ML20209B284

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Insp Repts 50-369/87-08 & 50-370/87-08 on 870221-0320. Violations Noted:Temporary Mod to Refueling Water Storage Tank Performed W/O Controlling Active Test Procedure or Work Request
ML20209B284
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 04/14/1987
From: Guenther S, William Orders, Peebles T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209B184 List:
References
50-369-87-08, 50-369-87-8, 50-370-87-08, 50-370-87-8, NUDOCS 8704280404
Download: ML20209B284 (8)


See also: IR 05000369/1987008

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NUCLEAR REGULATORY COMMISSION

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Report Nos.:

50-369/87-08'and 50-370/87-08-

Licensee:

Duke Power Company

422 South Church Street.

Charlotte, NC 28242

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Facility Name: McGuire Nuclear Station 1 and 2

Docket Nos.: 50-369 and 50-370

License Nos.: NPF-9 and NPF-17

Inspection Conducted:

February 21, - March 20, 1987

Inspectors:

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ision of Reactor Projects

SUMMARY

Scope: This routine unannounced inspection involved the areas of operations

safety verification,

surveillance testing, maintenance activities, and

follow-up of previous enforcement actions / inspection findings.

Results: Of the areas inspected, one violation was identified in the area of

procedural compliance relating to temporary modification control.

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UNITE') STATES

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Report Nos.:

50-369/87-08'and 50-370/87-08'

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Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

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Facility Name: McGuire Nuclear Station 1 and 2

Docket Nos.:

50-369 and Sc 370

License Nos.: NPF-9 and NPF-17

Inspection Conducted:

February 21, - March 20, 1987

Inspectors:

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ision of Reactor Projects

SUMMARY

Scope: This routine unannounced inspection involved the areas of operations

safety verification,

surveillance testing, maintenance activities, and

follow-up of previous enforcement actions / inspection findings.

Results: Of the areas inspected, one violation was identified in the area of

procedural compliance relating to temporary modificttion control.

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REPORT DETAILS

1.

~ Persons Contacted

Licensee Employees

  • T. McConnell, Plant Manager
  • B. Travis, Superintendent of Operations
  • D. Rains, Superintendent of Maintenance

B. Hamilton, Superintendent of Technical Services

  • N. McCraw, Compliance Engineer
  • M. Sample, Superintendent of Integrated Scheduling

N. Atherton, Compliance

  • R. White, Instrument and Electrical Maintenance
  • S. Copp, Maintenance Planning
  • B. Gragg, Performance / Production Specialist

Other licensee employees contacted included construction craftsmen,

technicians, operators, mechanics, security force members, and office

personnel.

  • Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on March 26, 1987, with

those persons indicated in paragraph 1 above. One violation concerning the

control of temporary modifications was discussed (see paragraph 6). One

unresolved item concerning post-maintenance valve testing was also

discussed (see paragraph 7). The licensee did not identify as proprietary

any of the information reviewed by the inspectors during the course of

their inspection.

3.

Unresolved Items

An unresolved item (UNR) is a matter about which more information is

required to determine whether it is acceptable or may involve a violation

or deviation. One new UNR is discussed in this report.

4.

Plant Operations

The inspection staff reviewed plant operations during the report period,

to verify conformance with applicable regulatory requirements.

Control

room logs, shift supervisors

logs, shift turnover records and equipment

removal and restoration records were routinely reviewed.

Interviews were

conducted with plant operations, maintenance, chemistry, health physics,

and performance personnel.

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Activities within the control room were monitored during shifts and at

shift changes.

Actions and/or activities observed were conducted as

prescribed in applicable station

administrative directives.

The

complement of licensed personnel on each shift met or exceeded the minimum

required by Technical Specifications.

Plant tours taken during the reporting period included, but were not

limited to, the turbine buildings, auxiliary building, Units 1 and 2

electrical equipment rooms, Units 1 and 2 cable spreading rooms, and the

station yard zone inside the protected area.

During the plant tours, ongoing activities, housekeeping, security,

equipment status and radiation control practices were observed.

