ML20101P558
| ML20101P558 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/03/1992 |
| From: | Mcceekin T DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-09, 92-9, NUDOCS 9207130121 | |
| Download: ML20101P558 (9) | |
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Mc Guirr Nazirar Genernliors Department DcrIWStJcnt
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07/03/92 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station, Unit i and 2 Inplant Review Number 92-09 Gentlement Attached is Inplant Review Report 92-09 concerning the Groundwater Monitoring System.
This 30 day report is submitted as a special report persuant to Selected Licenseo Commitment, Section 16.9-8, Remedial-Action Paragraph a.2.
This event is considered to be of no significance with respect to the health and safety of the public.
Very truly yours,.
fY}%M T.C. McMeekin TLP/bcb Attachment xc Mr. S.D.-Ebneter-INPO Records Center Administrator, Region II Suite 1500 U.S._ Nuclear Regulatory-Commission 1100 Circle 75 Parkway 101 Marietta St.,
NW, Suite 2900 Atlanta, GA 30339
-Atlanta, GA 30323 Mr. Tim ~ Reed'-
Mr. P.K.' Van Doorn U.S. Nuc1 ear-Regulatory Commission NRC Resident Inspector Office of Nuclear React.or Regulation McGuire Nuclear Stat.lon Washington, D.C.
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MCGUIRE SAFETY REVIEW GROUP INPLANT REVIEW REPORT 1.
RtPORT NUMBER:
92-09 2.
DATE OF REVIEW:
June 1992 3.
SUBJECT DESCRIPTION:
The groundwater level monitors have setpoints which exceed Selected Licenseo Commitment (SLC) values due to a Management Deficiency.
This 30 day report is submitted as a special report pursuant to SLC Section 16.9-8, Remedial Action a.2.
9 4.
EVALUATION AND COMMENT:
Abstract During a Design Basis Documentation (DBD) review of the Groundwater Level Control (WZ) system, it was determined that 4 of 6 total Selected Licensee Commitment (SLC) related groundwater level monitors have setpoints which exceed the SLC, Section 16.9-8 value.
It was also determined that 1 of 5 total Technical Specification (TS) related groundwater level monitors has an alert setpoint which exceeds TS Table 3.7-7 value.
Units 1 and 2 were in Mode 5 (Cold Shutdown) at the time 01 discovery. An investigation was initiated to determine corrective actions to be taken.
The cause of this event
.is Management Deficiency because there have been l
discrepancies assoc!.ated with the groundwater level monitoring portion of the WZ system which have existed since M6rch 1989, when L
TS 3/4.7.13 was changed.
Background
Since the lower elevations of some nuclear safety related systems, components, and structures are below the naturally occurring water table, a nuclear safety related WZ system was installed to lower the water table (reference ycGuire Final Safety Analysis Report (FSAR) Figure 2B-3).
The WZ system collects groundwater in wall drains, base mat flow channels and sumps, then pumps the collected wator f rom the suuips to the surf ace water drainage system, thereby
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DPC/MNS
'INPLANT REVIEW #:92-09 Page 2 of 8 creating a depression in the water table.
Presently, during normal operation of the WZ system, grour.dwater level is maintained at or below elevation 712 feet mean sea level (MSL) in the Auxiliary building areas and elevation 717 feet MSL in the Reactor building areas.
Groundwater level is monitored at 11 well locations that provide annunciator alarms in the Control Room.
Operations staff use McGuire procedures, OP/1 and 2 /A/6100/0101, Annunciator Response for Panel AD-8, to respond to groundwater monitor alarms.
The procedure provides instructions for Alert, liigh, and 111gh-high alarm levels.
The Alert and liigh level alarm results in the dispatch of an operator to check the groundwater monitor panel and the actual monitor that is in alarm.
For the liigh-high level groundwater alarm, the procedure refers to the TS and requires that the operations Shift Supervisor be informed.
If the liigh-high alarm occurs without previous alarms at the Alert and liigh levels simultaneously, Instrument and Electrical (IAE) personnel are also to be contacted.
At the Iligh-high level alarm, the TS requires the unit to be in at least flot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Selected Licensee Commitment (SLC) 16.9-8, Groundwater Level Monitoring System, requires that i f one or more of the required monitors are inoperable for more than 7 days, submit a special report to the NRC within 30 days documenting the results of the investigation of the inoperable monitor (s).
Description Of Event On October 31, 1984, Duke submitted a proposed revision of TS 3/4.7.13, Groundwater Level, to the NRC.
The proposed Thange was submitted to eliminato inconsistencies between the TS and the actual capabilities of the WZ system groundwater level monitoring equipment.
At tho time, the TS did not differentiate between setpoints of the interior groundwater monitors, which detected groundwater level at 2 feet 8 inches above the top of the floor slabs and the exterior monitors, which detected groundwater level l
at the top of tho floor slabs.
The NRC subsequently requested i
supplemental information regarding the TS proposed change.
