ML20151P113
| ML20151P113 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/19/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8601030304 | |
| Download: ML20151P113 (6) | |
Text
s.
t om s DUKE POWER GOMPANY P.O. IMut 33180 CIfA14LorrE, N.C. 28242 IIAL II. TUCKER resEPuoxn.
(704) 373-4o;gg vua paesenEnt ML0 LEAR PRODtJ0T10N
/
December 19, 1985 T Di.IJ.?Nel'a d Grace 7 Regional Administrator
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U.S. Nuclear Regulatory Commission Region 11 c:
101 Marietta Street, NW, Suite 2900 (2'
C3 Atlanta, Georgia 30302 m
c2
Subject:
McGuire Nuclear Station Docket No. 50-369, 50-370 o
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Reference:
RII:
NRC/01E Inspection Report 50-369/85-32, 50-370/85-29
Dear Dr. Grace:
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Pursuant to 10 CFR 2.201, please find attached a response to the viola-tion which was identified in the above referenced Inspection Report.
Very truly yours.-
/
M w Hal B. Tucker-JBD/jgm Attachment cc:
Mr. W.T. Orders Senior Resident Inspector - NRC McGuire Nuclear Station e-O
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DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION IN INSPECTION REPORT 50-369/85-32 and 50-370/85-29, EXAMPLES A THROUGH E Violation 50-370/85-29-01, Severity Level IV 10 CFR 50, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qua-11tative acceptance criteria for determining that important activities haye been satisfactorily accomplished.
~ Duke Power Company's approved Quality Assurance Program,. states in part, that Duke Power has established and implemented a quality assurance program which conforms to the criteria established in Appendix B to 10 CFR 50.
The basic written instructions and procedures for operating activities affecting quality are contained in the Nuclear Production Department's Administrative Policy Manual for Nuclear Stations.
Technical Specification 6.8.1.a, states in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
~ February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, states that the following are typical safety-related activities that should be covered by written procedures:
Administrative Procedures on:
(1) Procedure Adherence and Temporary Change Method, (2) Procedure Review and Approval, and (3) Log Entries, Record Retention, and Review Procedures.
Procedures for Performing Maintenance. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, as of September 27, 1985, NRC identified the following examples of failure to meet these requirements.
Example a:
Work Request 123686 OPS,Section III, states, Note: Any tubing work, contact quality control prior.
Administrative Policy Manual, Section 3.3.2.3(b) states, for maintenance activity which affects the pressure boundary of systems or components classified as ASME Boiler and Pressure Vessel Code Class 1, 2, or 3, a code authorized inspector shall be provided an opportunity to review the proposed activity prior to the beginning of work if required.
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Contrary to the above, Quality Control was not provided an opportunity to y
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review a tubing test tee replacement on Cold Leg Accumulator Level Transmitter w 2N1LT 5110 which was within a safety class boundary.
g Response to Example a:
J.*
Duke Power Company denies this example of the alfeged violation. The fitting in question was a test tee located between the manifold valve and the trans-mitter. As such, it was exempt from the ASME Boiler and Pressure Code per ICS-A-ll, "Mechantcal Instrumentation and Controls Instrumentation Standards
= Installation: Field Practices" which states:
"When a safety class materials identificatiorOflag is shown at an instrument, the impulse line between the isolation or manifold valve and the instrument is excluded from ASME section III code, requirenents." Thus, there is no deviation from Administrative Policy, Manual section 3'.3.2.3(b),.
M V
Example b:
McGuire Station Directive 2.1.1, Control of Master File Documents, states, O
document retention requirements are six (6) years or service life whichever is greater for copies of completed work' request and equipment histories for measuring and test devices and installed process instrumentation.
Contrary to the above, work request 123636 OPS, was missing a completed calibration data sheet for a cold leg accumulator level transmitter 2NILT5080 C
and the independent verification shdet for the April 24, 1985, calibration of level transmitters 2NILT5060 and 2NILT5070.
Response to Example b:
1.
Admission or deniali of the alleged violation:
Duke Power agrees 't$at' the violation occurred as stated.
1 2.
Reasonsforvioldtion:
The work was performed by several crews, working different s$1fts, over several days. Additionally, the work was performed in a contaminated environment.
Some of the paperwork may have been lost in the turnover between crews. Recollections of some technicians indicate that some data were recorded on the back of the procedure due to lack of extra data sheets in'the contaminated area. The procedure was probably discarded as contaminated waste.
3.
Corrective steps which have been taken and the results achieved:
At the time of the NRC visit, a search was made for the missing documents.
Th'ey could not be found.
4.
Corrective steps which will be taken to avoid further violations:
No further action is planned.
5.
Date when full compliance will be achieved:
McGuire Nucl ar Station is presently in full compliance.
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Example c:
McGuire Station Directive 4.2.1, Handling of Station Procedures, states in part, that this directive applies to all, both safety-related and nonsafety-related.
If any deviation from the method and steps specified in a procedure is necessary, a procedure change shall be_ initiated.
It is the responsibility of each person using the procedure to insure the procedure is followed or appropriate procedure changes are initiated and approved prior to using the procedure.
