ML20078M849
| ML20078M849 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/30/1994 |
| From: | Mcmeekin T DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412050162 | |
| Download: ML20078M849 (6) | |
Text
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1 Dde Mer Company T. C McVrm McCwre Nnclear Generanon Department tice President i1700 Hagm ferryRoad(MG0lVP)
(704)8754800 Iluntersalie, NC280788385 (701)8754809 Fax DUKEPOWER November 30,1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 NRC Inspection Report No. 50-369,370/93-33; 50-369,370/93-32 and 50-369,370/94-04 Supplemental Rcply to a Notice of Violation and Proposed imposition of Civil Penalty Gentlemen:
Attached is a supplemental response to the Notice of Violation and Proposed imposition of Civil Penalty, (Violation 1), issued May 16,1994. Implementation of the numerous corrective actions identified as a result of the Unit 2 Loss of Ofl site Power event has required a substantial effort by McGuire and General Office suppoit personnel and tcese efforts have been successfulin completing the majority of corrective actions. The corrective actions addressed in items 3.a through 3.1 of the supplemental response have been completed. The remaining corrective action identified in our June 13,1994 response, item 4.a, concerns issuance of a testing practices document. A new Nuclear Site Directive (NSD) 408, Testing, will be issued the first quarter of 1995 (originally scheduled for November 30,1994) and fully implemented at McGuire Nuclear Station by the end of 1EOC10 and 2EOC10 refueling outages.
I declare under pen'alty of perjury that the statements set forth herein are true and correct to the best of my knowledge.
Should there be any questions concerning this response, contact Randy Cross at (704) 875-4179.
Very Truly Yours, Nuhll T. C. McMeekin Attachment i
U.S. Nuclear Regulatory Commission
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f U.S. Nuclear Regulatory Commission November 30,1994 xc:
(w/ attachment)
Mr. S. D. Ebneter Mr. George Maxwell Regional Administrator, Region Il NRC Senior Resident inspector U.S. Nuclear Regulatory Commission McGuire Nuclear Station 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Victor Nerses U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation t
One White Flint North, Mail Stop 9H3 Washington, D. C. 20555
McGuire Nuclear Station Supplemental Reply to a Notice of Violation and Proposed imposition of Civil Penalty I.
Violation Assessed a Civil Penalty i
I 10 CM 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,' requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstarmes. Instructions, procedures, or drawings shall include appropriate quantitative or qualit ' ve acceptance criteria for determining that important activities have been satisfactorily accompt 7d.
10 CFR 50, Appendix B, Criterion XI, " Test Control," requires, in part, that a test program be established to assure that all testing required to 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 documents. Criterion XI also requires that test procedures shallinclude provisions for assuring that all prerequisites for the given test have been met, and that the test is performed under suitable environmental conditions.
Procedure MP/0/A/7200/11, "MSIV and Valve Actuator Corrective Maintenance," was established to provide for maintenance of the main steam isolation valves (MSIV).
Procedures PT/2/A/4255/03A and 03B, "SM Train A (B) Valve Stroke Timing - Shutdown," were established to test the "A" and "B" train MSIVs.
Contrary to the above, as of December 27,1993, the procedure conducting maintenance on the MSIVs did not include appropriate acceptance criteria and the procedures for testing the MSIVs did not contain provisions to conduct the tests under suitable environmental conditions as evidenced by the following examples:
1.
Procedure MP/0/A/7200/11 was inadequate in that appropriate acceptance criteria for MSIV yoke rod guide clearances were not established to ensure that a proper clearance existed between the valve yoke rods and the yoke rod guides when the valve was at operating temperature.
2.
Procedures PT/2/A/4255/03A and 03B did not include provisions to assure that MSIV testing was conducted at normal operating temperature.
On December 27,1993, these deficiencies resulted in the failure of "B" steam generator MSIV 2SM-5 to fully close and seat and the "A" steam generator MSIV 2SM-7 to fully stroke closed to prevent leakage on a steam line isolation signal. (01013)
This is a Severity Level 111 violation. (Supplement l}
Civil Penalty - $100,000.
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Sgoolemental Resoonse to Violation 1.
1.
Admission or Denial of the Alleaed Violation:
McGuire Nuclear Station admits the violation.
2.
Reasons for the Violation if Admitted:
The reason for the violation is inadequate Procedures. Maintenance procedure MP/0/A/7200/11 "MSIV and Valve Actuator Corrective Maintenance," did not include appropriate acceptance criteria for MSIV yoke rod guide clearances to ensure that a proper clearance existed between the valve yoke rods and yoke rod guides when the valve was at operating temperature. The inadequate clearance resulted in binding, which prevented valve 2SM-5 from fully closing. The vendor recommended yoke rod guide clearance and hot stroke testing in a 1981 letter. At the request of Enginee ring, the MSIV vendor provided a general vendor manual update in April 1992 that incuded the correct clearances and installation instructions for the yoke rod guides. The 1981 vendor recommendations were not incorporated in the appropriate maintenance procedures. The updated vendor information was under review prior to officially re <ising the vendor manual. As such, the clearances and installation instructions had not yet been incorporated into maintenance procedure MP/0/A/7200/11.
