ML20136H087
| ML20136H087 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 03/12/1997 |
| From: | Barron H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703190047 | |
| Download: ML20136H087 (7) | |
Text
... _.
.O DukeIbwer Company H. B. Banor McCuire Nuclear Generatum Department VicePresident 12100Hagers FerryRoad(MC0lVP)
(104)875 4300 i
.,thawa welle. NC2306% BIO (704)S754809 Fat DUKEPOWER March 12,1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk
)
Washington, D.C. 20555 i
Subject:
McGuire Nuclear Station, Units 1 and 2 i
Docket Nos. 50-369 and 50-370 NRC Inspection Report No. 50-369,370/96-11 Violations 50-369/96-11-02 and 50-369/96-1105
)
Reply to a Notice of Violation Enclosed is a response to a Notice of Violation dated February 10,1997 conceming failure to implement i
the temporary modification process and failure to perform a 10 CFR 50.59 review prior to performing a test or experiment not described in the UFSAR.
i Very Truly Yours.
l w
H. B. Barron I
Attachment j
I 1
ep}
/
1 9703190047 970312 PDR ADOCK 05000369 G
.10UU4V lL""%dEdlll%:
15p555555555
..-...m.
I i
1 i
9 U. S. Nuclear Regulatory Commission March 12,1997 i
i l
xc: (w/ attachment) t 5
Mr. Luis A. Reyes Regional Administrator, Region 11 i '
U. S. Nuclear Regulatory Commission
-101 Marietta St., NW, Suite 2900 l
- Atlanta, Georgia 30323 -
1-Mr. Vctor Nerses U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation i
.One White Flint North, Mail Stop 9H3 Washington, D. C. 20555 l.
Mr. Scott Shaeffer i
Senior Resident inspector
. McGuire Nuclear Station
]
l i.
k.
i 3
2
U. S. Nuclear Regulatory Commission March 12,1997 bxc: (w/ attachment)
P. R. Newton (PB05E)
NSRB Staff (EC05N)
P. R. Herran R. A. Jones J. W. Boyle D. A. Baxter R. B. Travis M. T. Cash J. W. Pitesa J. E. Burchfield (ON01RC)
M. S. Kitlan (CN01RC)
J. M. Frye (EC05N)
K. L. Crane E. M. Geddie H. B. Barron W.F. Byrum K. D. Thomas D. M. Jamil R. P. Michael R. B. White R. C. Birmingham L K. Criminger B. J. Dolan P. L. Stiles ELL (ECO50)
RGC File: Inspection Report i
McGuire Nucle r Statio2 Riply to a Nitice cf Violatio.:
Violation 50-369/96-11-02 McGuire Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide d.33, Revision 2, February 1978.
Duke Power Company Nuclear System Directive 301, Nuclear Station Modifications, defines a temporary modification as a physical change or addition of a temporary nature to a station's structures, systems, or components. The Nuclear System Directive also states that installation and removal of temporary modifications are to be controlled in accordance with the approved McGuire Modification Manual.
Contrary to the above, on December 20,1996, the inspector identified a modification involving installation of an additional vital area physical barrier located at the Unit 1 exterior valve vault was not implemented in accordance with the requirements of Nuclear System Directive 301 and the McGuire Modification Manual.
This is a Severity Level IV violation (Supplement I) 1 1
Reolv to Violation 50-369/96-11-02
- 1. Reason for the violation:
An engineering evaluation had determined that the temporary barrier was not a physical change or addition of a temporary nature to the station's structures, systems or components. Guidance provided in the temporary modification manual was subject to a range of interpretations regarding such temporary structures. Further review indicates that the fence located at the Unit 1 valve vault met minimum criteria for a Omporary modification.
- 2. Corrective steos that oave been taken and the results achieved:
a) Operations initially evaluated the potentialimpact of the barrier on plant operations and determined that the barrier would not have a significant impact on operator response to the Unit 1 valve vault. Upon completion of the evaluation, a note was issued to all Operations shift personnel outlining operator actions for access to the valve vault through the security barrier.
However, since no formal communication had been issued to Oor ations shift personnel regarding the security barrier addition, a training sheet was issu d 'o Cperations shift personnel on January 8,1997. A required reading package was also issueu an January 8,1997.
b) Operations conducted two unannounced drills on January 8,1997 to validate operator response times to the Unit 1 valve vault. The response times were within acceptable limits.
l c) The site vice president issued written guidance to all McGuire supervisors, managers,50.59 preparers and qualified reviewers on implementation of the 10 CFR 50.59 screening and evaluation process. This guidance identified the temporary fence as an example of a work activity that should have been processed as a temporary modification. Engineering supervision distributed written guidance to Engineering personnel p GC,ig additional direction for reviewing proposed work activities with respect to modification requirements.
d) The MWification Manual was revised to provide additional guidance on initiation criteria for a temporary modification. This corrective action was completed on March 5,1997.
e) A temporary modification was processed for the security barrier addition and a 50.59 evaluation was performed. These corrective actions were completed on March 11,1997.
l
\\
McGuire Nuclear Station Reply to o N:tice of Violatio:a No similar events have occurred since implementation of these corrective actions.
