ML20079L081
| ML20079L081 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 10/30/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111060038 | |
| Download: ML20079L081 (3) | |
Text
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- (%lct:rAC-j%I-IN' llaliilt n.I i 3 DUKE POWER Oc t otie r 30, 1991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington. D.C. 20555
Subject:
McGuiro Nuclear Station Docket, Nos. 50-369, -370 Inspection Report No. 50-369, -370/91-21 Reply to a Notice of Violation Gentlemen:
Pursuant to 10 CFR 2.201, please find attached Duke Power Company's response to Violation. 50-369 -370/91-21-02 for McGuire Nuclear Station.
During the exit for Inspection Report 50-369. -370/91-22 on October 21, 1991, McGuire was informed of a second example of Violation 50-370/91-21-01.
The NRC has requested that the response for this violation also address the second example of the violation.
In crder ta allow sufficient time to respond to both examples of this violation, we request-to delay.this response until thirty days after the date of issuance of Inspection Report 91-22.
Should there be any questions concerning. this matter, contact L.J. Rudy at (704) 373-3413.
Very truly yours.
L-f? /
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M.S. Tuckdan I.JR/s l
Attachment xc (W/ Attachment):
S.D. Ebneter Regional Administrator, Region II T.A. Reed, ONRR P.K. VanDoorn Senior Resident Inspector
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c MCGUIRE NUCLEAR STATION RESPONSE TO NOTICE OP VIOLATION c
Vioidtion 369,370/91-21-02 Technical Specification 6.8.1.a requires written procedures to be estab-lished, implemented, and maintained covering the applicable procedures re-commended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes procedures for mispositioned control rods.
Contrary to the above, un July 13, 1991, procedures AP/l and 2/A/5500/14, Rod Control Malfunction, were inadequate in that the case whereby misaligned rods were unable to be moved was not covered.
This is a Severity Level IV Violation (Supplement I).
Response
1.
The reason for the violation, or, i f contested, the basic for disputing the violation:
)
The procedure. in ef fect on date of event did address the case when a control rod would not move.
The guidance specified following Technical Specifications (TS) in-this case.
One option the applicable TS (3.1.3.1) requires is:
"...the remainder of the rods in the group with-the inoperable rod are aligned to within 12 steps of the inoperable rod while maintaining the rod sequence and insertion limits of TS 3.1.3.6...".
The operators followed the action specified in the Abnormal procedure.
The detail on how to move the operable rods without af fecting the inop-erable rod was not included in the procedure, but the operators had no-problem completing the required actions.
While this added detail would have been helpful, the step specifying the required action was not missing.
sThe procedure specified following the TS actionistatement.
In-this case, it would-have been appropriate to repeat TS action-statements in
= the procedure, and to give addition level of detail.
The operatorn knew by training-how to complete the high level step.
We: agree with the NRC_that the procedure would have been improved with added level of detailnto support the high level step.
The dhtail on how to move the operable rods without affecting the inop-erable rods existed in AP/1/A/5500/14, Rod Control Malfunction,-prior-to 4-5-82.
A procedure rewrite issued on this date deleted this de-tai),;but still addressed the case when a misaligned rod will'not' move.
-Personnel involved'in this1 rewrite could not recall why this detail.was-deleted.
It is_ speculated that this detail was deleted because TS give several options if inoperable rod cannot be moved (not just moving op-erable rods to inoperable rod position).
The other options may be more appropriate (action statement 3.1.3.1.c.3) depending on position of in-operable rod.-
(The procedure actually specified one of the actions covered under 3.1.3.1.c.3 (calculating shutdown margin). )
2.
The-corrective steps that have been taken and the results achieved:
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3._
'The corrective oteps that will be taken to avoid"further violationnt a.:
AP/1(2)/A/5500/14, Rod Control Malfunctions, will be reviewed and detail will be-added back on how to move operable rods without af-fecting_ inoperable-rods.
I b.
Additional guidance will be given to operators on how to handle i
situations where actions must be taken that go beyond the level of 4
detail that exists in proceduro (or outsido the scope of the pro-cedure).
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.The date when full compliance will be achieved:
McGuire vill be in full compliance on 12/30/91.
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