ML20205N783
| ML20205N783 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/02/1988 |
| From: | Matthews D Office of Nuclear Reactor Regulation |
| To: | Tucker H DUKE POWER CO. |
| References | |
| TAC-64843, TAC-64844, NUDOCS 8811040339 | |
| Download: ML20205N783 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMIS$10N o
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WASHINGTON, D. C. 20848 Nov3mber 2, 1988 Docket Nos. 50-369 50-370 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 26242
Dear Mr. Tucker:
SUBJECT:
STAFF POSITIONS AND REQUESTS REGARDING PROPOSED CHANGES TO TWO DETAILED CONTROL ROOM DESIGN REVIEW COMMITMENTS - MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 (TAC.'. 64843 and 64844)
NRR has evaluated your request of A Control Room Design Review (DCRDR) pril 5,1988, to revise two Detailed comitments for the PcGuire Nuclear l
Stction. The results of our evaluation are contained in the enclosure.
As noted in the enclosure, we find that you have not provided sufficient technical justification for cancelling your prior commitment on Human Engineering Discrepancy (HED) M-1-0018 or for deferring for an indefinite period implementation of the scope of your prior comitment on HED M-1-004A.
HED-1-0018 involves a poor panel arrangement of the ESF Panel which provides easy verification of SI valve alignment. The staff continues to believe that this HED enhances safety and should be corrected.
Similarly. HED H-1-004A is an HED that combines numerous annunciator and status light discrepancies. A special review was earlier conducted by Duke which determined that several categories of annunciator HEDs merited correction. We find inadequate justification for your April 5 proposal to drop the results of your own analysis and only correct a small portion of the work at this time. Moreover, we find further deferral beyond the next refueling outages in 1989 to be unacceptable, k
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8811040339 881102 PDR ADOCK 05000369 P
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i H. B. Tucker Therefore, the staff does not approve your request related to HEDs M-1-0018 and M-1-004A. We request that you provide a plan of action that discusses how the HEDs will be fully resolved in a timely manner or a technical justification that explains why the HEDs do not represent safety problems.
Should you desire a meeting to further discuss our apparent differences in view regarding the significance of these HEDs, contact Darl Hood at (301) 492-1442.
Sincerely, f
f, Yb L David B. Matthews, Director Project Directorate 11-3 i
Division of Reactor Projects I/II Enclosure Staff Positions and Requests i
cc:
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H. B. Tucker November 2, 1988 Therefore, the staff does not approve your request related to HED*,M-1-0018 and M-1-004A. We request that you provide a plan of action that discusses how the HEDs will be fully resolved in a ticiely manner or a technical justification that explains why the HEDs do not represent safety problems.
Should you desire a n>eeting to further discuss our apparent differences in view regarding the significance of these HEDs, contact Darl Hood at (301) 492-1442.
Sincerely, David B. Matthews, Director Project Directorate !!-3 Division of Reactor orojects 1/11 Enclosure Staff Positions and Requests cc:
See next page DISTRIBUTION:
Docket File NRC PDR Local PDR PDil-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. itatthews 14-H-25 M. Rood 14-H-25 D. Hood 14-H-25 DGC 15-B-18 E. Jordan MhBB-3302 B. Grimes 9-A-2 ACRS(10)
H-1016 J. 7wolinski 10-H-5 C. Goodman 10-H-5 McGuire Plant file
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3 6b Q' hDil-3 t4R d DHood:1s JZy 4nski lDMatthews 10LS/88 10/(3 /68 JO/
(8 1p/L/88 J
Mr. H. B. Tucker Duke Power Company McGuire Nuclear Station CC:
Mr. A.V. Cerr, Esq.