Both units operated at essentially full power for the entire reporting

period.

5.

Surveillance Testing

Selected surveillance tests were analyzed and/or witnessed by the

inspector to ascertain procedural and performance adequacy and conformance

with applicable Technical Specifications.

Selected tests were witnessed to ascertain that current written approved

procedures were available and in use, that test equipment in use was

calibrated, that test prerequisites were met, that system restoration was

completed and test results were adequate.

6.

Inadequate Control of Temporary Modification

As was reported in report 369,370/87-05, while reviewing the Unit 2

Performance Test (PT) Log on February 11, 1987, the inspector noted that

PT/2/A/4208/048, " Train 2B Containment Spray Heat Exchanger Performance

Test", had been entered in the log at 1:10 p.m., on February 9.

Part of

that PT involves heating up the refueling water storage tank (FWST) with

installed electric heaters to create a heat load such that a containment

spray (NS) heat exchanger heat balance can be performed. The FWST heaters

normally are interlocked to trip off at a temperature below that necessary

to perform an adequate capacity test / heat balance on the NS heat

exchanger. Step 8.5 of the PT directs that a lead be lifted in the heater

control circuitry so that the heaters remain energized to elevate the FWST

temperature to approximately 92 degree Fahrenheit (F). This step requires

independent verification to ensure that adequate administrative controls

are maintained over the lifted lead.

The Unit 2 FWST heater control lead was lifted in accordance with the PT

during the evening of February 9 and the Operations Staff was advised to

monitor FWST temperature to ensure that the 100 degree Technical

Specification Ilmit was not exceeded.

Through an apparent misunder-

standing, the Unit 1 Operations Staff was led to believe that an NS heat

exchanger capacity test was also scheduled for Unit 1.

They noted,

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however, on the evening of February 10, that the Unit 1 FWST heaters were

cycling to maintain normal temperature rather than remaining on

continually to raise the temperature in preparation for the anticipated

heat balance test.

Believing that the Performance Group had erred by

failing to lift the FWST heater control lead, the Operations Staff had the

Unit I lead lifted. It should be noted that there had been no PT logged

in on Unit 1 to facilitate this modification, nor had performance

requested it.

On the morning of February 11, performance personnel, in conversation with

the Operations staff, concluded that the modification on Unit I had been

performed in error. The equipment was restored to operable later that

day.

Station Directive (SD) 4.4.2,

" Control of Temporary Modifications",

defines a lifted lead in a list of fourteer types of temporary modifica-

tions.

Activities associated with a test under the direction of an

approved procedure (e.g.,

PT/2/A/4208/04B) may be excluded from the

requirements of the directive if the procedure includes appropriate steps

for the installation and removal of the temporary change, including

provisions for independent verification.

The Unit 1 FWST heater control lead lifted on February 10 was not removed

in accordance with the administrative controls established by SD 4.4.2,

nor was the lead lifted under the guidance of the NS heat exchanger PT.

During an exit interview the licensee's representatives informed the

inspectors that the Unit 1 FWST heater lead had been lifted under the

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guidance of IP/0/A/3090/02, " Controlling Procedure for Instrument and

Electrical Troubleshooting", which incorporates provisions for independent

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verification and documentation of lifted leads. At the end of the 87-05

report period, the licensee had been unable to produce the completed copy

of the above referred to procedure. The issue was, therefore, carried as

an Unresolved Item (369/87-05-01).

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The licensee ultimately produced a copy of the appropriate completed

procedure, Enclosure 11.2 which revealed that the Unit I lead had been

lifted and independently verified as previously stated.

Of concern,

however, is the following:

Procedure IP/0/A/3090/02, step 10.5.1 required that the technician

" Ensure that Temporary Modifications are used if required". The step

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refers the technician to IP/0/A/3090/30 for details on Temporary

Modification

determination.

Procedure

IP/0/A/3090/30,

Enclosure 11.1, Determining When A Temporary Change Is A Temporary

Modification, clearly indicates that the lifted lead should have been

controlled as a temporary modification.

