ML20099J987
| ML20099J987 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/30/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20099J948 | List: |
| References | |
| NUDOCS 8503200134 | |
| Download: ML20099J987 (4) | |
Text
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d q[c,co7 DUKE POWEiCo'sEsv P.O. ISOX 33189 J d C'I/4 CHAHLOTTE. N.C. 28242 HALB. TUCKER TELEPHONE (704) 373-4538 vsom remems.T ppn.p3 A
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November 30, 1984 I
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l Mr. James P. O'Reilly, Regional Administrator l
U. S. Nuclear Regulatory Commission l
Region II l
101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370
Reference:
NRC/0IE Inspection Report 50-369/84-25 and 50-370/84-22
Dear Mr. O'Reilly:
Pursuant to 10CFR 2.201, please find attached a response to the violation l
identified in the above referenced inspection report.
Please note that also included is a statement which addresses the additional example of r.on-compliance (i.e. inadequate procedure for nuclear instrumentation l
testing). This incident is described in LER 370/84-21.
Duke Power Company does not consider any information contained in this report to be proprietary.
Very truly yours,
ddk 1 s v l
Hal B. Tucker
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RLG/mj f l
Attachment l
cc:
Mr. W. T. Orders Senior Resident Inspector - NRC McGuire Nuclear Stat:.on i
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i 8503200134 850222 PDR ADOCK 05000369 0
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DUKE POWER COMPANY' McGuire Nuclear Station Response to NRC/01E Inspection Report-50-369/84-25 & 50-370/84-22 VIOLATION The following violation was identified during an inspection conducted on August September 20, 1984. The Severity Level was assigned ~in.accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).
Code of Federal: Regulations, Part 50.73, " License Event Report System,"
sart (2)(V)(c) states, in part,' that the licensee shall report within-30 days of.any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material.
Contrary-to the above requirement, containment integrity was degraded when containment spray vent valve INS-68 was left open and this event was not reported as required.
This is a Severity Level IV violation (Supplement I).
RESPONSE
a.
The alleged violation as written is denied.
- b. -The identified incident was not initially considered to be
. reportable based on an engineering assessment of impact on system performance. Additionally, the safety consequences of degraded containment were assessed, with the result that there was no appreciable impact on offsite dose consequences. Therefore, it does not appear that this incident alone "could have prevented the fulfillment of the safety function" of containment.
Such conclusion is consistent with that contained in 1E. Inspection Report 50-369/84-21. 50-370/84-18. "The NRC Region II office also evaluated the radiological consequences and system performance-during accident conditions with ' the vent valve being open and'found it.to have minimal impact on containment integrity and design function of the system".
l The Commission has recognized that the application 'of this section of the rule involves"the use of engineering judgement on the part l
of licenses (FR 33854).
It~is this engineering judg2 ment which is in q1estion. The results of further detailed engineering analysis have confirmed the incident not to be reportable.. The potential release of radioactivity.was still controlled such that off-site dose consequences previously predicted were not exceeded..
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f November 30, 1984-Page 2-RESPONSE (continued) c.
Licensee Event Report (LER 369/84-25) was submitted November 9, 1984 for informational purposes, d.
Personnel. involved in determining reportability will conduct thorough assessments of station incidents and consult with additional technical resources to provide assurance that incidents are properly evaluated and, as necessary, reported.
e.
Since the violation is denied the-station was/is not in non-compliance.
Item d was emphasized to applicable station personnel in September, 1984.
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a
, 'y ' h 13,c ~ Inadequate Procedure for Nuclear Instrument Testing y
This Inspection Report identifies this as an a'dditional example of non-compliance and reque'sts that. Duke address the item. The tect.. procedure and its implementation are stated to have contributed to a reactor trip of Unit 2 on August 31, 1984.
g As required by 10 CFR 50.73, Duke prepared and submitted Licensee Event Report 370/84-?A concerning the event on October 1, 1984. Within this LER, a committment'was made to identify appropriate procedural improvements.
In response to thJ.s,!the following. actions were taken. Procedure IP/0/A/3207/03B was deleted. jA new procedure IP/0/A/3207/03/K was implemented which emcompasses the Power Range Channel Calibration and includes independent verification at all steps requiring detector cableremoval/ reinstallation, jumpers and fuse recoval, In addition, the NIS cabinets and cables have been labeled in order to facilitate positive identification.
With these corrective actions, it is considered that this item has been adequately addressed.
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