ML20206T977
| ML20206T977 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/02/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-86-052, EA-86-52, NUDOCS 8607080276 | |
| Download: ML20206T977 (8) | |
Text
e DUKE POWER GOMPANY P.O. BOK 33189 CHARLOTTE, N.C. 28242 HAL B. TUCKER TE LEPHOME vice enestnewr (704) 373-4331 artT, LEAR PRODON July 2, 1986 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
McGuire Nuclear Station Dockst Nos. 50-369 and 50-370 EA 86-52
Dear Sir:
Pursuant to 10CFR 2.201, please find attached a response to the violation identified in the subject Enforcement Action. Although Duke Power is admitting that the subject violation occurred, we do not believe that a Civil Penalty is warranted.
Attachment I contains the response to the violation. contains a discussion of mitigating factors.
Very truly yours, C
Hal B. Tucker JBD/32/jgm Attachment xc:
Dr. J. Nelson Grace Regional Adminsitrator U.S Nuclear Regulatory Commission Region II Suite 3100 101 Marietta Street Atlanta, Georgia 30332 g
Mr. W.T. Orders I
NRC Resident Inspector Ifl McGuire Nuclear Station I
8607080276 860702 PDR ADOCK 05000369 G
]
ATTACHMENT 1 i
DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO NOTICE OF VIOLATION (EA 86-52)
(INSPECTION REPORT 50-369/86-04; 50-370/86-04)
Violation, Severity Level III, EA 86-52 Technical Specification 3.5.2 requires for Modes 1, 2, and 3 that two inde-pendent emergency core cooling system (ECCS) subsystems shall be operable with each subsystem comprised of one operable centrifugal charging pump, one operable safety injection (SI) pump, one operable RHR heat exchanger, one operable RHR pump, and an operable flow path capable of taking suction from the refueling water storage tank (RWST) on a safety injection signal and automatically transferring suction to the containment sump during the recir-culation phase of operation.
With both ECCS subsystem flowpaths inoperable, Technical Specification 3.0.3 applies, which requires that except as provided in the associated require-ments, within one hour, action shall be initiated to place the unit in a mode in which the specification does not apply.
Technical Specification 3.0.4 requires that entry into an operational mode or other specified condition shall not be made unless the conditions for the l
Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements.
l l
Contrary to the above, during the period beginning at 9:00 p.m. on November
]
2, 1985 until 7:30 p.m. on November 4, 1985, the plant entered Modes 2 and 3 with both trains of the ECCS subsystems for Unit 1 inoperable in that the safety injection pumps would initially take suction from the volume control tank (VCT) instead of the RWST and the capability to automatically transfer suction from the RWST to the containment sump did not exist.
Response
1.
Admission or denial of the alleged violation:
i Duke Power agrees that the violation occurred as stated in LER L
369/86-03, dated February 10, 1986.
2.
Reasons for violation:
i The violation. occurred due to personnel error.
It was (erroneously) determined that no Technical Specifications were violated and no safety concerns were unanswered due to the inoperability of INV-141A and l
INV-142B when the decision to start up was made. This determination was 1
based upon the fact that these valves are not addressed in the Technical Specifications. As these valves were not addressed in the Technical Specifications, personnel determined that the required flowpath of Technical Specification 3.5.2 was unaffected and that the NV (Chemical and Volume Control) system was capable of performing its design func-tion. The operability / degree of degradation was addressed in the Enforcement Conference of February 28, 1986.
l
. _ _ -. _ _ _ _ _ -,. _, ~.., _ _ _ _..
~ -.
. 3.
Corrective steps which have been taken and the results achieved:
t The valves were repaired and returned to service on November 4, 1985.
On January 15, 1986, a memorandum was sent to all licensed operators concerning the incident. This memorandum discussed the specific incident and stated:
"In the future when determining the operability of a flow path for systems covered by Tech Specs, ensure all valves in the subject system 4
that are energized from a vital source are capable of performing their designed function. These valves may not be in the ECCS flow path, but may protect that flow path from a degraded flow condition or other important design consideration not covered in Tech Specs."
j 1
l A functional review has been initiated of the design purpose of each motor operated valve (MOV) which receives ~an Engineered Safety Features (ESP) signal. This information will also include the consequences of such a valve being out of its safety position and inoperable.
It should also be noted that procedures were in place to assure manual actions should these valves have been called upon to function during this time. Procedure EP/1/A/5000/01 (Safety Injection), step D.2.C 1
addresses the group 4 monitor lights (which include indication for
{
INV-141 and 1NV-142) and includes the step " manually align equipment as j
required". This would have ensured that the valves would have been closed manually should they have been called upon to function while they were electrically inoperable.
I No similar incidents have occurred at McGuire since this incident, as j
none had happened before.
1 j
4.
Corrective steps which will be taken to avoid further violations:
When the functional review of the MOV's which receive an ESF signal is complete. (see item 3), it will be reviewed with all licensed personnel.
A Department Directive is being developed to apply to all of Duke 1
Power's Nuclear Stations. This directive will address the operability of a system based on its subsystems and components. As an interim
}
measure to the Department Directive, all operators have been instructed i
to perform a careful review in regards to system operability as discussed in the memorandum to all licensed operators as discussed above in number three. A new Technicc1 Specification interpretation (as i
discussed below), coupled with the information on MOV's that receive an l
ESF signal will form the McGuire specific implementation of this directive.
l As mentioned above and discussed in Mr. H.B. Tucker's (DPC) letter to j
Dr. J. Nelson Grace (NRC/RII) dated March 4,1986, a new Technical Specification interpretation on the determination of operability will be I
. developed. This interpretation will reference the listing of MOV's that receive an ESF signal, as appropriate, which will be included in the operator training program and in the Technical Specification reference manual.
