ML20155E536
| ML20155E536 | |
| Person / Time | |
|---|---|
| Site: | Mcguire |
| Issue date: | 10/06/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810120332 | |
| Download: ML20155E536 (5) | |
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Duke 1%cer Company Hu n T.u-ya garjjl93 iice Persident Charlotte, N C 28242 Nuclear Produtws (704)373-4511 DUKEPOWER October 6, 1988 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369. -370 Inspecties Report Nos. 369, 370/88-23 Reply to a Notice of Violation Centlement Pursuant to 10CFR2.201, please find attached Duke Power Company's response to violation 370/88-23-01 for the McGuire Nuclear Station.
Should there be any questions concerning this matter, contact S.E. LeRoy at (704) 373-6233.
Very truly yours,
$t Hal B. Tucker SEL/344/mmf Attachment xet Dr. J. Nelson Crace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., NW., Suite 2900 Atlanta, GA 30323 Mr. Darl Hood U.S. Nuclear Regulatory Covanission Office of Nuclear Reactor Regulation Washington, DC 20555 Mr. P.K. Van Doorn NRC Resident Inspector McGuire Nuclear Station 6810120332 881006 gDR ADOCK O s'
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Document Control Desk October 6, 1988 Page 2 j
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bxct P.M. Abraham EC2-827 l
A.V. Carr PB 5105 I
R.M. Dulin EC-1090 t
H.E. Edwards EC-724 R.M. Glover (CNS)
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W.A. Haller WC-2373 G.W. Hallman WC-2435 i
C.L. Harlin (ONS) t R.P. Ruth (MNS) i R.O. Sharpe (MNS)
A.R. Sipe (MNS/MSRG)
J.'s. Thomas EC2-530 QA Tech Services NRC Coord.(EC-1255) t S.S. Kilborn W
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R.L. Gill S.A. Gewehr P.B. Nardoci MC-815.01 (18) l 1
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Attachment Duke Power Company McGuire Nuclear Station Reply to Notice of Violation Inspection Report 50-369, 370/88-23' i
Violation 370/88-23-01 l
I Technical Specification 6.8.1 requires that written procedures be estabitshed, implemented, and maintained covering the activities recommended in Appendix A 1
of Regulatory Guide 1.33. Revision 2 February 1978.
Regulatory Guida 1.33. Revision 2 February 1978, Appendix A requires that procedures be writMn and implemented for procedural adherence, temporary change method, and surveillance tests.
I Station Directive 4.2,1ermanent Station Procedures, requires a major change I
to be processed if the method by which a procedure is performed must be
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l changed.
j Operations Management Procedure (OMP) 1-2, Use of Procedures, allows a supervisor that holds an SPO license to "N/A" a step if it does not need to 4
be performed.
Surveillance procedure PT/2/A/4204/05, Residual Heat Removal (ND) Valve Stroke l
Timing Shutdown, provides the instructions for performing Valve Stroke Timing tests of various ND valves including 2ND58A, ND Heat Exchanger 2A to j
Centrifugal Charging Pumps 2A and 2B Block.
Example No. 1 k
Contrary to the above, procedure OP/2/A/6250/02, Auxiliary Feedwater System, i
step 2.5 was not performed as written and a procedure change was not written.
A supervisor holding an SRO license approved performance of this step without j
processing a change on the false assumption that portions of the step could be
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marked "N/A" in accordance with OMP 1 2.
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Example No. 2 l
j Contrary to the above, procedure PT/2/A/4204/05, Residual Heat Removal (ND) l Valve Stroke Timing - Shutdown, was inadequate in that the procedure did not l
adequately specify system pre-requisite conditions to ensure safe performance l
cf the test.
ON July 21, lir88, valve 2ND58A, ND Heat Exchanger 2A to j
Centrifugal Charging Pumps 2A and 2B Block Valve, was opened in accordance i
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with the procedure allowing pressure in excess of design pressure to be unnecessarily applied to low pressure portions of the Chemical and Volume
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Control, and Safety Injection Systems.
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L This is a Severity Level IV (Supplement 1) violation and applies to Unit 2
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only.
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Reply to Example No. I 1.
Adnission or denial of violations The violation is admitted as stated.
2.
Reason for the violation if admitted:
The Supervisor involved thought the situation wa : covered by OMP 1-2.
Subsequent review of the OMP revealed this assuspelon was incorrect.
Because the supervisor felt he was correct in directing the operator, he chose not to make a procedure change.
3.
Corrective steps which have been taken and results achieved:
Nonc required.
4 Corrective steps planned to avoid further violations:
This incident will be covered with all operating shifts during the upcoming segment of operators requalification training.
5.
Date when full compliance will be achieved:
October 31, 1988.
I Reply to Example No. 2 1.
Admission or denial of violations The violation is admitted as stated.
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2.
Reason for the violation if admitted
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The valve testing procedure PT/2/A/4204/05, ND Valve Stroke Timing -
Shutdown, did not contain adequate limits or precautions to prevent the test from being conducted with pressure in excess of the design pressure of the involved systems.
3.
Corrective steps which have been taken and results achieved:
a.
A written operability determination was received from Duke Design Engineering which evaluated the affected systems and components after the overpressurization.
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Valve 2NV-1025 was inspectec for possible damage and no damage was l
found.
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c.
Procedures to test Unit 1 and 2 valves ND-58A were revised to ensure that Residual Heat Removal (ND) Pump A discharge pressure is less than Chemical Volume and Control (NV) and Safety Injection (NI)
Systems suction pressures.
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l d.
Systems which connect ECCS systems (e.g. NV. NI. ND and FW) were reviewed for potential of over pressurization. Procedure changes afullar to "c" above vere made for the corresponding B train valves (1&2 NI-136), as well as, valves 1&2 FW-27A. for protection of the Refueling Water Storage Tank piping.
4 Corrective steps planned to avoid further violations:
l The potential for over pressurtains systems during testing will be i
evaluated during the valve stroke timing procedures rewrite.
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5.
Date when full compliance will be achieved:
l June 1. 1989.
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