An analysis / investigation of a pprtion of the WZ system was initiated by Engineering and Station personnel.
From February 1985, through March 1991, there was considerable I
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DPC/MNS
' INPLANT REVIEW #192-09 Page 3 of 8 discussion which took place between Duke and NRC personnel concerning WZ system requirements which were to be documented in TS and the SLC, During this period Duke personnel performed many inspections, implemented numerous modifications, and performed engineering reviews of the WZ system.
This offort has been documented, in part to the NRC in correspondence which was generated throughou this time period.
On May 12,1992, while Design Engineering personnel were performing a review and documentation development (Design Basis Documentation development) of the WZ system, it was determined that 1 groundwater level monitor may have an alert setpoint which exceeds the TS Table 3.7-7 value.
During subsequent review and investigation, it was aise determined that 4
groundwater level monitors may have setpoints which exceed the SLC, Section 16.9-8 value.
On June 5, 1992, a meeting was held with Design Engineering and station Regulatory Compliance personnel in attendance to determine if a problem existed with the WZ system.
At this time, it was determined 4 groundwater level monitors have setpoints which exceed the SLC, Section 16.9-8 value and 1 groundwater level monitor has an alert setpoint which exceds the TS Table 3.7-7 value.
Subsequently, PIR 0-M92-M97 was initiated.
On June 8, 1992, during a Safety Review Group (SRG) review and investigation of PIR 0-M92-0097, it was determined that the i groundwater monitors and 1 TS related monitor were technically inoperable and that a reportable event per SLC, Section 16.9-8 a.2, had occurred.
Subsequently, TS monitor 2WZLS5070 was declared inoperable and logged in the Unit 2 Technical Specification Action Item (TSAIL) Logbook.
On June 9, 1992, a Component Engineer wrote work request 602139 to gather additional field information and confirm existing data on the groundwater level sampling wells and detectors.
l On June 17,1992, Design Engineering, System Engineering, Component Engineering, Regulatory Compliance, and SRG personnel met to discuss resolution of and formulate an action plan for resolution of the Groundwater Monitoring System problems.
On June 19, 1992, IAE personnel were assisted by personnel with surveying expertise who obtained additional data on the well for detector 2WZLF:070 as directed by work request 602139.
The following field data was obtained:
l Depth of well:
41 feet +10.5 inches l
Water found at a depth of:
41 foot +7.25 inches l
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- INPLANT REVIEW #:92-09 J
Page 4 of 8 i
Elevation of top flange of Well from top of floor slab:
3 foot +0 inches
+
Length of detector probe 32 feet +5.75 inches Top of floor slab:
760+5.9375 MSL On June 24,
- 1992, after discussion by General Office (GO)
Engineering, Regulatory Compliance, SRG, and Operations personnel, SLC-monitors 1WZLT5080, 1WZLT5090, 2WZLT5080, and 2WZLT5090 were declared inoporable and logged in the Units 1 and 2 TSAILs, respectively.
Also, required actions and actions to implement regarding the inoperability of these detectors were clarifico with station-personnel.
Conclusion The cause of this event is Management Deficiency because of discrepancias associated with the groundwater level monitoring portion of the WZ system which have existed since March 1989, when TS 3/4.7.13 was changed.
The TS revision approved by the NRC on March 2, 1989 listed the setpoint for all TS related groundwater monitors at a level of 731 feet MSL.
This is the correct value for 4 of the 5 TS related detectors.
However, the value agreed upon by McGuire Nuclear Station (MNS) and GO personnel for detector 2WZLS5070 was' 731 feet
+6 inches MSL. -The 731 feet +6 inches MSL value was reflected and
~ approved 'in the TS draft documentation...
During the event-
-investigation ~it could not be determined whether the 731 feet MSL value was submitted in error to the NRC or if an error occurred during printing and distribution of the NRC approved documentation',
in which the "+6" notation was dropped.
This error was undetected at the time becauso of less that adequate review of packages to or from the NRC.
At the time, the GO Licensing group was experiencing a reorganization and personnel turnover and this could have been a factor.
In late 1991, Duke _ Power Company _was reorganined and responsibility for TS and related changes were shifted from the GO to the' individual nuclear stations.
The McGuire Nuclear Station
.(MNS) Regulatory Compliance group currently-. processes TS_and SLC changes 1at;MNS and controls / reviews within this organization will eliminate less than adequato Teviews.of future TS revisions since
~the Regula, tory Compliance group is developing a procedure to provide guidance for development and processing of TS revisions.
- Also,- there have..been additional typographical omissions and errors in TS revisions and FSAR updates related to the WZ system and l-l l
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DPC/Mf1S
' It4 PLAT 4T REVIEW #192-09 Page 5 of 8 associated equipment.
These errors have been propagated in the past, in part, because there was no single station group following plant system related performance, problems, and enhancements. This contributed to the continued lack of resolution, and identification of WZ system deficiencies.
