ML20072Q657
| ML20072Q657 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/19/1990 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9012260276 | |
| Download: ML20072Q657 (5) | |
Text
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! ? 'I1' ? I l' l DUKEPOWER December 19, 1990 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Subject McGuire Nuclear Station Docket Nos. 50 369.
370 Inspection Report No. 369, 370/90-18 Reply to a Notice cf Violation Gentlemen:
Pursuant to 10CFR 2.201, please find attached Duke Power Company's response to Violntion 369, 370/90-18-04 for McGuire Nucicar Station.
Should there be any questions concerning this matter, contact 1..J.
Rudy at (704) 373-3413.
Very truly yours.
NthAMs M.S. Tuckman, Vice Picsident Nuclear Operations 1.JR004/1j r Attachment xc (W/ Attachment):
Mr. S.D. Ebneter Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, CA 30323 Mr. T.A. Reed Project Manager U.S. Nuclear Regulat.ory Commission office of Nuclear Reactor Regulation One White Flint North, Mail St.op 9113 Washington, l' C. 20555 Mr. P.K. VanDoorn NRC Senior Resident Inspector McGuire Nuclear Station h
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A Mc0VIRE NUCLEAR STATION RESPONSE 'IC HOTICE OF VIOLATION Violation 369/370/90-18-04:
Technical specification 6.8.1 requires that written procedures be established, biplemented and maintained covering the fire protection program.
Selected Licensee Commitments, Section 16.9-5 requires all fire barrier penetrations separating safety-related fire areas to be eperable.
The Fire Protection Review, pages 68-69, requires valves in the fire protection system which are not electrically supervised to be locked or sealed in the normal position.
The fire Protection Review, page 53, requires 8-hour battery. powered lights in various plant areas.
Licensee procedures-PT/1 and 2/B/4350/C9, Emergency Lighting Annual Test requires a yearly test of these lights using the test switch.
Contrary to the above these requirements were not met in thatt Licensee's procedure PT/0/A/4250/04, Fire Bstrier Inspection Was inadequate in that reach rod floor penetrations between Auxiliary Building elevations 733' and 750' were not properly identified to be maintained as fire penetrations.
These penetrations were found unsealed on March-22, 1990.
Licensee's procedure CP/1/A/6400/02A, Fire Protection System was inadequate in that it did not require valve 1RF603 to be locked.
This valve was found unlocked on April 25, 1990.
The licenses failed to implement procedures PT/1 and 2/5/4350/09, on February 28, 1990 in that the procedures were signed off as complete but with a note stating that the procedure could not be completed since the test switches had been removed.
This is a Severity Level IV (Supplement I) violation.
Response to Violations
-Each example given in this violation will be addressed separately.
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2 RXAMPLE %
1.
The reason for th". Violation, or, if contested, the basis for disputing the violation.
The applicablo procedure PT/0/A/4250/04 did not identity these penetrations as fire barriers.
The reach rod penetrations are made with a recessed seat which allows the reach rod valve operator to set and anchor firmly to the concrete.
This causes the reach rod assembly to be below the floor elevation by several inches.
Each reach rod penetration is then capper with a steel plate assembly which sets on top of the reach Od assembly and comes up flush with the floor.
These steel plate capping assemblies have a 1 inch to 1.5 inch hole in the center to allow for a T bar to be used to operate the valve reach rod assembly.
The snugly fitted and anchored reach rod assemblies form the barrier between the Auxiliary Building 133' and 7$0' elevation.
Because of this, the reach rod penetrations are not uniquely identified as fire barriers in the applicable procedures however, the Auxiliary Building floors are identified as fire barriers.
Therefore, the entire floor surface is subject to the periodic inspection.
Several of these reach rod floor penetrations were known not to contain the reach rod valve operator assembly and were appropriately identified as fire barrier penetrations in pT/0/A/4250/04 and properly fire stopped.
However, several other reach rod floor penetrations without a reach rod valve operator assembly were not identified as fire barrier penetrations.
These penetrations had the steel pitte capping assemblies installed in them and thus appeared to be reach rod assemblies.
j 2.
The correctivo steps that have been taken and the results I
achieved.
When these penetrations were discovered as fire barrier breaches the appropriate compensatory actions were initiated in accordance with Selected Licensee Commitmento. Section l
16.9-5.
A fire watch was established and the inoperable barriers were reported to the control room SRO and entered in the Tech. Spoo. Action Item Log.
An emergency work l
request was initiated to fire stop the penetrations and fire barrier penetration numbers were assigned to each-penetration.
Subsequent to this action, a Problem t
Investigation Report (pIR) was initiated to further evaluate l
the problem with reach rod type floor penetrations.
The resolution to this PIR is to inspect all reach rod type floor penetrations, removing the steel plate capping assembly to verify that a reach rod valve operator is installed in the penetration or if not installed that the penetration is properly firestepped and a fire barrier penetration number has been assigned to the penetration.
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3 This has been completed and all fire barrier penetrations have been appropriately fire stcpped and identified.
3.
The corrective steps that will be taken to avoid further violations.
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The empty reach rod penetrations which were uniquely.
identified as fire barrier penetrations will be incorporated in procedure PT/0/A/4250/04 and therefore subjected to future periodic inspections.
4.
The date when full compliance will be achieved.
McGuire Nuclear Station will be in full ccmpliance prior to the next fire barrier periodic inspection due to be performed October 19, 1991.
EXAMPLE II 1.
The reason for the violation. or, if contested. the basis for disputing the violation.
The valve was not required to be locked por the piocedure because it was missed during generation of the procedure.
This valve is required to be locked open for insurance concerns and is not required to be. locked open due to Technical Specifications or Selected Licensee Commitments.
2.
The corrective ste")s that have been taken and the results achieved.
The valve position in the procedure was changed to locked open and the valve is now locked open.
3.
The corrective steps that will be taken to avoid further violations.
None.
The omission of this valve was an isolated case.
4.
The date when full compliance will be achieved.
McGuire Nuclear Station is in full compliance.
EKAMPLE III The reason for the violation, or, if contested, the basis 1.
-for disputing the violation.
The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery lights were being modified to enhance their storage capacity.
During the modification, all the lights were tested and the test switches were removed.
The switches were removed because the new battery packs are not L
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.c designed for the test switches.
During performance of these procedures, the modification was being-implemented and the test switches were not present on mest of the lights.
The personnel performing the procedure wrote this as a discrepancy on the procedure rather than rewriting the e
precedure because it could not be determined at the time if there was a need to test the op ration of the lights versus verifying the locatien of the lights or if there was a method to test the operation since the switches had been
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removed.
2.
The corrective steps that have been taken and the results achieved.
The modification process verified the operability of these lights during the time the procedure was being performed.
3.
The corrective steps that will be taken to avoid further viciations.
g Operations and Instrumentation and Electrical have begun negotiations about proper teeting methods to be used for the lights in the future.
The procedure will be changed to reflect the new test method.
4.
The date when full compliance will be achieved.-
McGuire Nuclear Station will be in full comellance.by June 1, 1991 when the procedure for testing the lights will be changed.
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