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Station Directive 4.4.2 clearly states that when a Temporary

Modification is required, an active or new station Work Request shall

be utilized and will have " Temporary Modification" clearly marked on

it.

The Work Request shall explicitly describe the proposed

modification (e.g., which terminals will be jumped or disconnected

and in which cabinet).

The directive describes in great detail the process to follow when a

Temporary Modification is performed.

Of course, the intent of the

directive is to maintain technical and administrative control over the

modification of station equipment.

In conclusion, the Temporary Modification (lifted lead) performed on the

Unit 1 FWST heaters was required to have been controlled by either an

active test procedure, or as a Temporary Modification with appropriate

accompanying Work Requests and approvals.

This event constitutes a violation 369,370/87-08-01:

Inadequate Control

of Temporary Modification.

One violation was identified in this area.

7.

Maintenance Observations

Routine maintenance activities were reviewed and/or witnessed by the

resident inspection staff to ascertain procedural and performance adequacy

and conformance with applicable Technical Specifications.

The selected activities witnessed were examined to ascertain that, where

applicable, current written approved procedures were available and in use,

that prerequisites were met, that equipment restoration was completed and

maintenance results were adequate.

During the period from January 15 to February 14, 1987, valve INM-268, the

Unit 1 Reactor Coolant System (NC) hot leg sample header (NM) Outside

Containment Isolation Valve, underwent repair under Work Request (WR)

No. 129992 to replace a failed actuator motor.

The valve motor was

replaced and the valve was functionally tested by cycling it electrically

from the control room. The valve's indications were verified to work

correctly and both the leak test and valve stroke timing test were

completed satisfactorily prior to declaring the valve operable.

A second WR (No. 87433) was written on February 24, 1987, when INM-26B

exhibited unusual behavior during a slave relay test (PT/1/A/4200/28).

When output relays K613 and K646 from the "B" train Solid State Protection

System (SSPS) cabinet were energized 1NM-26B closed but then continued to

cycle repeatedly between the closed and open positions.

Upon investiga-

tion, Instrument and Electrical (IAE) personnel found wire terminal #24

shorted against the barrel nut for terminal #15.

The short was cleared

and the valve performed satisfactorily.

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Technical Specification (TS) 3.6.3 requires that containment isolation

valves, including INM-26B, be operable (i.e., capable of performing its

specified functions) while operating in Modes 1, 2, 3 and 4.

Unit I was

. operated in Modes 1, 2 and 3 during the period from February 14 to 24th.

Although INM-268 is normally opened only while drawing an NC System

Sample, the actuator terminals were shorted in such a manner that the

valve would have cycled repeatedly to the open position if an automatic

ESF containment isolation signal was present.

INM-26B could not have

achieved and maintained its required safety position and was, therefore,

inoperable for the period from February 14 to 24th. This is an apparent

violation of TS 3.6.3.

In terms of safety significance, it appears that

the subject penetration would have isolated via the remaining operable

isolation valve.

The failure to detect the short in the INM-268 actuator wiring raises the

concern with the NRC regarding the adequacy of post-maintenance valve

testing,

10 CFR 50, Appendix B, Criterion XI, Test Control, states that a test

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program shall be established to assure that all testing required to

demonstrate that systems and components will perform satisfactorily in

service is identified and performed in accordance with written test

procedures which incorporate the requirements and acceptance units

contained in applicable design documents.

Section 17.2.11 (Test Control) of the Duke Power Company Quality Assurance

Program Topical Report states that electrical tests, operational test,

proof tests or other special tests are performed as required to verify the

satisfactory performance of nuclear safety-related systems and components

after maintenance.

TS 4.6.3.1 requires that containment isolation valves be demonstrated

operable prior to returning the valve to service af ter maintenance,

repair, or replacement work by performance of a cycling test.

The

specified safety function of INM-268 is to close in response to a

containment isolation signal and to remain in the closed position.