MNS management has recognized that a dedicated system engineering organization is beneficial in tracking and solving wide ranging system related deficiencies and developing potential improvements.
Subsequently, an engineering organization was established, in part, to monitor plant systems and provide dedicated engineering support.
This organization includes an engineer assigned to the WZ system.
A working group consisting of Mtis System Engineering, Component Engineering, Regulatory Compliance, and GO Engineering personnel i
was established to resolve the Groundwater Monitoring System problems.
The WZ system current unresolved problems are:
1.
TS related detector 2WZLS5070 actual setpoint is higher than the setpoint allowed by TS Table 3.7-7 value.
2.
SLC related detectors 1WZLT5080, 1WZLT5090, 2WZLT5080, and 2WZLT5090, actual setpoints are 8 inches higher than the setpoint allowed by SLC, Section 16.9-8 Current-WZ system problems which have solutions in progress are:
1.
All remaining TS and SLC detectors will be added to the TS Reference Manual,Section III, TS Required Mechanical Equipment.
2.
An FSAR revision will be submitted to the WZ system and related equipment discussions which are in agreement with j
the system as actually installed.
l During the event investigation, a concern was raised by SRG I
personnel of potential undetected violations of current TS requirements.
Therefore, a data search of the Control Room TS
- logbook and WZ system equipment history files from March 1,1989 to June 5, 1992 was conducted.
Detector 2WZLS5070 was considered to be inoperable during this time period.
The review found no more than 2 TS related WZ detectors inoperable during the same time period of-the review.
Therefore, there is no evidence that TS Limiting Condition For Operation (LCO) 3/4.7.13,. Groundwater Level, which requires action to be taken if any 3 of the 5 monitors is inoperable was challenged during the time period from March 1989 to June 5, 1992. -The Diesel Genprator (DG) room groundwater monitors are currently calibrated per the FSAR.
There were no personnel injuries, radiation overexposures, or
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- INPLANT REVIEW # 92-09 Page 6 of 8 uncontrolled releases of radioactive material as a result of this event.
Corrective Actions Immediate none Subsequent 1.
PIR 0-M92-0097 was generated to investigate setpoint problems with TS and SLC related groundwater monitors.
2.
Engineering,
- Design, and IAE personnel inspected WZ wells and detectors to gather data about groundwater monitoring equipment.
3.
TS monitor 2WZLS5070 was declared inoperable and logged in the Unit 2 TSAIL Logbook.
4.
SLC monitors 1WZLT5080, 1WZLT5090, 2WZLT5080, and - 2WZLT5090 were declared inoperable and logged in the Units 1
and 2
- TSAILs, respectively.
5.
A working ' group consisting of MNS Cystem Engineering, Component Engineering, Regulatory l
Compliance, and GO Engineering personnel wac l-established to resolve the Groundwater l
Monitoring System problems.
System Engineering personnel agreed to accept lead l
responsibility for coordinating the activities associated-with investigation and correction of the WZ system deficiencies.
l Planned 1.
An evaluation will.be performed to determine
-- the -
desired setpoint(s) for-detector 2WZisS5070.
The High-high level setpoint will be 731 feet
+0 inches MSL.
The evaluation will include-a determination of the feasibility of adding a float assembly to provide an, alarm below the High-high level.
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DPC/MNS INPLANT REVIEW # 92-09 Page 7 of 8 2.
The following TS and SLC detectors will be added to the TS Reference Manual,Section III, TS Required Mechanical Equipment:
Detector Requirement lWZLS5060 SLC IWZLT5090 SLC 2WZLS5060 SLC IWZLS5070 TS lWZLT5100 TS OWZLT5110 TS 2WZLS5070 TS An FSAR revision will be submitted to the WZ 3.
aystem and related equipment discussions which is in agreement with the system as actually installed.
An Evaluation will be performed to change the 4.
SLC to reflect the ac' ual calibration setpoint of the Diesel Generator room WZ monitors, which are currently calibrated por the FSAR.
5.
A procedure to provide guidance for development and processing of TS revisions will be developed.
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- INPLANT REVIEW #:92-09 Page 8 of 8 ATTACHMENT 1 TS And SLC Groundwater Level Monitor Instrumentation Applicable Designation Location Hoference IWZLS5060 Unit 1 Reactor building, SLC Exterior 1WZLT5000 DG 1B room, Interior SLC IWZLT5090 DG 1A room, Interior SLC 2WZLS5060 Unit 2 Reactor building, SLC Exterior 2WZLT5080 DG 2B room, Interior SLC 2WZLT5090 DG 2A room, Interior SLC 1WZLS5070 Auxiliary building West TS wall, Exterior 1WZLT5100 Auxiliary building, PPS1, TS Interior OWZLT5110 Auxiliary building, 0056, TS Interior 2WZLS5070 Auxiliary building East TS wall, Exterior 2WZLT5100 Auxiliary building, PP61, TS Interior
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