ML20149G276

Responds to NRC Re Violations Noted in Insp Repts 50-369/97-08 & 50-370/97-08 on 970406-0517.Corrective Actions:Reduced Power Range Channel N-42 Simulated Power to Zero to re-energize Source Range Indication

ML20149G276
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/16/1997
From:	Barron H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-369-97-08, 50-369-97-8, 50-370-97-08, 50-370-97-8, NUDOCS 9707230091
Download: ML20149G276 (5)

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[~T Duke Power Company j,_ _ j A Duke Enery Gmpay EV McGuire Nudear Station N '*"8C'""'

MG01VP 12700 Hagers Ferry Rd.

i HunterwWe, NC 28078-9340 H. B. Barron Vice hesident, McGuire (704) 875-4800 omCE Nudear Generation Department (704) 875-4809 MX July 16, 1997 P

U.

S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555

Subject:

McGuire Nuclear Station, Units 1 and 2

' Docket Nos. 50-369 and 50-370 NRC Inspection Report No. 50-369, 370/97-08 Violation 50-369/97-08-02 Reply to a Notice of Violation Pursuant to the provisions of 10 CFR 2.201, attached is Duke Energy Corporation's response to a Notice of Violation dated June 16, 1997 regarding an inadequate Analog Channel Operational Test (ACOT) procedure.

This violation was identified during inspections conducted between April 6, 1997 and May 17, 1997.

Duke Energy Corporation acknowledges _this occurrence to be a violation of the requirements of Technical Specification j

6.8.1.

The procedure in use at the time was inadequate for the specific conditions.

A~new procedure validation and verification process was recently implemented for maintenance procedures.

The adequacy of the validation and verification process will be reviewed relative to this violation.

If there are any questions concerning this response, please contact W.R. Cross'at (704) 875-4179.

I Very Truly Yours, WC 1

H.

B.

Barron Attachment' uulsinspil 9707230091 970716 PDR ADOCK 05000369;>

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'U.

S Nuclear Regulatory Commission July 16, 1997 xc:

(w/ attachment)

Mr. Luis A.

Reyes Regional Administrator, Region II U.

S.' Nuclear Regulatory Commission Atlanta Federal Center 6l Forsyth St.,

SW, Suite 23T85 Atlanta, Georgia 30323

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Mr. Victor Nerses U.

S. Nuclear Regulatory Commission OfficeLof Nuclear Reactor RegGlation

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One White Flint North, Mail Stop 9H3 Washington, D.

C.

20555 Mr. Marvin Sykes Senior Resident Inspector (Acting)

McGuire Nuclear Station l

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.McGuiro Nuclear Stctica

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Reply.to a Notice of Violation Restatement of Violation 50-369/97-08-02 i^

Technical Specification 6.8.1 requires that written

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procedures shall be established, implemented and maintained

covering the; applicable procedures-recommended in Appendix A j

l of Regulatory Guide-1.33, Revision.2,- February 1978.

i ilpherent in this requirement is that the procedure be i

adequate to perform plant activities.

Contrary;to the above, on May 14, 1997, Procedure PT/1/A/4600/014D *NIS PowerLRange ChannelLN-41 Analog L

Channel Operational ~ Test",. was inadequate in providing sufficient guidance to' bypass properly the reactor l

protection system functions of an inoperable N-41 channel to i

permit testing of channel N-42.

-This resulted in a Unit 1-reactor trip.and engineered safety feature actuation while preparations ~for an approach to reactor criticality were-l

.being made.

This is a Severity Level.IV violation (Supplement I).

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Reply to Violation 50-369/97-08-02

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Reasons for the violation:

Duke Energy Corporation acknowledges this violation.

The reasons-for the violation are addressed below:

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a). Procedure PT/1/A/.4600/014D, NIS Power Range Channel N-41 Analog Channel Operational Test was inadequate I

in that.it did not alert technicians that Permissive P-8 remained unblocked during use of~this procedure.

In addition, the procedure.did notLrefer or transition to' Procedure IP/0/A/3207/09A, Bypassing Power Range Channels in Tripped Condition.

This is the appropriate procedure for bypassing a tripped power range channel.

b) The Operations.Shif t Manager (OSM), in observing that the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> window for plant startup since the previously performed ACOT'was running out, recognized that this could create a perceived time pressure on the operators to commence the startup.

To avoid this time pressure perception, he directed that the ACOT l

be re-performed prior to commencing'startup.

While I

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McGuiro Nuclecr Staticn Reply to'a Notice of Violation this action removed the perceived time pressure from the operators, it placed the performance of the ACOT on the. critical path, thus creating perceived time pressure on the instrumentation t'echnicians. 'This time pressure, combined with other factors, may have led to the decision to use the inappropriate-procedure.

2.

Corrective' steps that have been taken and the results achieved:

a) Immediate corrective actions included reducing power i

range channel N-42 simulated power to zero tc re-energize source range indication, re-establishing main feedwater flow, returning steam generator levels to normal.

b) Procedures PT/1/A/4600/014D, 014E, 014F and 014G -

Analog Channel Operational Tests (ACOT) for all four power range-channels-(Unit 1) and PT/2/A/4600/014D, 014E, 014F and 014G - Analog Channel Operational Tests (ACOT) for all four power range. channels (Unit

-2).were placed on maintenance hold on May 14, 1997.

. c) The " lessons learned" from this event were discussed with all maintenance personnel.in communications sessions.

Topics discussed included procedure use and adherence and the need for increased' focus.when performing first time evolutions.

This corrective action was completed on June 1, 1997.

No similar events'have occurred since implementation of i

'these corrective actions.

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'3.

Corrective steps that will be taken to avoid-further i

violations:

a) All ACOT related procedures identified in section 2.b above will be reviewed to identify additional barriers and guidance that ensure procedures are used in the appropriate plant conditions and for the appropriate L

scope of work.

This review will be completed by L

September 1, _1997 and any needed changes will be incorporated into procedures by December 1, 1997.

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i McGuiro Nuclocr Station Reply:to a Notice of: Violation b). All - station. testing procedures containing provisions

.for use of the NIS/7300 bypass tester instrument bypass steps will be reviewed'for adequacy'by October.1, 1997.

This review will include an assessment of the effects of bypass:on all.. interlocks and trip-logic. Changes-ithat are ~iden';ified ' from this review-will' be 4

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. incorporated into affected procedures by January 31,-

i1998'.

4. - Date when full compliance will' be ' achieved:

McGuire Nuclear Station is'now in full compliance with Technical Specification 6.8.1.

All corrective actions will be completed by January 31, 1998.

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