Dr. John M. Barry Duke Power Company Department of Envirunmental Health P. O. Box 33189 Mecklenburg County 422 South Cnurch Street 1200 Blythe Poulevard Cnerlotte, North Carolina 28242 Charlotte, North Carolina 28203 l
t County Manager of Mecklenburg County fir. Dayne H. Brown, Chief l
720 East fourtn Street Radiation Protection Branch Charlotte, Nurth Carolina 28202 Division of Facility Services Ospartment of Human Resources 701 Barbour Drive Mr. Robert Gill Raleigh, North Carolina 27603-2008 Duke Power Company Nuclear Production Department P. O. Box 33189 Charlotte, North Carolina 28242 J. Michael McGarry,111. Esq.
Bishop, Liberm6n, Cook, Purcell and Reynolds 1200 Seventeenth Street, N.W.
Washington, D. C.
20036 Senior Resident Inspector i
c/o U.S. Nuclear Regulatory Commission Route 4, Box 529 i
Hunterville, North Carolina 28078 1
Regional Administrator, Region 11 U.S. Nuclear Regulatory Commisstun l
101 Marietta Street, N.W., Suite 2900 Atlante, Georgia 30323 i
i S. S. Kilborn Area Manager, Mid-South Area I
ESSO Projects Westinghouse Electric Corporation l
MNC West Tower - Bay 239 P. O. Box 355 Pittsburgh, Pennsylvanie 15230
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ENCLOSURE STAFF POSITIONS AND REQUEST FOR ADDITIONAL INFORMATION REGARDING TWO DCRDR COMMITMENTS DUKE POWER COMPAN,Y, McGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 370 NRR has evaluated the April 5,1988 request by Duke Power Company for the McGuire Nuclear Station to cancel the commitment on Human Engineering Discrepancy (HED) H-1-0018 and potentially reduce the scope of the commitment on HED M-1-004A.
We find that Duke has provided insufficient technical justification to cancel HED M-1-0018 and to indefinitely defer implementation of the full scope of HED M-1-004A. Moreover, the staff coes not approve the request by Duke related to deferral of HED M-1-004A beyond the next scheduled refueling outages in 1989.
- 1. HED M-1-0018 HED M-1-0018 involves inadequacies in the Engineered Safety Features (ESF)
Monitor Light Panel. The purpose of the ESF Monitor Light Panel is to provide the operator with a quick, consolidated indication that sil ESF components have actuated properly during a safety injection.
The ESF Panel provides the status of over 69 ESF components including easy verification of 51 valve alignment. The HED is categorized as safety significant.
a.
We acknowledge Duke's statement that a special review of the present design, the proposed design and the emergency procedures was cunducted to determine whether Duke should proceed with implementation of the panel redesign to resolve HED M-1-0018.
The staff is concerned that the review's conclusion, that little benefit will be gained by the modi-fication, may reflect that Duke has not effectively addressed the original concerns identified in the HED in the proposed design.
Specifically, Duke has not presented a case as to why, if the proposed design resolves the concerns of the HED and the HED is of safety significance, little benefit is achieved.
b.
The April 5 letter also implies that the monitor light panel serves as a backup in most situations.
It is the stoff's understanding that operators may base certain actions on the readings they receive from the panel. At present the indications are not functionally grouped and panels are not consistently lighted or dark depending on the emergency sequence. The letter does not present sufficient information concerning the review that was conducted to justify cancelling the redesign connitment, c.
In view of recent inspection findings such as those of NRC Inspection Report Itos. 50-369/88-29 and 50-370/88-29, we agree with Duke's statement
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. that "there is justified concern over the potential increase in risk associated with a wiring error or coordination mistake effecting plant safety during and following the outage." However, we believe that this reflects a need for improvements in Duke's existing controls for in-stallation and testing of plant modifications. We do not agree that the in.plementatinn risks outweigh the benefits when proper procedures and post-modification testing are implemented by trained personnel under dppropriate quality-assurance and qudlity-control conditions.
d.
One of the changes under HED H-1-0018 involves the use of lighted rather than derk panels for indication purposes. Specifically, lighted panels are preferred because dark panels do not reveal whether the indicator is off or its bulb is burned out. Cuke states its belief that this concern is edequately covered by the weekly inspection Operations conducts of all light bulbs used for indication in the control room.
