ML20150F242
| ML20150F242 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/06/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807180194 | |
| Download: ML20150F242 (8) | |
Text
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DUKE POWER GOMPANY P.O.190X 33180 CIIARLOTTI:. N.O. 28242
!!AL II. TUCKEH 1et menoxe vue emessent (704) 073 4,131 NtT4. JAR PSOEKOT104 July 6, 1988 F
U.S. Neelear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369, -370 NRC/01E Inspection Report Nos. 50-369,370/A8-12 Reply to a Notico of Violation Gentlemen:
Pursuant to 10CFR 2.201, please find attached Duke Power Company's response to the violations and deviation identified in the subject inspection report.
Note that Duke's response to Violation 369, 370/88-12-04 is being delayed until July 22, 1988.
Should there be any questions concerning this matter, contact S.E. LeRoy at (704) 373-6233.
Very truly yours, Y'
Hal B. Tucker SEL/294/ bhp Attachment xc Dr. J. Nelson Grace Regionni Administraur, Region II U.S. Nuclear Regulat e Commission 101 Marietta St., NW, Suite 2900 Atlanta, GA 30323 Mr. Darl Hood U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Mr. W.T. Orders NRC Resident Inspector f
McGuire Nuclear Station
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DUKE POWER COMPANY McGUIRE NUCLEAR STATION REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-369, 370/88-12 Violation 369, 370/88-12-03 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, requires that procedures be written and implemented for startup, operation and surveillance i
testing of safety related equipment including auxiliary feedwater systems, diesel generators and associated support equipment.
Technical Specification 4.0.5 requires that inservice testing of ASME Code Class 1, 2, and 3 pumps be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code, 1980 Edition.
i ASME Boilet and Pressure Vessel Code, 1980 Edition,Section XI, Subsection IWP, Article IW -3000, Inservice Test Procedures, Table IWP-3100-2, Allowable Ranges of Test Quat.t (ties, specifies vibration ranges to be used, based on pump baseline data, to determine if inservice test results are acceptable or if actions are required.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instruo: ions, procedures, or drawings, of a type appropriate to the circumstances anJ shall be accomplished in accordance with these instructions, procedures, or irawings.
Instructions, procedures, or i
drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Station Directive 2.8.2, Operability Determination, Attachment 1 Paragraph 8, requires a technical disenssion to be documented as to why the concern idertified does not prevent the item from fulfilling its intended safety function.
Station Directive 3.1.19, Safety Tags, paragraph 7.4.4 step 2 states tag removal shall be done in the designated sequence.
Example No. 1:
Contrary to the above, Procedure PT/1/A/4252/01, Auxiliary Feedwater Pump Number 1 Performance Test, was inadequate in that horizontal vibration ranges j
specified did not correspond to those required by ASME Section XI and pump baseline data.
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Example No. 2 l
Contrary to the above, Station Directive 2.8.2 was not properly implemented in i
that no technical discussion of operability was documented in the operability l
determination associated with Problem Investigation Report (PIR) 0-M88-0089.
l This PIR concerned the operability of the turbine driven auxillary feedwater pumps with questionable contact area between the emergency head lever and the tappet nut.
Example No. 3 Contrary to the above, Station Directive 3.1.19 was not properly implemented in that the restoration and tag removal performed on May 12, 1988, for work requests 500184 and 083804 was not done in the sequence designated on the Removal and Restoration Record Sheet. This led to an ESF acutuation involving swap over of CA B pump suction supply to nuclear service water.
Example No, 4 Contrary to the above, Procedure PT/1/A/4350-04B, D/G 1E Load Sequence Test, was not properly implemented on May 16, 1988 during a test on Unit 1 in that the requirements of step 12.9 were not performed.
This led to an inadvertent actuation of ESF equipment.
This is a Severity Level IV (Supplement I) violation.
Reply to Example No. 1:
1.
Admission or denial of violation:
The violation is admitted as stated.
2.
Reason for the violation if admitted:
The violation criteria were incorrectly calculated durfm;; the IWP program d evelo pment.
3.
Corrective steps which have been taken and results achirted:
Procedure changes have been made to PT/1/A/4252/01 to correct this error.
The remaining IWP pts have been reviewed and are correct per ASME section XI requirements.
4.
Corrective steps planned to avoide further violations:
No additional steps are required.
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5.
Date when full compliance will be achieved:
McGuire is in full compliance at this time.
Reply to Example No. 2:
1.
Admission or denial of violation:
The violation is admitted as stated.
2.
Reason for the violation if admitted:
Mechanical Maintenance personnel write operability determinations infrequently.
In their attempt to be thorough, they included abundant background information in the determination.
They also depended upon Operations and Compliance personnel to assist in the evaluation of the completeness of the operability determinations.
Due to the abundant amount of information provided in the determination, station Operations and Compliance personnel read more into the determination than was there.
They failed to recognize that the information provided did not constitute a technical discussion of why the turbine driven CA pump was operable.
3.
Corrective steps which have been taken and the results achieved:
The operability evaluation was rewritten to provide a better technical description.
4.
Corrective steps planned to avoid further violations:
This event will be discussed with station personnel that are involved with operability determinations.
The importance of fully evaluating Operability statements from other groups will be emphasized.
5.
The date when full compliance will be achieved:
Full compliance vill be achieved by September 1, 1988.
Reply to Example No. 3:
1.
Admission or denial of violation:
The basis for the violation is admitted but not as stated in the notice.