Periodic Test procedures PT/2/A/4255/03A and 03B "SM Train A(B) Valve Stroke Timing - Shutdown," did not contain provisions to assure that MSIV testing was conducted at normal operating temperature The existing surveillance program for the MSIVs specified full stroke testing of the valves following modification or maintenance.
i These tests were performed with the valves at ambient temperature to avoid potential j
inadvertent safety injections upon reopening the MSIVs at operating temperature and pressure. This test method did not ensure the valves would meet the timing and stroke requirements at normal operating temperature.
3.
fddective Steos That Have Been Taken and_the Results Achieved:
a.
Mechanical maintenance and Engineering personnel adjusted the yoke guide rods on valve 2SM-5 to allow the valve to fully close prior to restart.
b.
Mechanical maintenance personnel measured and reset yoke rod guide 3
clearances for Unit 1 and 2 MSIVs at full operating temperature in accordance with maintenance procedure MP/0/A/7200/11, "MSIV and Valve Actuator Corrective Maintenance." This information was used to develop cold target values and to verify proper valve setup prior to returning Unit 2 MSIVs to service. This activity was completed on January 6,1994.
c.
Prior to Unit 2 restart, Engineering personnel performed an assessment of the current state of updates to safety related documents and procedures due to vendor information changes. No items of safety significance were identified.
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d.
The MSIV vendor manual was revised to include the vendor supplied yoke rod guide installation instructions and yoke rod to yoke rod guide clearances. The update to the vendor manual was completed on January 25,1994.
e.
Nuclear System Directive (NSD) 204 " Operating Experience Program (OEP)
Description" was revised to address the processing of vendor technical information. This was completed on June 9,1994.
f.
A Nucle.ar Network Bulletin discussing the MSIV failure was issued on December 31,1993.
g.
A Problem Investigation Process (PIP) was initiated for all outstanding Vendor Information Letters (VILs) and the Operating Experience Program (OEP) was enhanced to require a PIP to be initiated with each new VIL. These actions were completed on March 1,1994, h.
Periodic test procedures PT/1/A/4255/03C and PT/2/A/4255/03C were developed to verify full closure of each MSIV at full temperature and steam line pressure greater than or equal to 900 psig. PT/2/A/4255/03C was completed on January 3,1994; PT/1/A/4255/03C was completed on January 6,1994.
Unit 2 MSIVs were stroke tested using procedure PT/2/A/4255/03C on January 5,1994. Unit 1 MSIVs were stroke tested on April 7,1994.
J.
System Engineering personnel reviewed Final Safety Analysis Report (FSAR)
Chapter 10, Section 10.3 and Chapter 6, Section 6.2.4.4 for test requirements and/or commitments relating to the MSIVs. The review indicated the station is and has been in compliance with test commitments contained within the FSAR.
Upon completion of the review, System Engineering personnel completed an FSAR change to clarify the wording of our current commitments and to include the new commitment to stroke the MSIVs at a Main Steam temperature greater than 350 degrees and pressure greater than or equal to 900 psig at least once per refueling outage. This FSAR change will be submitted in the next annual FSAR update scheduled six months following completion of the Unit 2 EOC9
- outage, k.
A comparison of testing practices at all three nuclear stations wa= performed which indicated there are no significant differences or problems related to safety-related or NRC committed testing programs. However, differences in the scope of testing for non-safety secondary systems were identified. The results of this comparison were outlined in a report dated April 18,1994. A Nuclear Generation Department testing practices team was formed to develop a philosophy and a consistent approach to testing. Planned corrective action item 4.a addresses the issuance and implementation of a new Nuclear Site Directive (NSD) 408, Testing.
l.
The Engineering Documents Manual, Section 3.4.6 (Revision 1), was added to specify proper handling of vendor technicalinformation/ vendor documents. This corrective action was completed on July 7,1994.
No s!milar violations have occurred since implementation of the above corrective actions.
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. Corrective Steos That Will Be Taken To Avoid Further Violations:
4.
a.
Nuclear Site Directive (NSD) 408, Testing, will be issued the first quarter of 1995 and will be fully implemented at McGuire Nuclear Station by the end of 1EOC10 and 2EOC10 refueling outages.
5.
Date When Full Comoliance Will Be Achieved:
McGuire Nuclear Station is now in full compliance.
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