ML20207T628
| ML20207T628 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 02/23/1987 |
| From: | Guenther S, William Orders, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207T613 | List: |
| References | |
| 50-369-87-04, 50-369-87-4, 50-370-87-04, 50-370-87-4, NUDOCS 8703240192 | |
| Download: ML20207T628 (6) | |
See also: IR 05000369/1987004
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-369/87-04 and 50-370/87-04
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Licensee: Duke Power Company
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422 South Church Street
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Charlotte, NC 28242
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Docket Nos.:
50-369 and 50-370
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License Nos.: ~NPF-9 ~and NPF-17
Facility Name: McGuire Nuclear Station
Inspection Conducted: December 30, 1986 through February'10, 1987
Inspectors:
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2 .2. )-U
W. T. Orders, Resfdent Inspectop
Date Signed
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2-X7-72
S. F. Guenther, Accompanying Pers6nnel
Date Signed
Approved by:
[ [M.d.o
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T. A. Peebles, Section' Chief
Date Signed
Division of Reactor Projects
SUMMARY
Scope:
This special, unannounced inspection was conducted in the areas of
operations.
Results:
Three violations were identified:
Failure to maintain containment
spray system operable per TS 3.6.2 or take action required by TS 3.0.3; Failure
to take adequate correction actions; Failure to follow procedures. Collectively
these violations may constitute a single violation. These violations are under
consideration for escalated enforcement action.
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REPORT DETAILS
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Licensee Employees Contacted
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- T. McConnell, Plant Manager
- B. Travis, Superintendent of Operations
D. Rains, Superintendent of Technical Services
- B. Hamilton, Superintendent of Technical Services
- M. Sample, Superintendent of Integrated Scheduling
- N. McCraw, Compliance Engineer
- N. Atherton, Licensing and Compliance
- P. Nardoci, General Office Licensing
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, mechanics, security force members,
and office personnel.
- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on January 28, 1987, with
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those persons indicated in paragraph 1 above.
The inspector described
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the areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee. The licensee did not
identify as proprietary any of the materials provided to or reviewed by the
inspectors during this inspection.
Three violations were identified:
failure to maintain containment spray
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operability; failure to take adequate corrective actions; failure to follow
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procedures (369/87-04-01).
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Another exit was held on February 12 with the plant manager. An additional
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example of failure to provide adequate procedures with respect to
replacement of materials during refueling was discussed (369, 370/87-04-02)
3.
Containment Spray System Inoperability
On the morning of December 30, 1986, both McGuire units were operating at
100% power.
At 9:45 a.m.,
the resident inspector noted in the Unit 1
Technical Specification Action Item Logbook (TSAIL) that train
'B'
of the
Solid State Protection System (SSPS) had been removed from service at
8:39 a.m. to facilitate surveillance testing. It was also noted that train
'A' of Containment Spray (NS) had been removed from service at 9:31 a.m. to
accommodate NS heat exchanger testing.
Since SSPS testing can affect the
automatic actuation of NS, the inspector questioned the shift supervisor
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(SS). The SS informed the inspector that the SSPS testing would not affect
the operability of train 'B' NS (i.e. selected portions of SSPS testing can
be performed without affecting all that train's components). The inspector
documented ,the pertinent information to allow a subsequent, more detailed
review.
During that review, the inspector concluded that the SSPS testing had made
the automatic start of train 'B'
NS inoperable.
As train
'A'
NS was
inoperable with the pump discharge valves closed and power removed, for
the period from 9:31 a.m. until 10:10 a.m. on December 30, 1986, both trains
of NS were inoperable. (Train 'B' was returned to service at 10:10 a.m.).
That conclusion is supported by the following:
(1) The procedure employed to facilitate testing on SSPS train 'B'
was
PT-0-A-4601-08B.
Step 12.1.9 of that procedure instructs the
technician to place the " Mode Selector" in the 'B'
SSPS Output Relay
Test Panel in the " Test" position. This action removes 120V AC from
the coils of the 'B' train output relays, thereby rendering the train
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The 120V AC is not restored until the testing is complete.
(2) The procedure employed to facilitate the train ' A' NS heat exchanger
testing was PT-1-A-4208-03A.
