ML20101G195
| ML20101G195 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/01/1983 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101G191 | List: |
| References | |
| NUDOCS 8412270449 | |
| Download: ML20101G195 (5) | |
Text
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- t DUKE PISEEd COMPANY
'P.O. BOX 33189 [
,i CHARLOTTE, N.o. 28242 HALH. TUCKER ratt.mpnown vaca.eammeav 0A (704) aW531 ua DEC 6 all1 3 7 December 1, 1983 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370
Reference:
RII:WO 50-369/83-36, 50-370/83-43
Dear Mr. O'Reilly:
Please find attached responses to Violations 50-369/83-36-01 and 50-370/83-43-01 which were identified in IE Inspection Report 50-369/83-36, 50-370/83-43.
Duke Power Company does not consider any information contained in this report to be proprietary.
Very truly yours, ff Hal B. Tucker WIDf/php Attachnent cc:
Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station 8412270449 831230 PDR ADOCK 05000368 G
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JP0/HBT/WHH December 1, 1983 Duke. Power Company McGuire Nuclear Station Response.to Violations 50-369/83-36-01 and 50-370/83-43-01 Violation 50-369/83-36-01, Severity Level IV:
. Technical Specification 6.8.1.a requires that written approved procedures be established, implemented and maintained covering facility operation and surveillance testing.-
Contrary to the above, approved, procedures were not followed, properly.
maintained, and implemented in.that the following conditions were noted::
Part 1:
On June 30, at'2:25.p.m., license electronics technic'ians-failed to follow
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Step 12.9.1 of Procedure PT-1-A-4601 during the performance of the protective system channel 1 functional test resulting in a unit trip from full power.
The feedwater valve controller was not placed in proper channel and its proper position was not verified as afforded-by instructions of Step 12.9.-l.:
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Response
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Duke Power Company agrees that McGuire Nuclear Station electronics technicians failed to satisfy the intent of Step 12.9.1 of the Protective System Channel 1 Fun.7tional Test. This resulted in a Unit 1 trip from full power. The technicians did attempt to perform Step 12.9.1; however, the procedure directions were incorrectly interpreted due to misleading terminology.
The cause of the violation was ambiguous switch nomenclature.
The procedure
- states,
"...the feedwater valve modulating controller is in.the channel II mode of control..."
The technicians interpreted this toLbe the Control Room switches for Steam Generator Feedwater Flow, and therefore verified'that these switches were in channel II..The switches that actually need to be verified in channel II are Steam Generator Narrow Range Level Control switches.
Pro-cedure Step 12.9.1 has been changed to identify the proper' switches by the Control Room label.- Procedure reviews are continually performed af ter. technician -
identified procedural problems and procedural changes. No similar errors in monthly testing have occurred since the corrective actions have been implemented.
The Protective System Functional. Test is in full compliance with the requirements of Technical Specification 6.8.1.a.
Part 2:
As of September 1, 1983, the annunciator response procedure OP-1-A-6100-10G
- which delineates actual setpoints for pressurizer safety discharge.high temperature alarms did not incorporate new setpoints when they were changed on July 22, 1983, by-Work Request Numbers 114790 and 114791.
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'JP0/HBT/WHM'
'Dectabar 1, 1983
Response
Duke ~ Power. Company agrees that the alarm setpoints for pressurizer safety relief discharge high temperature were increased while the new setpoints were not incorporated into the annunciator response procedure. The need for a procedure change was not recognized during the work request review.
The new safety _ relief setpoints were' incorporated into the annunciator response procedure and shift supervisors were made aware of this situation in order to prevent recurrence. The. annunciator response procedure _is presently in full compliance with the requirements of Technical Specification 6.8.1.a.
Part 3:
The. operations daily surveillance procedures performed for the days of September 13 and 14, 1983 have been completed with indication that the Unit I loose parts monitor was fully operable when in fact Channel 4 had been inoperable since September 7, 1983; the procedure' requires that discrepancies be noted and~ reported.
