ML20215C087
| ML20215C087 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/05/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8612150022 | |
| Download: ML20215C087 (6) | |
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i Dmm POWER GOMPANY P.O. BOX 33189 CHARLOTTE, N.C. 28242 HALB. TUCKER.
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December 5,1986:
$Dr."[J. Nelson Grace,; Regional' Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St. NW, Suite 2900
. Atlanta, Georgia ;30323
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370
Reference:
- NRC/0IE Inspection Report 50-369/86-28, 50-370/86-28 ~
Dear Dr. Grace:
Pursuant to 10CFR2.201,.please find attached a response to the violations which
-- were identified in the above referenced Inspection Report.
Very truly yours, p/
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e Hal B. Tucker JBD/133/jgm Attac'hment xc:' Mr. W.T. Orders-NRC Resident Inspector McGuire Nuclear Station ADOCK0500g9]I 8612150022 861205 DR l I
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'McGUIRE NUCLEAR STATION RESPONSES TO' VIOLATIONS IN INSPECTION REPORT
'50-369/86-28 AND 50-370/86-28 Violation 369/86-28-01, Severity Level IV'
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Technical Specification 3.4.2.2 requires in modes 1,.2,.and 3 that all pressurizer' 7
L Code. safety valves be.0PERABLE with a lift -setting of 2485 psig+/-1%.
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With'one pressurizer Code safety valve inoperable, the inoperable. valve must be restored to OPERABLE status within.15 minutes or. the unit must be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least BOT SHUTDOWN within the following-6. hours.
. Contrary to.these requirements, on September 2, 1986, with McGuire unit 1 in mode 3,. pressurizer code' safety valve '1NC1 lifted at 'a pressure of 2370 psi. ~ The valve
.'was subsequently found to have a repeatable setpoint of 2320 psi. The. valve was inoperable 'from June 1985 until September 1986, during which time, the unit was operated for extended periods in modes 1, 2, and 3.
Response
1.
-Admission or.denfallof the alleged violation:
Duke Power admits the violation occurred as stated'.
2'..
Reason for violation:
Station personnel and the valve manufacturer's representative feel that INC-1 lif ted at 2375' psig due to a lift setpoint downward trend continuing af ter the valve was installed. No one had reason to suspect the downward trend and thus did not recognize it as a potential problem.
Contributing; to this event, a personnel error was made when the mispositioned adjusting ring of INC-1 was verified as being set correctly. Due to a misinterpretation of the-procedure for determining setpoint, the technicians believed that three successive lifts which averaged 2485+/-1% was acceptable.
3.
Corrective steps which have been taken and the results achieved:
The adjusting ring was correctly positioned on valve INC-1.
Procedure PT/0/A/4150/05 (Pressurizer Safety Valve Setpoint Test) was revised to address problems which may occur during testing and to provide an acceptable range for each test list.
4..
Corrective steps which will be taken to avoid further violations:
Once Wylie laboratories completes testing of INC-1, procedure MP/0/A/7150/38 (Pressurizer Safety Valve Corrective Maintenance) will be revised to provide more detailed instructions on performing corrective maintenance on pressurizer safety valves. Requalification training will be revised to provide more detailed instructions on setting adjusting rings, nozzle rings and setpoints.
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5.
Date when full compliance will be achieved:
All testing and procedure revisions will be completed by 3/1/87. Changes to the requalification training program will be in place by 3/1/87. As each technician goes through their requalification session, they will receive instructions on the changes in the valve maintenance and periodic testing procedures.
Violation 369/86-28-10, and 370/86-28-10, Severity Level IV Technical Specification 3.8.1.1, requires in modes 1, 2, 3 and 4 that two emergency diesel generators be operable. With one diesel generator inoperable, the remaining diesel must be verified operable within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Both diesel generato:s must be returned to OPtRABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant must be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Technical Specification 3.9.2 requires in mode 6 that, at a minimum, two Source Range Neutron Flux Monitors be OPERABLE and operating with Alarm Setpoints at 0.5 decade above steady-state count rate, each with continuous visual indication in the control room and one with audible indication in the containment and control It is also required that each Source Range Neutron Flux Monitor be room.
demonstrated OPERABLE by performance of:
1.
A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, 2.
An ANALOG CHANNEL OPERATIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS, and 3.
An ANALOG CHANNEL OPERATIONAL TEST at least once per 7 days.
Contrary to the above:
1.
On August 1 and August 10 with McGuire unit 2 operating in mode 1, diesel generators 2B and 2A respectively were not verified to be operable within the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowed when the remaining diesel was inoperable.
2.
On August 5, 1986, with McGuire unit 1 in mode 6, it was determined that the 7-day channel operation test due to be performed on August 3,1986 had not been executed.
Response
1.
Admission or denial of the alleged violation:
Duke Power admits the violation occurred as stated.
2.
Reason for violation:
A.
The D/G surveillances were missed due to inattention to time by the operators. The operators knew the surveillances were due but forgot to do them within the required time frame.
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The missed source range surveillance was the' result of inadequate-administrative controls.
r3.
- corrective ' steps which have been taken and the results achieved:-
~A.
The D/G surveillances were run ~and completed as soon as operators realized ~ the oversight. In both cases, D/Gs were proved operable.
B.-
The source range operational test was successfully completed prior to the unit entering Mode 5.
