ML20217R229
| ML20217R229 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/06/1998 |
| From: | Barron H DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-369-98-02, 50-369-98-2, 50-370-98-02, 50-370-98-2, NUDOCS 9805140209 | |
| Download: ML20217R229 (7) | |
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5 Duke Power Company A is Ewy cmyy L$
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McGuire Nudear Station mW MG01VP 12700 Hagers Ferry Rd.
Iluntersville, NC 28078-9340
- 11. B. Barron Vice Prnident. McGuire (704) 875-4800 omcr Nudear Generation Department (704) 875-4809 W
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l May 6, 1998
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l U.
S.
Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 370 NRC Inspection Report 98-02 Violation 50-369/98-02-01 Reply to Notice of Violation (NOV)
Pursuant to the provisions of 10 CFR 2.201, attached is Duke Energy Corporation's response to a Notice of Violation dated April 6, 1998 regarding the failure to adequately establish or adhere to procedural guidance for the repair of two safety-related containment isolation valves.
Duke Energy Corporation acknowledges this is a violation of the requirements of Technical Specification 6.8.1.
Enclosure 1
of Inspection Report 98-02 describing the circumstances associated with 1CF35 references procedure MP/0/A/7600/79, this should read MP/0/A/7600/077.
Enclosure 1 of Inspection Report 98-02 describing the circumstances associated with IVP8 states the failure to install all of the screws as required led to unexpected degradation of the containment isolation valve.
All 24 of the screws were octually installed, however; one screw was not in the fully seated position.
Corrective Action 3 in Section 2 under Occurrence 1 is the only regulatory commitment in this correspondence.
McGuire currently has plans to replace the feedwater isolation valve hydraulic actuators with pneumatic actuators.
Following 9805140209 980506
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,U.
S. Nuclear Regulatory Commission
, Document Control Desk Page 2 this replacement, corrective actions associated with hydraulic actuators will no longer be necessary at McGuire.
At that time the regulatory commitment associated with Corrective Action 3
will no longer exist.
Questions regarding this response should be directed to Jimmy Dial at (704) 875-4187.
Very truly yours, lY n
H.
B.
Barron, Vice President McGuire Nuclear Station
1
', U.
S. Nuclear Regulatory Commission Document Control Desk Page 3 cc:
Mr. Luis A.
Reyes Regional Administrator, Region II U.
S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,
Suite 23T85 Atlanta, Georgia 30323 Mr. Frank Rinaldi U.
S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 1
One White Flint North, Mail Stop 9H3 Washington, D.C.
20555 Mr. Scott Shaeffer Senior Resident Inspector McGuire Nuclear Station i
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1
McGuire Nuclear Station Reply to Notice of Violation l
Restatement of Violation 50-369/98-02-01 McGuire Nuclear Station Technical Specification 6.8.1, Procedures and Programs, requires that written procedures be established, implemented and maintained to cover safety-related activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978, ~ which includes licensee procedures that control maintenance activities that can affect the performance of safety-related equipment.
Inherent in these requirements is that the procedures be adequate.
McGuire Nuclear Station maintenance procedure MP/0/A/7600/79, Feedwater Isolation Valve Hydraulic Pneumatic Corrective Maintenance, Revision 12, provided instructions for the repair of the hydraulic actuator system for containment isolation valve 1CF35.
McGuire Nuclear Station maintenance procedure MP/0/A/7600/042, Fisher T-ring 9200 Series Butterfly Valve Corrective Maintenance, Revision 7,.
required that each of the 24 adjusting set screws be tightened % turn, one at a time, until the seat ring contacts the seat in all areas.
Contrary to the above, the licensee failed to adequately establish or adhere to procedural guidance for the repair of two safety-related containment isolation valves as evidenced by the following examples:
1.
Maintenance procedure MP/0/A/7600/79 was not adequate to ensure removal of entrained air in the hydraulic actuator system of the containment isolation valve ICF35 on February 14, 1998.
The entrained air degraded the operation of the containment isolation valve hydraulic actuator.
- 2. Maintenance technicians failed to follow MP/0/A/7600/042 during the installation of lower containment purge inlet isolation valve 1VP8 valve seal ring adjustments screws.
The failure to install all the screws as required led to unexpected degradation of the containment isolation valve.
s l
I Reply to Violation 50-369/98-02-01
- 1. Reason for the violation:
Occurrence 1 (lCF35)
- 1) On February 14, 1998, maintenance was performed on 1CF35 to repair a hydraulic leak.
Repair involved the replacement of a
fitting on the bottom of the hydraulic / pneumatic accumu]ator.
The entrained air degraded the operation of the valve hydraulic actuator.
This was identified on February 23, 1998 by computer alarms indicating continuous operation of the hydraulic pump.
The ability of the valve to perform the designed safety function was not affected during this occurrence.
The degraded portion of the hydraulic system is only used for normal open and close operation.
Maintenance prccedure MP/0/A/7600/077 was not adequate to ensure removal of entrained air in the hydraulic actuator system of the containment isolation valve 1CF35.
The normal fill and bleed portion of this procedure was performed during this evolution, however, there was inadequate time between valve cycles to remove air.
Maintenance procedure MP/0/A/7600/077 did not have a
specified time between valve cycles (accumulator blowdowns) to allow for removal of entrained air.
Occurrence 2 (1VP8) 2)
Maintenance technicians failed to follow MP/0/A/7600/042 during the installation of lower containment purge inlet isolation valve lVP8 valve seal ring adjustments screws.
Cf tile twenty efour adjustment screws, one was not properly adjusted.
The failure to properly adjust all the screws as required led to unexpected degradation of the containment isolation valve.
Technical Specification leakage through this penetration was never exceeded during this occurrence, therefore, the penetratica remained operable.
2.
Corrective steps that have been taken and the results I
achieved:
l Occurrence 1 (ICF35) l 1)
Maintenance personnel refilled the hydraulic reservoir and vented the kydraulic system.
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- 2) Proper hydraulic pump operation was observed during i
subsequent testing.
3)
Procedure MP/0/A/7600/077 was changed to add a requirement for a fifteen minute wait between valve l
cycles during the fill and bleed portion of the j
i procedure.
This will allow air entrained in the fluid to rise, aiding in removal.
Occurrence 2 (1VP8) 1)
All set screws associated with the T-Ring for IVP8 were adjusted and the penetration was retested with satisfactory results.
2)
Maintenance Technical Support held a meeting with Electrical System Support personnel on March 10 and 11, 1998, stressing the proper fabrication and installation of sheet gasket material and the proper technique to adjust the retainer set screws on butterfly valves with adjustable seats.
The discussion included what the ramifications can be for missing seemingly minor procedural substeps.
This meeting also reinforced strict procedural adherence, STAR, and the six human event free techniques.
3)
The involved individual and supervisor have been counseled on the above issues.
4)
Staff completed a review of procedures for Unit 1 and Unit 2 VP valve work.
Documentation discrepancies were identified during that review.
However no operability issues were identified through that review.
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,3.
Corrective steps that will be taken to avoid further
. viclations:
Occurrence 1 (1CF-35)
None beyond those described in section 2 above.
Occurrence 2 (1VP8) i None beyond those described in section 2 above.
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- 4. Date when full compliance will be achieved:
i McGuire Nuclear Station is now in full compliance.
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