Response
Duke Power Company agrees that a discrepancy in the operability of Unit 1 loose parts monitor channel 4 was not noted or reported as required by the procedure. When performing the daily surveillance procedure, operability was verified when (1) there was an absence of alarms. (2) power to the loose parts monitor was "0N", and (3) a tape was inserted in the tape recorder subsystem. None of these items identified Channel 4'as inoperable.
The daily surveillance procedure for loose parts monitoring has been changed.
The acceptance criterion now requires that channels 1-8 are verified operable by a sound check (noise in channels) and that all channels are responding to noise. Shift supervisors have been made aware of this situation in order to prevent recurrence. The surveillance procedure for loose parts monitoring is now in full compliance with Technical Specification 6.8.1.a.
Part 4:
On September 21, 1983, electronics techniciaae worked inside the Unit 1 solid state protection cabinets without a procedure while preparing to perform a neutron noise surveillance test. The applicable work request specified use of Procedure TP/1/A/2100/01.
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Response
Duke Power _ Company agrees'that McGuire Nuclear Station electronics technicians
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were working on the Reactor Protective System of the 7300 Process Control' System without a procedure. (The procedure;specified on the work request.was not applicable to the work being performed in that it did not address test equipment setup and preparation for a neutron noise surveillance test. A I
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-JPO/HBT/WHM Dec:mbar: 1, 1983.
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- test equipment hookup procedure has been written which'will be utilized Ifor this situation. The electronics technicians have been counseled on using the proper procedure for the hookup of any. test. equipment on safety-related equipment. McGuire Nuclear _ Station'is presently in full compliance
!with Technical' Specification 6.8.1.a.'
1 50 370/83-43-01, Severity Level V:
Violation Technical Specification 6.9.1.10.b _ requires that operation of the unit or affected systems when any parameter.or operation is less conservative than-r the least conservative aspect of the Limiting Condition for Operation estab-lished in the Technical Specifications be reported within'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Regional Administrator of the Regional Office of the NRC or his designee
.no later than.the first working day following the event, with a written followup report within 14 days.
Contrary to the above, on August 9, 1983, Unit 2 was made critical with a control rod configuration less conservative than the least conservative aspect.
of Technical Specification 3.1.1.3 and the event was reported as a thirty day
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report rather than a prompt report requiring a written followup within 14 days.
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Response
Operation with a moderator temperature coefficient (MTC) less conservative than the specification is specifically allowed by Technical Specification 3.1.1.3 Action Item a(1) for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Since the MTC was returned to acceptable limits well within the time allowed Duke Power Company does not agree that this situation represented operation in a mode less conservative than the least conservative aspect of the Technical Specification. This event should therefore not have been. reported as a 14 day report per Technical Specification 6.9.1.10.b. but as a 31 day report as required by Technical.
Specification 6.9.1.11.b.
The reportability of this event was determined at the time of the incident and reviewed by Licensing personnel. Although Action Item a(2)' states that rods shall be maintained within the limits, the previous Action Item a(1) establishes the time limit to accomplish this. The intent of the action items was satisfied and a 14 day report was not applicable. Please note that-i the violation of the rod withdrawal limits was previously admitted in a report submitted to the NRC on November 18, 1983. After submittal of the 31 day-report, during discussions with the NRC Resident Inspector, it was recognized that the most conservative interpretation of the action items could lead to the conclusion stated in the violation.- However~, this interpretation was not warranted by_the circumstances at'the time the incident: occurred. A subsequent analysis has revealed that the MTC remained negative throughout the incident.
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l JP0/HBT/WHM Dectabarol, 1983 Although the reporting time of this~ incident has been questioned, the information and analysis of this incident-were provided to the NRC in' a timely manner. Further violations of this type will not exist under the revised reporting requirements which are effective January 1, 1984.
- Under these new requirements the reporting time will be the same for all incidents. McGuire Nuclear Station will continue to comply with all applicable reporting requirements.
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