4.
Corrective steps which will be taken to avoid further violations:
A.
The individuals involved in both incidents were counseled.
These incidents were reviewed with all licensed personnel through staff and crew meetings. A step was added to PT/1,2/A/4350/25 (Essential Auxiliary Power System Source Verification) on 9/26/86, instructing operators to use an alarm timer to notify them of the need to run the surveillance.
B.
Planned corrective actions are as follows:
1.
Establish a check-off sheet to be used in Mode 6 to keep track of the 7 day surveillance.
2.
7 day surveillance will be performed every Wednesday, when applicable, regardless of other activity.
3.
Only one PT activity will be documented on a given work request.
If the surveillance must be done again, a new work request will be obtained.
- 4.
Any time a work request is changed from one crew / schedule to another, I&E will document these change son both schedules affected. K&E will also inform the respective planners of these changes,.ss soon as reasonable, so planning can update their schedulen.
5.
I&E will verify that adequate notification exists in Operations group procedures to ensure source range surveillance is always initiated as required under the following conditions:
t Prior to entering Mode 6 from Mode 5 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to core alterations Reentering Mode 6 from No Mode 6.
The I&E procedure for performing the source range surveillance will be changed to incorporate the following improvements:
Determination of whether surveillance is satisfying the 7 day, monthly, or "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to" surveillance.
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' If ~ the surveillance is ' satisfying the "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior" spec,
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y then~the procedure will document. time'of surveillance and.
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- include wording in the procedure ' describing the recent Tech s a Spec Interpretation concerning~the "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior"-
. surveillance.
L7..
Lessons'1 earned will be shared with appropriate I&E and Planning '
personnel.
8.
Maintenance Management Procedures '(HMPs) will be evaluated for any required changes necessary to reflect the above. philosophies.
5.-
Date when full compliance will be achieved:
A.
All corrective steps were completed by.11/20/86.
B.
All corrective' actions except for item'7 will be developed and completed' by 1/1/87. Item 7 will.be. completed by 2/1/87. The station is currently in compliance regarding the subject technical specification surveillance.
. Violation 369/86-28-01, and 370/86-28-01, Severity Level V 10CFR 50.72 (b) (2) (ii), as. implemented by Duke Power Company Procedure RP/0/A/5700/10, requires that any event or ccudition that results in manual or automatic actuation of' any Engineered Safety Feature (ESP), including the Reactor Protection System (RPS), be' reported to the NRC as soon as-practical and, in all 1
cases, within~four hours of the occurrence.
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10CFR 50.72 (b) -(B) as implemented by Duke Power Company Procedure RP/0/A/5700/10 requires that any deviation from the plant's te/inical specifications authorized
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pursuant to 50.54 (x) be reported to the NRC as soon as practical and, in all cases, within one hour of the occurrence.
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Contrary to the above:
i 1.
On August 27, 1986, the NRC Operations Center was not notified of a Unit 2 ESF (Auxiliary Feedwater System) actuation within the required four-hour time period.
i 2.
On September 2,1986, the NRC Operations Center was not notified of a deviation from plant technical specifications on McGuire unit I as authorized pursuant to 50.54 (x).
Response
1.
Admission or denial of the alleged violation:
A.
Example 1 of the violation is denied.
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-Duke Power admits to a. deviation from procedure but not from plant Technical Specifications and believes that the violation _should be reworded. Duke admits the NRC should have been notified.
' 2.
- Reason for violation:
A.- ;The initiating event.was a manual reactor trip due to a loss of.
fee'dwater to S/G 2D.- Operators-manually started the auxiliary feedwater (CA) pumps to supply the S/Gs. This was clearly the proper action to take instead of waiting for an automatic CA initiation..
At the time of the NRC notification of the reactor trip, the shift supervisor was not aware that one of the CA pumps had auto' started.
' Prior to this~ incident, operators had not been instructed that a manual start of CA was considered an ESF actuation. The shift supervisor and shift engineer do not recall discussions with the NRC inspector concerning the reportability of the CA actuation. Followup notification was made-three hours and forty eight minutes following the initial notification, which was four hours and thirty eight minutes following the initisting event (reactor trip). This is within the four hour notification time requirement.
'B.
At the time of the' September 2, 1986 incident, reactor operators and supervisor's had very little time in which to decide whether or not to block the safety injection signal. The unit was in Mode 3 and personnel safety was foremost in their minds at this time. No previous training had expressly forbid blocking this signal in this situation. The 50.54(x) notification requirement was not very specific in this instance.
3.
Corrective steps which have been taken.and the results achieved:
1 A.
A followup call was made notifying the NRC of the CA auto start.
B.
The safety valve reseated, precluding the need for safety injection.
The Superintendent of Operations met with all shift personnel to discuss the philosophy of blocking safety injection signals.
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4.
Corrective steps which will be taken to avoid further violations:
A.
In the future, unplenned manual starts of ESF equipment will be considered reportable. Changes will be made to the operator training program to include this information.
B.
The Nuclear Production Department (NPD) will generate a policy statement for all Duke Power nuclear stations concerning the blocking of safety injection signals.
5.
Date when full compliance will be achieved:
A.
Changes to the operator training program will be completed by 4/1/87.
i B..
The NPD will generate a policy statement by 3/1/87.