ML20211B865
| 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
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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FEB 111987
Enclosure
2
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.
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