ML20095F365
| ML20095F365 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/25/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20095F332 | List: |
| References | |
| NUDOCS 8408270259 | |
| Download: ML20095F365 (4) | |
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-6 DUKE POWER GOMPANY P.O. HOX 33180 CHARLOTTE, N.O. 28242 HAL B. TUCKER rg,,gpi,oug m2.5.",Um"so.
July 2,lh8k
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- Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370
Reference:
RII:WTO NRC/OIE Inspection Reports 50-369/84-11 and 50-370/84-09
Dear Mr. O'Reilly:
Pursuant to 10 CFR 2.201, please find attached a response to violations 50-369/84-11-03, 50-370/84-09-02, and 50-369/84-11-03 which were identified in the above referenced inspection report.
Duke Power Company does not consider any information contained in this report to be proprietary.
Very truly yours, f
H. B. Tucker PBN/rhs Attachment-cc:
Mr. W. T. Orders Senior Resident Inspector-NRC McGuire Nuclear Station 8408270259 840009 PDR ADOCK 05000369 G
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DUKE POWER COMPANY McGuire Nuclear Station Response to NRC/0IE Inspection Report 50-369/84-11 and 50-370/84-09 Violation 50-369/84-11-02 and 50-370/84-09-03, Severity Level IV:
10 CFR Part 50, Appendix J. IV.A., Special Testing Requirements - Containment modification, requires that any modification which is part of the primary p
reactor _ containment boundary, performed after the preoperational leakage rate test shall be followed by either a Type A, B, or C test, as applicable for.the area affected by the modification.
'The Reactor Vessel Level Indication Systems _(RVLIS) were installed on Units 1 and 2 in March 1981 and July 1983, respectively. The RVLIS' consists of tubing which connects to the containment penetration fittings. Contain-ment penetratica leakage test is required prior to unit startup.
Contrary to the above, a leakage test on the Unit 2 RVLIS and its associated containment penetration had not been performed until March 14, 1984. Unit 1 RVLIS testing was performed in June 1982. Units 1 and 2 had entered into operating modes 1 through 4 during the 15 month and eight month duration, respectively, without having verified containment integrity. The belated test results have shown that the penetrations would have maintained con-
.tainment integrity.
Response
1.
Duke Power Company admits the event occurred as initially reported in LER 369/84-09.
2.
This violation is attributed to Administrative Deficiency, due to the lack of administrative controls in the design, installation, and follow-up'on RVLIS. The installation problem occurred because the RVLIS package was not a typical Duke Power installation, and there was a lack of central control of the project.
In most instrument installations, Duke is the designer supplier and installer. The RVLIS package was designed and supplied by Westinghouse. The installation drawings were prepared by Duke and the installation was Dune's responsibility. As a result of unclear responsibility definitions within various internal Duke Power Departments, the instrument detail.was incorrectly interpreted resulting in tubing installations with no verifications being performed as re-quired by Q. A. Condition 1.
Since the system on each unit did not have to be functional prior to the first refueling, the containment integrity issue was not noticed. Additional details on the cause are available in LER 369/84-09, 3.
Containment integrity was verified on Unit 1 on June 29, 1982 with the puff and pressure test performed by Westinghouse. Unit 2 containment integrity was verified when a leak test was performed on RVLIS on March 14, 1984.
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4.
The potential for these problems to occur in the future will be eliminated by Duke PoweE's review and clarification of design requirements associated with containnent penetrations. Containment integrity will be specifically reviewed at the end of each outage to assure that all completed or uncom-pleted modifi' cations have not adversely affected containment integrity.
These actions will climinate future occurrences of this problem.
y 5.
The station is preachtly in full compliance with the codeof Federal Regulations in this area.
Violation 50,'169/84-11-03, Severity Level IV:
Technical SpecificaClon 6.8.1 requires that written approved procedures be established implemented and maintained covering surveillance tecting of safety related equipment. Procedure PT/1/A/4200/09A 'an approved station procedure for surveillance. testing of the enginecchd safety features actuation system'was amended by change numbers 54 and 57 'to cover black-out response testing of a nuclear service water system isolation valve.
Contrary to the above, on April 20, 1984, an electronics technician failed to follow the requirements of procedure PT/1/A/4200/09A, Change No. 57 when he incorrectly connected a lead wire to a power supply, resulting in an inadvertent initiation of train A blackout sequence. Furthermore, procedure PT/1/A/4200/09A, Change No. 54 was incorrect in that it epecified the opening of sliding link B-13 instead of B-14.
Response
1.
Duke Power Company admits th'e event occurred as initially reported in LER 36?/84-14, 2.
This violation is attributed to Personhc1,irror because a jumper wire was attached to the wrong place in the circuit being tested, and was independently verified as being correctly Installed. Also contributing to the event was Administrative / Procedural Deficiency due to an erroneous procedure and misleading electrical elementary drawings. Additional details on the cause r.re available in LER,369/84-14.
3.
Review of the procedule ofcer the blackout discovered the problem and the procedurd was revised. The LER was covered with appropriate station personnel, ressing the following items:
- Individuals should exercis~e particular care when modifying or verifying the modif'ications of systems. They should not be lulled into a false since of-Security because the step has been done before.-
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- Modifications of syste.ng for testing must be researched to the extent that all possible consequences are known and understood. Technical, reviews of procedures must be thorough and should be performea'vith the same source documents used for the prLparation. Sufficient manhours must be scheduled to accomplish these tasks.
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- Personnel responsible for scheduling testing activities should consider the manpower and added risks involved in separating components or parts of systems from the inte-grated test. The main effort should be directed toward having complete systems available at the scheduled test times. Problems in test scheduling should be identified early enough (long before outages) so that procedure revisions can be prepared and reviewed when adequate manpower is available.
4.
Corrective Steps to avoid further violations have been taken as indicated above.
5.
The station is presently in full compliance with technical specifications in this area.