and independent i
verification to verify proper installation were in error.
As described in LER 269/93-09, the cause of this event was improper installation.
2.
The corrective steps that have been taken and the results achieved:
Since this modification was installed in
- 1987, several enhancements have been made associated with modifications and testing.
One of these is the development of a Modification l
Test Plan and issuance of Test Acceptance Criteria by design.
l Also, implementation procedures are written in more detail to reduce installation errors.
To insure that the "as built" l
condition matches the drawings, a
configuration control inspection has been started.
It was this inspection that discovered the error and it is intended to identify any similar deficiencies which may exist.
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i 3.
The corrective steps that will be taken to avoid further violations:
The configuration control inspection will be continued and is ~
l scheduled for completion by June 30, 1994.
4.
The date when full compliance will be achieved:
Duke Power Company is in full compliance.
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Violation 2 69. 2 70. 26149_3 - 2_4- 02J.eSAtitJ_Le3_el_JY Technical Specification Section 6.4.1 requires that the Station be
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operated and maintained in accordance with approved procedures and that written procedures with appropriate check-offs and instructions be provided for implementation of the Fire Protection Program.
Selected Licensee Commitments Manual, Final Safety Analysis Report Chapter 16, Section 16.9.2, Sprinkler and Spray Systems, requires that the Sprinkler and Spray Systems in safety related areas listed in Table 16.9-2 be functionally tested annually except in the cable l
spreading rooms, equipment rooms and cable shafts.
Table 16.9-2 lists the Keowee Hydro Station Main Transformer as one of the required Spray Systems.
Procedure MP/0/A/2000/032, Mulsifyre System Semiannual Check, is i
the procedure which is used to perform the annual functional test of the fire protection water spray system for the Keowee Main Transformer.
Section 9.5 of the procedure lists the acceptance l
requirements for the fire protection pump as follows:
Fire protection pump output pressure MIa be 2 54 psi (adjusted to I
account for the effects of higher than minimum lake level) with flow 2 static flow plus 1060 GPM.
Section 11.3.50 of the procedure states that if the pump discharge pressure is less than the lake level divided by 2.31 subtracted by 283.7 the Fire Protection Pump is NO_I acceptable RQ the pump is NOI operable.
Contrary to the above, the annual operability test performed April 30, 1992, on the Keowee transformer Sprinkler Spray System did not verify operability of the Keowee Fire Protection Pump in that the pump was not operated to measure flow and output pressure in order to compare results against acceptance criteria.
Prior to this inspection, the most recent operability test on the Keowee fire pump was October 31, 1990.
RESPONSE 1 1.
The reason for the violation, or if contested, the basis for disputing the violation:
There was no intention of violating Selected Licensee Commitment (SLC) 16.9.2.
There was confusion over the requirement for pump testing in order to meet the SLC since the pump is not addressed in any SLC.
The interpretation was made that the pump test was not a
part of the SLC l
requirements.
This was not a proper interpretation.
The ability to measure flow was not available during the 1992 test.
Previous methods were insufficient and the new insertion flow meter was inoperable.
Had there been flow measure capability readily available, the test would have been performed.
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2.
The corrective steps that have been taken and the results achieved.
i Corrective actions were taken after this item was identified by the NRC inspector.
The missed test was reported to System Engineering on September 14, 1993 at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />; the test was completed by 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on September 17, 1993.
Operability and a new lake level requirement were determined by September 21, 1993.
Past operability was also determined and at no time since the previous test was the Keowee Station without operable fire protection due to low lake level and improper pump performance.
SLC 16.9.7 (Keowee Lake Level) was revised including the proper lake levels for Keowee Main Transformer Emulsifier
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System operability.
In addition, SLC 16.9.2 (Sprinkler and j
Spray Systems) was revised to provide clarification.
3.
The corrective steps that will be taken to avoid further violations:
SLC 16.9.1 (Fire Suppression Water System) will be revised to include the Keowee Fire Protection Pump.
The Fire Protection System will be inspected at the pump, pump bypass check valve, and Main Transformer Emulsifier System strainer for possible blockage.
The piping upstream of the pump will be modified to make the insertion flow meter operable and to reduce pump suction side pressure losses.
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test will be performed after the modification and inspections to determine if any improvements have been made by the modification.
This will also determine the priority for i
pursuing pump replacement or modification.
All corrective actions will be completed by August 1, 1994.
4.
The date when full compliance will be achieved:
Duke Power is in full compliance.
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