McGuire did not properly implement Operations Management Procedure (OMP) 2-17 on Removal and Bestoration Record Sheets, not Station Directive i
3.1.19 as stated in the notice.
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2.
Reason for the violation if admitted:
The Operations personnel involved failed to make the necessary procedure changes as required by the Station Directive before beginning work.
3.
Corrective steps which have been take and the renuits achieved a.
The proper alignment was instituted.
b.
The Operatf.ons personnel involved were counselled.
c.
A representative from each _ operating shift and the periodic test group reviewed and discussed the event.
The requirements of the affected Station Directive were also discuss 6d.
4.
Corrective steps planned to avoid further violationst OMP 2-17 was changed to clarify the method of assigning sequences for removal and restoration steps.
An addition was also made to OMP 2-17 addressing a formal way to change a previously approved removal and restoration sequence.
These changes and the error leading to these changes were covered with all shifts and the staff by the Superintendent of Operations, stressing the need for procedural compliance.
5.
The date when full compliance will be achieved:
Full compliance was achieved May 27, 1988.
Reply to Example No. 4:
1.
Admission or denial of violatient The violation is admitted as stated.
2.
Reason for the violation if admitted:
The subject PT had previously been successfully executed and the test coordinator was both qualified and experienced.
The ESF actuation was caused by a combination of communication problems (between the test coordinator located remotely and test support personnel in the Control l
Room) and PT deficiencies which did not require verification of the RESET I
action on the load sequencer.
3.
Corrective steps which have been take and the results achieved a.
The importance of communication skills during crew / staff meetings was emphasized.
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Changes were drafted to the four BGLS pts tot 1.
Clearly delineate that the RESET action is done by Control Room personnel.
ii. Verify that the DGLS action has occurred via Control Room indications.
iii. Add "CAUTIONS" to the PTr: fD alert test personnel to the potential of ESF actuationa and to suspend test execution and seek technical assistance t) ; p'oper RESET status is indicated by the DGLS cabinet indicatn zights.
4.
Corrective steps planned to avoid further violations:
The procedure changes will be communicated to test personnel.
5.
The date when full compliance will be achieved:
McGuire will be in full compliance by September 1,1988.
Violation 369, 370/88-12-04:
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Crieterion XI, requires that a test program be i
established to assure that all testing required to demonstrate that systems I
and components will perform satisfactorily in service is identified and I
performed in accordance with written test procedures.
Contrary to the above, the test program established to demonstarte that the turbine driven auxiliary feedwater pumps will perform satisfactory in service was inadequate.
The procedure use to test the pumps does not perform the test in the as found condition in that the steam lines to the pump turbine are drained of condensate prior to testing.
This is a Severity Level IV (Supplement I) violation.
Reply to Violation:
Due to continuing review of this question additional time is needed in order l
to prepare a response. A supplemental response will be submitted by July 22, 1988.
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1 Violation 370/88-12-01:
Technical Specification 3.7.11 requires that all fire barrier penetrations separating portions of redundant systems.important to safe shutdown within a fire area and all sealing devices in fire rated assembly penetrations (fire
- doors, fire windows, fire dampers, cable piping,' and ventilation duct penetration seals) be OPERABLE.
With one or more of the above required fire barrier penetrations and/or sealing devices inoperable, within I hour either establfsh a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol.
Contrary to the above, fire doors 601C and 601D were found blocked open on May 9,1988, rendering them inoperable for an undetermined period of time without stationing a fire watch or verifying the operability of fire detectors on at least one side of the inoperable doors and establishing an hourly " re watch patrol.
This is a Severity Level IV (Supplement I) violation and applies to Unit 2.
j Reply to Violation:
1.
Admission or denial of vielation:
The violation is admitted as stated.
2.
Reason for the violation if admitted:
This violation occurred due to Performance personnel error and due to the l
excessive ambient temperature which is created in the TD Cl. pump room when the turbine le running.
The Performance personnel involved blocked the door open to increase air flow into 4e room.
3.
Corrective steps which have been take and the results achieved:
a.
Responsible Performance personnel have been counseled and disciplined as appropriate, b.
The McGuire Safety Section has been requested to conduct a heat stress inspection of the room.
4.
Correr <.ge steps planned to avoid further violations:
No furcher corrective actions have been identified.
Past training on this topic has been extensive and is considered adequats to assure compliar.ce by station personnel.
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5.
The date when full compliance will be achieved:
McGuire is in full compliance at_this time.
Deviation 369, 370/88-12-02:
The following deviation was identified during a Nuclear Regulatory Commission (NRC) inspection conducted on April 23 - May 20, 1988.
In a response dated May 29, 1987, to Violation 87-04-01 issued on April 29, 1987, the licensee stated that "Training and staff licensed personnel are no longer permitted to make an operabili ty determination.
Operability determinations by training instructors and staff SRO's must be made with the concurrence of a regular shift SR0".
Contrary to the above, only a staff SRO was involved with the operability determination associated with Problem Investigation Report 0-M88-0089 concerning turbine driven auxiliary feedwater pump operability.
Reply to Deviation:
The response to Violation 8 7-04-01 was stated as above.
However, what was implied but not stated was the fact that this statement applied to personnel with inactive licenses.
The response to the violation will be revised to state:
Personnel with inactive licenses-are not permitted to make Tech Spec Action Item Logbook (TSAIL) entries independently. TSAIL entries will be made by the control room SRO who holds an active license.
The control room SRO may consult various staff personnel as required.
This revision to the May 29, 1987 response will be completed by September 1, 1988.
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