Inspection frequency is not the only issue here. The NPC's observations are that numerous uncorrected control room functional deficiencies exist in the form of malfunctioning indicators and annunciators (20-40 per unit). Although management receives weekly status of the number of deficiencies, the total remains fairly constant because new items keep pace with corrected items.
Duke's response fails to address whether deficiencies will be limited and corrected expeditiously and how this is assured.
- 11. HED M-1-004A HED M-1-004A involves inodifir.ations to the annunciator system.
This HED is a combination of numerous annunciator and status light HEDs. Like HED M-1-0018 dbuve, Duke's original cunmitment for this NUREG-0737 Supplernent 1 item was the subject of a June 15,198a, "Order Confirming Licensee Commitments on Emergency i
Response Cepability" that was based upon Duke's letter of April 14, 1983, committing to the actions specified in the Order. After additional corres-i pondence Duke's letter of May 5,1987 noted that "Operating personnel ano management support complete installation of this HED on both Units in the 1988 i
refueling outages." A special review was conducted and determined that seven Categories of HEDs merited correction.
The existing HED resolution involves the following:
1.
Remove colored film from all tiles except for panels F01 and AD1; 2.
Convert blank panels $19 and S110 from status to annunc14 tor panels; 3.
Revise engraving on 429 tiles (50% of total tiles);
4.
Hove 688 windows within the sette panel or to another pariel; 5.
Add 31 windows; 6.
Delete 34 windows; and, 7.
Convert some status windows to annunciator type ona some annunciator windows to status type.
4 Duke's proposed change of April 5 would reduce the scope of the HED to the extent that only items 1 and 3 of the onnunciator nodifications above would be 1
completed penoing further review,
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. i Duke states that operator performance during the alinost seven total years of l
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operation has shown that the existing arrangement of annunciator and status light systems is "adequate." The issue here should not be whether operator's performance provides sufficient compensation for poor design.
Duke also states that "Considering this experience, the scope to the rearrangement, and the negative transfer of training and experience from the existing errangement to the new arrangement, Duke Power is concerned about the increased potential for operator error if the rearrangement l
is implemented." We are not convinced that such transition is beyond the capabilities of Duke to appropriately manage and impleinent.
Nor dre we Convinced that operator's performance after Completion of this transition will not be significantly enhanced. We have and do recognize Duke's need for time to provide sufficient preparations for such i
transition, but in light of Duke's commitinent in 1983, we question whether adequate attention has been given this item by Duke's management. We also l
note Duke's commitment to further study is open-ended with no schedule l
provided for e decision. We request Duke advist us of its intended cumpletion date.
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b.
The technical justification presented by Duke for the potential reduction i
in scope is based, in part, upon the results of an EPRI study (Research Project RP-2011). NRC does not have access to the study report since it is a proprietary study. A technical justification that would allow NRC to t
i concur in reduction in scope of the HED shoulo be self-sufficient. A i
proprietary study outs not provide the public and the NRC with such a self-sufficient justification. Additionally, information not available to the public can not be relica upon by the NRC unless it meets the require-ments of 10 CFR 2.790, "Public inspections, exemptions, requests for i
j withholding."
c.
The technical justification should also show that the proposed corrective dCtions Will adequately resolve the HED.
Based on the information in Duke's lettir, it would appear that the EPRI study only addresses the i
grouping of dnnunciators, or number 4 on the list above.
In order for the j
st.ff to consider a potential reduction in the scope of HED N-1-004A, issues nuirters 2, 5, 6 ano 7 would also need to be eddressed.
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III. HED M-1 0018 AND HED M-1-004A i
We request that Duke provide a plan of action that discusses how the HEDs will
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be fully resolved in a timely manner or a technical justification that explains i
1 why the HEDs do not represent a safety problem.
The information should be provided to a schedule consistent with staff review completion well in advance of the 1989 cutoges.
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