ML20133D479
| ML20133D479 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/23/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8507220216 | |
| Download: ML20133D479 (2) | |
Text
, e; DUKE POWEn GOMPAhT P.O. Isox 33:80 l
S CHARLOTTE. N.C. 28242 RALB. TUCKER TELEPHONE vice reamsmas, (704) 073-4 FEM mootsaa emnerction tp May 23, 1985 "c5 3-o Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission A
Region II l
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
[
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370 I
Reference:
RII:CFS NRC/0IE Inspection Report 50-369/85-09 and 50-370/85-10
Dear Dr. Grace:
Pursuant to 10CFR 2.201, please find attached a response to violation 50-369/85-09-01, 50-370/85-10-01 which was identified in the above referenced
' inspection report. Note that Duke Power Company is denying the alleged-violation.
Very truly yours, k
fhW H. B. Tucker l
PEN /mjf Attachment t
l cc:
Mr. W. T. Orders Senior Resident Inspector - NRC McGuire Nuclear Station r
l l
0507220216 850 g3,
j/g PDR ADOCM 050 f
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DUKE POWER ~ COMPANY MCGuire Nuclear Station Response to NRC/0IE Inspection Report 50-369/85-09 and 50-370/85-10 Violation 50-369/85-09-01, 50-370/85-10-01, Severity Level IV (Supplement I):
10 CFR 50 Appendix B' Criterion III and the licensee's accepted QA program Section 17.2.3 collectively require that measures be established to assure that applicable regulatory requirements are correctly translated into speci-fications, drawings, procedures and instructions.
The QA Program endorses Regulatory Guide 1.64, Revision 2, and ANSI N45.2.ll-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants. Paragraph 3.2.20 of this standard states that-the design input shall include test requirements including in-plant tests and the conditions under which they will be performed.
Contrary to the above, Duke's Design Engineering Department does not specify post-modification acceptance test requirements and test acceptance criteria for station modifications designed by the Design Engineering Department.
Response
Duke Power Company denies the alleged violation.
The violation was identified as failure to meet the requirements of ANSI N45.2.11-1974, Section 3, titled
" Design Input Requirements". This section addresses requirements to assure an adequate design. As such, subsection 3.2 provides a list of typical design inputs. Paragraph 3.2.20 discusses test requirements that must be factored into the design (not test requirements that must be specified by the design organization). An example is pipe and support design for the dead weight of water during hydro testing in addition to the loads seen during operation. Duke Power Company's design program fully complies with the ANSI Standard,10CFR50 Appendix B Criterion III and Regulatory Guide 1.64.
Modifications are designed by the Design Engineering Department or the Nuclear Production Department. Operational test requirements / criteria are defined by the Nuc1 car Production Department, with input from the Design Engineering Department as appropriate, and tests are performed by the Nucicar Production Department. The Nuclear Production Department Administrative Policy Manual, which defines fundamental administrative policies for the conduct of operations at Duke Power Company nuclear stations, requires testing for the 2rpose of confirmation that station modifications reasonably produce expected cesults and do not adversely affect the safety of operations.
It further requires that special testing procedures (if required) state the criteria for evaluating the acceptability of the results of the specified testing. In addition, the Nuclear Production Department has controls which meet 10 CFR50 Appendix B Criterion III, ensuring that testing criteria inputs from the Design Engineering Department are reviewed for consideration in development of post-modification testing requirements. Consequently, Duke is presently in full compliance with 10 CFR and QA program requirements in this area.
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