Steps 12.2.11, 12, 13 and 14 respectively,
have the technician close or verify closed pump discharge valves INS-29A
and INS-32A and remove power from them. Thus, train'A' NS was rendered
It is important to note that a very similar situation occurred on the
morning of March 12, 1986, when, at approximately 9:10 a.m.,
while
performing a routine operations safety verification, the inspector detected
in the Unit 1 TSAIL that the 'B' train NS pump and the ' A' train of SSPS
had been taken out of service. The NS pump had been removed from service
at 4:45 a.m. that morning. Train 'A' of SSPS had been removed from service
only moments prior to the inspector's review.
The inspector questioned the control room Senior Reactor Operator (SRO),
who concluded that the work ongoing on SSPS would, in fact, degrade the 'A'
NS pump start logic and was able to stop the work on SSPS prior to the
personnel actually taking the train out of service. The details of this
event and associated enforcement action is detailed in Inspection Report
369, 370/86-08.
The significance of the most recent situation is, therefore, exacerbated by
the fact that it is a repetitive occurrence.
As was the case during the previous event, it appears that certain selected
administrative controls which were established to preclude this type event
appear to have been circumvented.
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The heat exchanger test, procedure PT-1-A-4208-03A, prerequisite 8.4
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requires the technician to " Ensure Train IB of Containment Spray is
fully operable during test if in Modes 1, 2, 3, or 4".
This step was
signed off by the technician ba' sed on permission granted by the Shift
Supervisor. The shift supervisor was under the erroneous impression
that the
'B' train of NS was operable.
Operations Management Procedure (OMP) 2-5, " Technical Specifications
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Action Item Logbook," provides the operating staff instructions for
documenting operation in a degraded condition.
Section 8.1 of that
procedure required that, prior to removing a component from service, an
evaluation be made tc determine what effect the action has on the
operability of other equipment.
The procedure further instructs that
to properly perform the evaluation, the other open items in the TSAIL
must be reviewed to determine if the redundant train component is
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DMP 2-5, step 6.6 requires that the operator ensure that the redundant
train is verified to be operable before removing equipment from
service.
Obviously, the intent of the above requirements is to preclude the removal
of both trains of redundant equipment simultaneously.
The regulatory requirements associated with this event are as follows:
Technical Specification (TS) 6.8.1 requires that written procedures be
established, implemented and maintained covering the operation of safety-
related equipment. As detailed above, it appears that certain procedural
requirements were not complied with.
Technical Specification 3.6.2 requires two independent Containment Spray
Systems be operable in modes 1, 2, 3, and 4.
With one Containment Spray
System inoperable, the inoperable Spray System is to be restored to operable
status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. There is no allowable statement in TS 3.6.2 if both
trains are inoperable.
With both trains of NS inoperable, the unit was in TS 3.0.3 which requires
that when a Limiting Condition for Operation (LCO) is not met, except as
provided in the associated ACTION requirements, that within one hour action
shall be initiated to place the unit in a MODE in which the specification
does not apply.
In this particular case, since the operating staff was
unaware of actual plant status, the requisites of TS 3.0.3 were not
considered. However, as they should have known the condition of the system,
the time for entering TS 3.0.3 was taken from when both trains were removed
from service.
Fortunately, the testing on train 'B'
was completed at
10:10 a.m. which precluded exceeding the one hour action requirement.
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In conversation with members of plant' management,' the position was taken
that the unit was not in noncompliance with TS 3.6.2 because the one hour
action statement of TS 3.0.3 had not been exceeded. It is acknow1
the action statement of TS 3.0.3 was not exceeded, howevef, the'ciged that
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position is that the unit was in noncompliance with TS 3.6.2.
The basis for
this position is founded on the following:
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TS 3.0.2 states that . noncompliance with a specification shall exist
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when the requirements of the Limiting Condition for Operation and
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associated ACTION requirements are not met.
The bases of TS 3.0.2
defines those conditions necessary to constitute compliance with the
terms of an individual Limiting Condition for Operation and associated
ACTION requirement.
The bases of TS 3.0.3 specifies that the specification delineates the
measures to be taken for those circumstances not directly provided for
in the ACTION statements of an individual LC0 and whose occurrence
would violate the intent of a specification.
Thus, in this case, with both trains of containment spray inoperable the
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unit was not in compliance with TS 3.6.2, yet no action was taken pursuant
to TS 3.0.3.
The events leading up to the removal of both NS trains involved the
following:
1)
the lack of accurate communication between the performance and
Operations personnel pertaining to equipment operability;
2)
the violation of administrative requirements which, if adhered to,
would have precluded the event; and
3)
apparent inadequate corrective actions to the occurrence of March 12,
19E6.