- 3. Corrective steos that will be taken to avoid further violations:
The corrective actions addressed in section 2 of this response should prevent further violations. A required reading package 97-01-SRN was issued on January 8,1997 to all Operations shift personnel that addressed the physical barrier and how to access the barrier if response to the Unit 1 valve vault is required during emergency situations. Severalindividuals on scheduled time off have not completed the required reading package. This corrective action will be completed by March 31,1997.
4.
Date when full comoliance will be achieved:
McGuire Nuclear Station is now in full compliance. All corrective actions will be completed by March 31,1997.
McGuire Nucle:r Station Riply to o Notice of Violatiom Violation 50-369/96-11-05 10 CFR 50.59 (a) (1) authorizes the licensee to conduct tests or experiments not described in the safety analysis report, without prior commission approval, unless the proposed test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
10 CFR 50.59 (b) (1) requires the licensee to maintain records of the conduct of tests and experiments not described in the safety analysis report. These records must include a written safety evaluation that provides the bases for the determination that the test or experiment did not involve an unreviewed safety question.
Contrary to the above, on March 25,1996, Unit 1 secondary plant hydrazine levels were lowered as a test without performance of a 10 CFR 50.59 written safety evaluation to provide the bases for the determination that the test not described in the FSAR did not involve an unreviewed safety question.
This is a Severity Level IV violation (Supplement I)
Ecolv to Violation 50-369/96-11-05
- 1. Reason for the violation:
The McGuire UFSAR contains a description for making changes to secondary water chemistry parameters included the following section.
From the McGuire UFSAR Section 10.4.7.2.1:
"The basis for the program as described is adapted from vendor recommendations and the Electric Power Research institute (EPRI) PWR Secondary Water Chemistry Guidelines (latest revision) which represent a compilation of the industry-wide experience on protection of secondary side components, including the steam generators.... All exceptions to these Guidelines are by written evaluation and are approved by the Technical System Manager, Chemistry or his designee."
Chemistry personnel interpreted the last sentence in this UFSAR paragraph as guidance that temporary changes to secondary parameters only require written evaluation and management approval. The personnel prepared a written evalua6cn and obtained management approval as described in the UFSAR. This UFSAR description is not clear. This section should only have been used as administrative guidance for changing secondary side chemistry parameters. This section of the UFSAR should not have been interpreted to allow changes to secondary side chemistry parameters without performing 10 CFR 50.59 evaluations.
The site chemistry manual provided guidance that 10 CFR 50.59 evaluations were required for permanent changes to Section 3.1 through 3.7 of the Chemistry Manual. The hydrazine control value listed in Section 3.2 of the manual was not changed because this was not considered a permanent operating condition. Therefore, a 10 CFR 50.59 evaluation was not required by the chemistry manual guidance. This reinforced the belief that temporary changes to secondory side hydrazine did not require a 10 CFR 50.59 evaluation.
i
- 2. Corrective Actions that have been taken and the results achieved:
a) The operating level of hydrazine in the Unit 1 secondary plant feedwater has been retumed to a control value of 100 ppb. No observed effect on core thermal power from de-fouling was observed during this evolution.
McGuire Nuclesr Station Reply to e N:tice ef Violation
)
b) A 10 CFR 50.59 Unreviewed Safety Question evaluation was performed for operating with a 50 ppb control value for hydrazine in the secondary plant feedwater system. This evaluation did not identify an unreviewed safety question.
j c) A change has been initiated to update the UFSAR to clarify that secondary side feedwater control values can only be changed by methods specified in the Chemistry Manual which include performing a 10 CFR 50.59 evaluation.
4 d) The Site Vice President issued written guidance to all McGuire supervisors, managers,50.59 preparers and qualified reviewers clarifying implementation of the 10 CFR 50.59 screening and evaluation process. This guidance identified the change in hydrazine parameters as a change i
that should have been recognized as a test, thus requiring a 10 CFR 50.59 evaluation to be j'
pertormed.
No similar events have occurred since implementation of these corrective actions.
- 3. Corrective steos that will be taken to avoid further violations:
The corrective actions addressed in section 2 of this response should prevent further violations.
Chemistry Management will communicate lessons teamed from this violation by May 1,1997, 4, Date when full comoliance will be achieved:
McGuire Nuclear Station is now in full Compliance. All corrective actions will be completed by May 1, 1997.
l