ML20101H731

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Responds to NRC Ltr Re Violations Noted in Insp Repts 50-369/92-13 & 50-370/92-13.Corrective Actions:Personnel Stopped Silling SG 1D & Reset MSIVs & Returned Valves to Original Position
ML20101H731
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 06/26/1992
From: Mcmeekin T
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9206300163
Download: ML20101H731 (5)


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.I 11ake Ibuer Cornpany T C Alcu m tM McGuire Nudrat Generation Department Flce President

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12 00 llagers l'erry Road (AfG014)

(701}875 4800

' fluntersnile. NC28078 89U (iM)375009hx DUKE POWER June 26,1992 U.S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 2055 -

Subject:

McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369 and 50-370 Reply to a Not:ce of Violation Inspection Report No. 50-369, -370/ 92-13 Gentlemen:

NRC Inspection Report No. 50-369, -370/ 92-13 resulted in Violation 3G9/92-13-01, concerning Failure to Follow a Procedure Resulting in an Engineered Safety Features Actuation.

Attached is a description of the event that led to the violation, and corrective actions to prevent future occurrences.

For questions please contact Larry Kunka at (704) 875-4032.

Very truly yours, ke 24/.S A T. C. McMeekin f

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Mr. S.D. Ebneter, Reginnal Administrator U.S. Nuclear Regulatory Commission, Region il Mr. Tim Reed, Project Manager U.S. Nuclear Regulatory Commission, ONRR Mr. P.K. Van Doorn NRC Senior Resident inspector, MNS l

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Document Control Desk June 26,1992 Page 3 MCGulRE NUCLEAR STATION RESPONSE TO NOTICE OF VIOLATION Yiolatigo169192dh01 Technical Specification 6.8.1a requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in Appondix A of Regulatory Guide 1.33 Revision 2, February 19'18, which includes the operation af safety related systems, maintaining containment integrity, and performing surveillance tests on safety-related equipment. Licensee's Procedure OP/1/A6250/o3A, Enc'osure 4.1, Establishing BW (Wet Layup Recirculation) Step 1.3, require 1 that the condensato booster pumps be Ci for putting a steam generator in wel lay-up condition.

Contrary to the above, on May 6,1992, a licensed operator failed to adhere to procedure OP/1/A6250/03A, for putting a steam generator in wellayup condition, in that a condensate booster pump was left running. This resulted in the actuation on an engineered safety feature actuation, main steam isolation on high pressure negative rate change.

l This is a Severity level IV Violation (Supplement 1) applicable to Unit 1 only.

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1.

Reason for Violation:

On Ma) 6, at 0121, Unit 1 was in Mode 5 (Cold Shutdown) and in the process of performing procedure OP/t/6100/02, Controlling Procedure For Unit Shutdown, During the shutdown process the Steam Generatois (SG) are stored wet using Procedure OP/1/A/6250/0M SG Cold Wet Lay Up Recirculation. During the filling process SG 1D was overpressurized. When the pressure was released, an Engineered Safety features (ESF) actuation occurred.

Specifically, the actuation was Main Steam isolation due to high pressure negative rate change. A!! the appropriate valves associated with Main Steam isolation moved to their proper position. Two factors contributed to the ESF actuation, a technical error in the procedure and inadequate procedural compliance.

TECHNICAL ERROR IN PROCEDURE-Level Setpoint The setpoint for level in Procedure OP/1/A/6250/03A should have had a lower value than the value listed, The level in the procedure is appropriate when the unit is at 100% power, but needs adjustment / correction when tne unit is off line.

Document Control Desk June 26,1992 Page 4

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INAPPROPRIATE PROCEDURAL COMPLIANCE-Poor Communication Before utarting the lay up for SG 10, the Reactor Operator at the Controls (ROATC) attended a crew meeting about the outage activities. In the meeting Operations (OPS) management stated that the Main Condensate (CM) Systern should remain in operation during the outage.

Experienced crew listening during the meeting knew thct it is possible to operate CM without the Condensato Booster pumps. However, the relatively inexperienced ROATC didn't know the CM pumps were not necessary to keep CM in operation. Later, the ROATC romerubend the crew meeting while using Procedure OPA/A/0250!O3A SG Cold Wet Lay Up Recirculation to fill SG 1D.

The ROATC read Section 1.0 Initial Conditions, in Procedure OP/1/A/6250/03A which states that all Condensate Booster pumps are off during the wel lay up process. But in addition l' using Procedure OP/1/A/6250/03A, the ROATC also referred to Procedure OP/1/A/0100/02 step 2.50.2.

That step read, *lf desired, place the switches for the non-operating CM Booster pump (s) to the 'STOP' position and stop the running CM Booster p. imp (s)" When he read "If desired. ~ hi2 belief that leaving a CM Booster pump running was e acceptable option and not a dehnite requirement to stop prior to initiating SG 10 wet lay up.

The ROATC snould have clarified the two procedures and the intentions of OPS management with available, experienced, licensed operations personnel.

2.

Corrective actions taken and results achieved:

Immediately -OPS personnel stopped filling SG 1D and subsequently reset the main steam isolation valves and returned those valves to the original position.

3.

Corrective actions to be taken to avoid further violations:

1)

COMPLETE July 1,1502 Correct the technical errors in Procedures OP/1 and 2/A/6250/03A as follows.

Change Procedures OP/1 and 2/A/6250/03A to state "When the last S/G level indication (NR or WR) for the applicable S/G stops increasing with no sigr'ilicant change in fill rate, continue filling that S/G for 20 minutes, then secure feeding the S/G by closing its associated valves."

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Enhance Proceduros OP'1 arid 2/A/6250/03A by adding a sign off stop that states

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  • while estab!!shing wel lay up conditions in a SG, all Cc;1donsato Dovcier Pumps shall I

be off".

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2)

COMPLETE December al,1992 i

Reemphasize the interd 4rd p9tpve of initial conditions in procedutos to OPS licensed 4

oporators during annual roqualification training.

3)

COMPLETE June 1,1993 The Procedural Compliance Group is addressing situations when procodores are not proporly used as substantiated by this violation, Their recommendations will be implomonted by Juno 1,1993.

4.

Full compliance will be achieved by December 31,1992 for actions directly portaining to this violation. Full compliance for the generic problems in this violation will be achloved June 1,1993.

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