Although INM-26B was successfully cycled from the control board, thereby

demonstrating one of its functions (control sample flow), it's safety

isolation function was not demonstrated prior to declaring the valve

operable on February 14.

Review of the adequacy of post-maintenance valve testing at the McGuire

facility is still being reviewed by the licensee as well as the NRC staff

and will remain unresolved pending completion of that review.

This is

UNR 369, 370/87-08-02:

Post Maintenance Testing Program.

The issue has

been referred to NRC Region II management for review because of its

potential generic implications and review of requirements regarding

post-maintenance testing.

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8.

Follow-up on Previous Enforcement Actions / Inspection Findings (92702)

The items detailed below were analyzed to ascertain that the licensee's

response is in conformance with regulatory requirements and that the

corrective measures were completed.

The inspection intent was to verify by record review, observation, and

discussions with licensee personnel the following information relating to

followup on items of noncompliance:

a.

That the licensee responded in a timely manner,

b.

That the measures taken to correct the item and avoid further items

of noncompliance were effected as described and within the time

period specified in the reply.

c.

That other licensee commitments discussed in the reply were also

completed.

(Closed) Violation 369/84-21-01, 370/84-18-01.

Procedure violation

leading to inadvertent engineered safety feature (ESF) actuation

and reactor trip. Licensee Event Report No. 370/84-15 addressed

this same incident and was previously reviewed and closed by

Inspection Report (IR) No. 370/85-32.

This violation is,

therefore, considered closed.

(Closed) Violation 369/84-11-03.

Procedure violation leading to

inadvertent train "A" blackout.

LER 369/84-14 addressed this

same incident and was previously reviewed and closed by IR

369/85-27. This violation is, therefore, considered closed.

(Closed) UNR 369/85-03-02.

LER 369/84-18 inadequacy.

The licensee

submitted Revision 1 to LER 84-18 on March 22, 1985.

The

revised LER was reviewed and appeared to have addressed the

inadequacies discussed in IR 85-03.

This UNR is considered

closed.

(Closed) Violation 369/85-06-01.

Failure to meet adequate wire

separation criteria while installing a reactor trip breaker

modification.

LER 369/85-08 addressed this same incident and

was previously reviewed and closed by IR 369/85-27.

This

violation is, therefore, considered closed.

(Closed) UNR 370/84-09-01.

During the time period covered by IR

370/84-09, the " Loss of Steam Generator Feedwater" procedure

(AP/1-2/A/5500/06) did not address the loss of a single main

feedwater pump.

The AP revisions in effect since December 3,

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1984, have provided operator guidance for response to the loss

of one er both main feedwater pumps.

This UNR is considered

closed.

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(Closed) UNR 369/87-05-01.

Control

of Temporary Modification of

Refueling Water Storage Tank (FWST) heaters. This UNR has been

resolved as a violation as discussed in paragraph 6.

9.

In-Office Review of Written Reports of Non Routine-Events (90712)

A review was performed of the written reports of nonroutine events at

McGuire.

The objective of the review was to determine, among other

things, if:

additional inspection effort is warranted in the applicable area

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corrective action is appropriate

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reported information satisfies requirements

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generic issues are present

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The delineated LERs appeared to be satisfactory, and herewith will be

closed.

50-369/ Unit 1

50-370/ Unit 2

LER 84-18

LER 84-10

LER 84-29

LER 84-12

LER 85-11

LER 84-16

LER 85-13

LER 84-17

LER 85-23

LER 85-25

LER 84-19

LER 85-30

LER 84-24

LER 85-31

LER 84-25

LER 85-33

LER 84-27

LER 85-35

LER 85-34

LER 84-28

LER 85-36

LER 84-30

LER 85-39

LER 84-31

LER 86-01

LER 85-02

LER 86-02

LER 85-05

LER 86-03

LER 85-09

LER 86-05

LER 85-10

LER 85-14

LER 85-16

LER 85-18

LER 85-20

LER 85-27

LER 85-28

LER 85-30

LER 86-01

LER 86-02

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