5.
Date when full compliance will be achieved:
Duke Power Company, McGuire Nuclear Station, will complete the training of licensed personnel with regard to the Motor Operated Valves which l
receive an ESF signal by November 1, 1986. The Department Directive will be in place by February 1, 1987. The new Technical Specification interpretation will be in place by March 1, 1987.
i 4
ATTACHMENT 2 DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO PROPOSED CIVIL PENALTY While Duke Power agrees the violation occurred, we do not feel that a Civil Penalty is warranted in this instance. The operators were aware of the inoperability of the valves and acted accordingly. Several factors should be considered that indicate that while the valve operators were inoperable, manual manipulation of the valves could be depended upon, should a safety injection occur.
In the June 2, 1986 letter transmitting the Notice of Violation and Proposed Implementation of Civil Penalty, NRC states that "The Staff recognizes that certain manual actions could be taken to isolate the VCT. However, specific procedures were not in place for these actions..." (emphasis added); contrary to this, procedural controls were in place to ensure valve alignment, manually if necessary. Attached is page 3 of procedure EP/1/A/5000/01,
" Safety Injection". Step D.2 specifies to check the ESF monitor light panels; substep c specifically states that Ss and St components in group four are to be lit. If the proper response is not obtained (group four lit), the procedure directs the operators to " manually align equipment as required".
Valves INV141 and 1NV142 are indicated on monitor panel four, the indicator being lit when the valves are closed (panel diagram included, the whole panel should be lit for a safety injection). With the valves open and the actuators inoperable with power removed, the monitor panel would show the valves as open (the last position of the limit switches) indicating to the operators that the valves needed to be manually aligned.
It should be noted that the emergency procedure is based upon a generic Westinghouse Emergency Response Guideline which has been approved by the NRC.
The lower boration level of water in the VCT relative to the RW3T is not a safety concern. The boron concentration in the VCT would be approximately that of the reactor coolant system, and thus would not affect reactivity which would be controlled by the control rods.
In addition, only the centrifugal charging (NV) pumps would be drawing from the VCT, with the RWST as a parallel suction when suction pressure from the VCT and RWST were equal. The Safety Injection (NI) pumps and residual heat removal (ND) pumps would take suction from the RWST should system pressure decrease to allow injection from these pumps,1520 psig for the NI pumps and 195 psig for the ND pumps.
Also, the safety analyses of the event has shown that the NV pumps will not become hydrogen bound for at least 18.25 minutes following the initiation of a safety injection. This allows sufficient time for manual actions.
Two separate " dry runs" plus the real situation on November 2, 1985 indicate the valves can be closed in 14 - 18 minutes (including dress out time).
Since the operators were aware that the breakers for INV-141 and 142 were red tagged open for repair, dress out requirements could be waived and the time required to close the valves would be approximately five minutes.
. j In addition, as best as can be determined, repair personnel were always at the valves during the time the valves were being repaired. The shift supervisor was aware that these personnel were at the valves and the repair personnel had been instructed to notify the shift supervisor if they lef t the valve. There is no record of such a notification occurring.
Therefore, had a safety injection occurred, repair personnel at the valves could have been instructed, by station phone system or the paging system, to manually close i
the valves. The two valves are in series, and one valve was always capable of being manually closed.
With these factors in place, the conclusion is that while the violation did occur in that these two valves were not capable of automatic closure as designed, no loss of safety function would occur as it was always possible to close the valves manually before hydrogen binding of the pumps would occur thus maintaining the design safety function of the valves.
On this basis Duke Power believes that a Civil Penalty is not warranted in this case and requests mitigation of the proposed fine.
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Form 34913 (8-82)
PAGE NO.
EP/1/A/5000/01 SAFETY INJECTION 3 0F 10 REV 0 ACTION / EXPECTED RESPONSE RESPONSE NOT OBTAINED 5.
Verify Load Sequencers actuated:
Manually initiate SI.
e Status light "E/S Load Seq Actuated Train A" - LIT e
Status light "E/S Load Seq Actuated Train B" - LIT.
D.
Subsequent Actions 1.
Initiate RP/0/A/5700/01, NOTIFICATION OF UNUSUAL EVENT.
CAUTION Monitor lights may not be aligned properly for other than initial entry into this procedure.
2.
Check ESF Monitor Light Panel:
a.
Groups 1, 2, 5, 7 - DARK a.
Manually align equipment as required.
IF " Safety Inject Train A/B" lit,
~
TiiEN check OAC Tech Spec program 13 to determine misaligned valves.
IF OAC is out of service, THEN i
Emplete Enclosure 2.
o.
Group 3 - LIT b.
Manually open valves.
c.
Ss AND St components in c.
Manually align equipment as group 4 - LIT required.
IF " Cont Isol Phase A Train A/B" IIdT lit, THEN manually initiate Phase A isolation.
d.
UHI Surge Tank Press - GREATER d.
Verify Group 6 lit AND valves THAN 350 PSIG gagged.
I_F NOT lit, THEN manually close UHI Accum Isol AND Gag Valves.
Go to step 3.
e.
Group 6 - DARK.
e.
E lit, THEN open UHI Accum Isol Valves UNLESS closed after accumulator discharge.
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