Contrary to the above, the licensee failed to follow procedure IP/0/A/3214/04, Calibration Procedure for Rosemount Model 1152 Transmitters, while performing work request 123686 OPS on cold leg accumulator level transmitters 2NILT5060 and 2NILT5070, in that, Step 10.1.7 of'the procedure required " applying input pressure at approximately 0, 25, 50, 75, and 100% of input range specified for this transmitter." The licensee only applied input pressures to the transmitter at the 0 and 100% ranges. Additionally, the calibration reference data and method of calibration was unreviewed and procedure change was not initiated and approved for this method of calibration.
Response to Example c:
1.
Admission or denial of the alleged violation:
Duke Power agrees that this example of the violation occurred as stated.
- 2. Reasons for violations:
Calibration of the transmitters at 0, 25, 50, 75, and 100% levels was completed under work requests 023345 through 023352 earlier in the outage.
There was no reason to suspect the span and linearity of the transmitters.
The suspected source of the problem was inadequate venting and/or incorrect zero. As such, all of the work being performed under this work request was considered to be troubleshooting. Normal practice is not to perform the complete procedure (s), but rather to perform those sections necessary to correct the problem. The 0% and 100% checks were considered to be sufficient to verify calibration.
It was suspected that the calibration reference data given in the procedure was in error. To resolve this question, a transit survey of transmitter elevations was performed. Data from this survey showed that the calibration reference data was essentially correct. Average error in the reference data was.8% with a maximum error of 1.9%.
The setpoints in the calibration pro-cedure have a 5% conservative margin with respect to Technical Specifications requirements; thus, even if the survey data were wrong, the Technical Specifi-cations requirements would be met.
The decision to proceed without a procedure change was based upon several factors. These factors included:
- 1) the instru-ments were non safety related; 2) the work was of a troubleshooting nature, not requiring calculation of complete new reference tables in IP/0/B/3000/03;
- 3) the new survey data indicated that there was no Tech. Spec. problem.
3.
Corrective steps which have been taken and the results achieved:
The survey elevations used in the procedure have been corrected to eliminate this source of error.
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4.
Corrective steps which will be taken to avoid further violations:
As procedures are being reviewed and updated, statements are being added to allow flexibility when troubleshooting. This procedure, 1P/0/A/3214/04, will be revised accordingly upon completion of review.
5.
Date when full compliance will be achieved:
IP/0/A/3214/04 will be reviewed and appropriately revised by February 1, 1986.
Example d:
Contrary to the above, the licensee failed to have appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished on procedure IP/0/B/3000/03, revision 15.
The procedure was inadequate, in that, Unit 2 cold leg accumulator level transmitter calibration reference data was deleted and all Unit 2 cold leg accumulator level transmitters were calibrated with Unit I data when performing work requests 023345 PM through 023352 PM.
Response to Example d:
Duke Power agrees that the situation occurred as stated.
In our view an error in a procedure should not, by itself, constitute a violation. Therefore, the violation is denied.
IP/0/B/3000/03 change 15 was written, reviewed, and approved in an acceptable manner per Station Directive 4.2.1.
The equipment was not required to be in service during the time it was calibrated to the erroneous data. The error resulted from differences between Unit 1 and Unit 2 accumulator volumes prior to the refueling. A revision to Technical Specifications was issued which changed the Unit 2 accumulator volume to be the same as Unit 1 At that time, the procedure was changed to make the level alarm setpoints the same. Neither the preparer or the reviewer realized that other differences still existed.
The error was found by Operations when a channel check was performed prior to startup. The channel check is a part of startup and would identify such an error and prevent unit operation in an unsafe condition. The procedure has been cor-rected. The situation was identified and corrected prior to the instruments being required to be operable by Tech. Specs.
Example e:
McGuire Station Directive 3.2.1, states in part, that a functional verification shall be performed on QA conditions 1, 2, 3, and 4, security systems and Techni-cal Specification related components following maintenance. The functional veri-fication will be the responsibility of the Maintenance Supervisor performing the work and shall be documented in Section V or VIII of the work request by stating method and results obtained in the space provided.
Contrary to the above, the licensee failed to conduct a functional verification and documentation of work request 123686 OPS, investigate and repair cold leg accumulator level loops and work requests 023345 PM through 023352 PM, perform preventative maintenance and performance test on accumulator level instruments.
Cold leg accumulator level instruments are Technical Specification related instruments (TS 3.5.1.1.e).
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Response to Example e:
1.
Admission or denial _of the alleged violation:
Duke Power agrees that the violation occurred as stated.
2.
Reasons for violation:
On work request 123686, functional verification was performed but was not documented for all channels. Lack of documentation in section VIII was because section II of the work request specified that functional verifi-cation was not required.
Work request 023345 through 023352 met the requirements of Station Direc-tive 3.2.1 in that the functional verification was performed and completion was documented in section V (" Action Taken") of the work request. _Documen-tation consisted of the following or similar statements:
"Re-caled to acceptable limits, verified proper indication and actuations".
3.
Corrective steps which have been taken and the results achieved:
No action has been taken.
4.
Corrective steps which will be taken to avoid further violations:
Corrections have been made to the computer file from which the PM work requests are printed. Corrections consisted of designating functional verifications as being required.
5.
Date when full compliance will be achieved:
McGuire Nuclear Station is presently in full compliance.
The above incidents have been reviewed at shop meetings with appropriate personnel to prevent recurrence.
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