ML20211B865

Ack Receipt of 870109 Response to Violations Noted in Insp Repts 50-369/86-35 & 50-370/86-35.Encl Staff Assessment of Licensee Response Provides Reasons That Violation Occurred. Corrective Actions Requested

ML20211B865
Person / Time
Site:	McGuire, Mcguire
Issue date:	02/11/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8702190582
Download: ML20211B865 (3)

See also: IR 05000369/1986035

Text

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FEB 111987

Docket Nos. 50-369, 50-370

License Nos. NPF-9, NPF-17

Duke Power Company

tRTN: Mr. H. B. Tucker, Vice President

Nuclear Production Department

422 South Church Street

Charlotte, NC 28242

Gentlemen:

SUBJECT: DENIAL OF VIOLATION

(NRC INSPECTION REPORT NOS. 50-369/86-35 AND 50-370/86-35)

Thank you for your response of JaNary 9,1987, to our Notice of Violation issued

on December 10, 1986, concerning licensed activities conducted at your McGuire

facility.

We have evaluated your response and concluded, for the reasons given in the

enclosure to this letter, that the violation occurred as stated in the Notice

of Violation. Therefore, in accordance with 10 CFR 2.201(a), please submit to

this office within 30 days of the date of this letter a written statement that

describes: (1) corrective steps which have been taken and the results achieved;

(2) corrective steps which will be taken to avoid further violations; and (3) the

date when full compliance will be achieved.

The response directed by this letter is not subject to the clearance procedure

of the Office of Management and Budget issued under the Paperwork Reduction

Act of 1980, PL 96-511.

We appreciate your cooperation in this matter.

Sincerely,

Orm S:cmo Oy,

J. HELSLW GRACE

J. Nelson Grace

Regional Administrator

Enclosure:

Staff Assessment of Licensee Response

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ENCLOSURE

STAFF ASSESSMENT OF LICENSEE RESPONSE

The NRC Regional Staff has reviewed and evaluated your response to the Notice

of Violation in light of information provided by the NRC Resident Inspectors

and contained in the applicable operating procedures.

Step 12 of Enclosure 4.2, " Pre-Heatup Checklist", of McGuire Operating Procedure

OP/2/A/6100/01, " Controlling Procedure for Unit Startup", specifically directed

that no-load programed steam generator (S/G) levels be established per OP/2/A/

6250/03A, " Steam Generator Cold Wet Layup Recirculation". However, the licensee's

response to the violation states that the intent of that step was to have the

S/Gs at no-load level, and that, since the S/Gs were already at the specified

level, the operator was not in error by signing the step as complete.

If the intent of Step 12 was, indeed, to have the S/Gs at no-load level, then

the licensee's intended corrective action of changing OP/2/A/6100/01 to read,

" Remove S/G from Wet Layup per OP/2/A/6250/03A (S/G Wet Layup Recirc)", appears

inappropriate. The proposed corrective action would change Step 12 to more

clearly direct the action which was not properly implemented on November 17,

1986, and resulted in the original violation.

The licensee's response further states that, "0P/2/A/6250/03A has nothing to

do with establishing S/G levels." A review of that OP revealed, however, that

several steps appear to pertain directly to lowering S/G 1evels from the wet

layup condition. Step 2.1, for example, directs the operator to notify chemistry

to sample the S/Gs for activity and chemicals prior to draining them to the

turbine building sump. Steps 2.4 and 2.5 instruct the operator how to align the

blowdown system to the turbine building basement ditch and then insolate the wet

layup recirc (BW) system when S/G levels are belew the upper manway cover. Step

2.8 subsequently directs the coordination of raising and lowering S/G water

levels with Chemistry until S/G water chemistry is in specification. All these

steps lend credence to the NRC's position that Step 12 of Enclosure 4.2 of

OP/2/A/6100/01 had the dual function of establishing no-load S/G levels and

securing the S/G wet layup recirculation system per OP/2/A/6250/03A.

In their response to the violation, Duke Power Company states that the cause

of the incident was an inadequate procedure. Although, it may be true that

OP/2/A/6100/01 was deficient in not clearly and unambiguously stating the intent

of Step 12 of Enclosure 4.2, the fact remains that the OP was not properly imple-

mented as written. Even though S/G water levels were verified to be at their

no-load values, they had not been established per the wet layup recirculation OP.

Had the S/G 1evels been established as directed by Step 12 of the startup OP,

then the spill would have been avoided. The licensee's proposal to clarify the

intent of Step 12 should prevent the recurrence of this incident in the future.

..

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Enclosure 2 FEB 111987

The licensee is encouraged to counsel their operating staff to exercise caution

in interpreting the intent of similar steps in this and other ops when reference

is made to activities performed "per" or "in accordance with" another procedure.

Procedures referenced in this manner may often contain hidden intents and objec-

tives which would be missed if the parent step were performed superficially.

The staff concludes that the violation, as stated in the Notice, is valid.

1 . _ . ,