With respect to the apparent inadequate corrective actions, the event of
March 12, 1986 occurred, as stated in your response, as "...a result of the
failure to realize that "A" Train SSPS work would block the auto start
feature of
"A" Train NS Pump."
You also stated in your response to
Violation 369/86-08-02 that "the incident was covered at the Shi f t
Supervisor's meeting of April 4, 1986." Clearly then, the operations staff
was made aware of the problem and should have known that SSPS testing does
affect the operability of the associated engineered safety features (ESF)
equipment.
4.
Inoperable Containment Air Returr. Fans
On January 30, 1987, at 2:20 p.m., the licensee, in response to a Region II
notification, determined that two sections of curbing were missing from the
refueling floors of both McGuire units.
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The curbing sections (a 3-foot and 6-foot section per unit) form parts of a
dam which is designed to prevent containment spray water from flowing into
the cpntainment air return fan pit area. Without the dam, the water would,
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accorcing to the licensee, result in fan failure.
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requisites of Technical Specification (TS) 3.0.3.
At 3:19
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licensee began shotting both units down. Unit I was at 100% and Unit 2 was
at 58% power at that time. At 4:18 p.m., after discussions with NRC Region
II management, the licensee received an 8-hour discretionary enforcement
extension to the TS 3.0.3 action statement requirements in that the units
could remain stable instead of decreasing in power for the six hours allowed
by the TS and an additional two hours was allowed to conduct the repairs in
a more controlled manner. This additional 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of reactor criticalit a
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was granted as the work would be done in a total of eight hours and it was
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decided that safety would be better served if the plant was not ramping i.n
power during the repairs. The drawings for the dams were available and the
extension would allow time for the manufacture and installation of the dam
sections. The unit shutdowns were held in abeyance with Unit 1 at 99% and
Unit 2 at 57% power.
The shutdowns were resumed in accordance with the
agreement and TS 3.03 at 11:20 p.m.,
since the work on neither unit was
complete.
The work on Unit 2 was completed at 12:20 a.m.
on January 31, and at
1:54 a.m. on Unit 1. Unit 1 and 2 had reduced power to 80%, and 53%,
respectively. The Unusual Event was cleared at 1:54 a.m.,
and both units
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returned to their previous power levels.
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The air return fans, located in the containment, are designed to return air
from the upper compartment into the lower compartment.
Two full capacity
fans are provided each with the capability to perform the assigned function.
Each fan has a capacity of 30,000 cubic feet per minute.
Both fans are started by a containment spray actuation signal nine (+or-one
minute) minutes after a postulated loss of coolant accident (LOCA) would
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cause containment pressure to reach 3 psig. The fans move air from the
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upper compartment to the lower compartment, thereby returning the air which
would be displaced by the reactor coolant system blowdown to the lower
compartment. After discharge into the lower compartment, the air and steam,
produced by residual heat, would flow through the ice condenser doors into
the ice condenser compartment where the steam portion of the flow would be
condensed. The air flow reta ns to the upper compartment through the vents
in the upper doors of the ice condenscr compartment. The fans operate
continuously after actuation, circulating air through the containment
volume.
The fans, located below the operation deck, discharge into the
equipment annulus outside the crane wall on both sides of the refueling
canal.
Flow enters the lower compartment through ports in the fan room
crane wall.
These ports provide for equalization of pressure between the
lower compartment and dead-ended volumes.
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Preliminary indications reveal that with both containment air return fans
inoperable, the potential would have existed for significant post-LOCA
problems with containment pressure, local hydrogen accumulation and fission
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product scrubbing.
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Since this particular scenario is an unanalyzed condition, the true safety
significance is unknown. The licensee's safety evaluation is forthcoming in
the associated Licensee Event . Report (LER) due by March 1,
1987. The
sections of dam were originally installed on both units, but were removed
during subsequent refueling outages and not replaced.
The root cause of the event appears to be the lack of administrative
controls regarding the removal and re-installation of the components. A
review of pertinent procedures and discussions with licensee personnel
revealed that there were no specific controls concernifig either evolution.
This is an another example of an apparent violation of TS 6.8.1, which
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requires that written procedures be established, implemented and maintained
covering operation and maintenance of safety related equipment. . These
examples question the adequacy of management control over activities
affecting the safe operation of the McGuire nuclear units.
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