ML20062J127
| ML20062J127 | |
| Person / Time | |
|---|---|
| Site: | Mcguire |
| Issue date: | 07/14/1982 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20062J106 | List: |
| References | |
| NUDOCS 8208160270 | |
| Download: ML20062J127 (4) | |
Text
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Vict Potsiof MT ICLEPMoNc AntA 704 ST(AM PaoouctioN 373-4083 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Subject:
McGuire Nuclear Station Docket No. 50-370
Reference:
RII:WHM 50-370/82-10
Dear Mr. O'Reilly:
Please find attached a response to deviation items A(50-370/82-10-02) and B(50-370/82-10-01) which were identified in the above referenced inspection report. Duke Power Company does not consider any information contained in this report to be proprietary.
I ry truly yours, f
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William O. Parker, Jr.
PBN/j fw Attachment
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DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO I.E. INSPECTION REPORT 50-370/82-10 Deviation Item A (50-370/82-10-02):
McGuire Nuclear Station Fire Protection Review (FPR) revised January 1979 Section C.,
states that a fire protection quality assurance (QA) program will be applied to the installation and test of all fire protection features pro-vided after January 1, 1978.
Contrary to the above, a QA program had not been initiated for all fire pro-tection features provided after January 1, 1978. Examples are as follows:
1.
QA organization had not verified that all fire protection systems provided since January 1, 1978, were installed in accordance with the design and installation documents as stated by FPR Section C.4.
Two examples of this item are the sprinkler systems for the component cooling pumps and centri-fugal charging pumps.
2.
QA organization had not verified that all portions of the fire protection system installations were installed in accordance with the design and installation documents as stated by FPR Section C.4.
Two examples of important items which were not verified are the fire protection piping hangers and the electrical wiring, conduit, etc., to each fire detection device.
3.
QA audits had not been conducted on the flushing and hydrostatic tests for the fire protection piping systems as stated By FPR Section C.S.
4.
Documentation was not provided for all inspection conducted on the fire protection system to identify items that have satisfactorily passed the required tests as stated by FPR Section C.5.
One example is the lack of documentation provided for the inspection conducted on the welds in the fire protection piping systems.
Response
Example 1:
Page 18 of the Fire Protection Review dated September 1977 and revised January 1979 states the following: "Only those revisions to the fire protection program negotiated after January 1, 1978, will be under the Duke Power Quality Assurance Program to assure they conform to guidelines of the Branch Technical Position or are controlled deviations". The intent of this statement was to permit the design and installation process on systems that were committed to prior to the January 1, 1978 date to proceed while the review by NRR of the Fire Protection Program was in progress. These systems were in various stages of the process (i.e., released for design, in the design phase or released for installation). The centrifugal charging pumps fall into this category. This system was committed to prior to January 1, 1978 and does not come under the QA program.
During the review process with NRR, additional systems and additions to systems were made as formal commitments. These additional commitments are covered by the QA program, but the program was not backfitted on the entire system under
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i consideration. The twenty-foot extension on the sprinkler system for the component cooling pumps is an example of this category.
(Reference W. O.
' Parker's August 1, 1978 letter to H. R. Denton). The installation of the original system was'not under the QA program since it was committed to prior to January 1, 1978, but the revision to the system was negotiated after January 1, 1978, and this ravision did come under the QA program.
As'a i
result of this concern, a review of the records of this system was made and additional records which were unavailable for the inspector at the time of his visit were retrieved. Records are available to show,that the portion of the system in question was inspected in accordance with the program at that time. Records are also available that show that inspections were made on this system after it was turned over to Steam Production as a result of additional work on this system. An as-built verification was made on this system and that information was transmitted to Design Engineering in July of 1980. Our review shows that we are in compliance with FPR Section C.4 on the portion of this system in question.
Example 2:
Test procedures and field verification are utilized to meet the intent of Section C.4. of the Fire Protection Program.
In the case of detectors, there is verification of the location of the detector as well as testing of the detector to verify that the detector is operating, that the detector panel is operating, and that the correct zone is identified on the panel. Each wiring connection and conduit routing is not verified since the operation test is considered sufficient verification that the system is operable.
,r The intent of the Fire Protection QA Program is to assure systems and components are installed as designed and will function as intended. Since fire protection systems are non-seismic and not required for the safc shutdown of the plant, structural components of fire protection systems such as hangers are designed i
i and installed in accordance with standard procedures for structural items of non nuclear safety related systems. Hanger material, assembly, and location are-established accordingly. Hanger locations are verified by construction following installation. Water flow through systems during high velocity flush causes structural loads on hangers that would be experienced during operation.
This is a reasonable measure of structural integrity; therefore, it is appro-d priate to exclude pipe hangers from the Fire Protection QA Program.
Example 3:
Duke Power uses the review and retention of the flush and hydrostatic test records by Quality Assurance to meet this section of the FPR.
As'a result of the NRC concern, a review of these records is being made to assure that they are complete. This review will be completed by August 31, 1982.
Example 4:
Although the QA program for fire protection does not require weld inspections, 4
a final inspection of these welds is accomplished as a part of our normal construction practice. Since these inspections are outside the QA program, no documentation is maintained. The hydrostatic tests are considered to be sufficient verificaiton that the welds are satisfactory. The records of these i-tests are maintained by QA.
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Deviation Item B (50-370/82-10-01):
FPR Section A.6 states that the fire protection program to include plans, personnel, and equipment, for the new fuel storage area and for adjacent fire zones which could affect the fuel storage zone will be operational before fuel is received at the site.
Contrary to the above, on May 14, 1982, approximately 130 fuel assemblies were stored in the fuel storage building and the installation of the fire detection system for this building was not complete and thus was not operational. The licensee that fuel receipt for Unit 2 began in February 1982.
Response
The station agrees the violation occurred as stated. The responsible station personnel were not aware of the requirement. The fact that.other auxiliary systems (i.e. Ventilation Systems, etc.) are not required unless there is irradiated fuel in the building led the personnel to believe a functional fire detection system would not be required when storing new fuel.
It should also be noted that the fuel building was patrolled at least once every four hours during the period in question. The fire detection system has been installed and is presently in service.
The station is presently in full compliance with the fire protection review in this area.
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