ML20235H116
| ML20235H116 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 02/15/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8902230485 | |
| Download: ML20235H116 (11) | |
Text
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- :b i liikeIbuOr Company.
ilAL 11 Tucker
'.0 Dat33198 Vice />rsident P
- Charlotte, NC 28242 Nuclearl'rutuction
- 1 (701)3734591 DUKEPOWER February 15, 1989
' Director,-Office _of Enforcement U.S. NuclearL Regulatory Commission ATTENTI0W:
Document Control Desk Washington, DC 20555
Subject:
Duke Power Conpany McGuire Nuclear Station Docket Nos. 50-369 and 50-370 Reply to a Notice of Violation and Proposed Imposition of Civil Penalty Dated January 19, 1989 With Payment Included
'(NRC Inspection 0.eport Nos. 50-369/88-24.,
50-370/88-24, 50-36/88-29, and 50-370/88-29)
Pursuant to 10 CFR 2.201 please find attached my response to the violations contained in the NRC notification letter referenced in the above subject. This notice addressed two violations described in the following paragraphs.
The violations described in Section I of the notice involved the McGuire Units 1 and 2 Hydrocen Skimmer (VX) system and proposed a civil penalty of
$37,500. My response to this violation it contained in the attachment to this letter and a check for full payment of the civil penalty is enclosed.
Section II of the notice involved a failure to perform appropriate post-maintenance testing following modifications at McGuire Units 1 and 2.
My response to this violation is also contained in the attachinent to this letter.
I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge.
Very truly yc,urs, l
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l Hal B. Tucker JSW/349/mmf Af 0%,7ej2A' l
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Document Control Desk February.15,,1989
.Page 2 xc: Mr.'M.L..Ernst Regional Administrator, Region lII
-U.S. Nuclear Regulatory Commission-101'Marietta Street, NW, Suite 2900
. Atlanta, Georgia 30323 P.K. Van Doorn NRC Resident Inspector-McGuire Nuclear Station Mr. Darl Hood U.S. Nuclear Regulatory Commission Office of Nuclear Reactor' Regulation Washington, DC 20555 w-_-_____-___-_________-_____-_______----_______-___-______-____---__-_______---.____-__
.j-ATTACHMENT DUKE POWER COMPANY Reply to a Notice of Violation i
~fnspection Reports 50-369, 370/88-24 and 50-369,'370/88-29 Violation 369, 370/88-24 A.
Technical Specification Limiting Condition for Operation (LCO) 3.6.5.6, Containment Air Return and Hydrogen Skimmer (VX) system, applicable in Modes 1, 2, 3, and 4 requires, with.one train inoperable, to restore the inoperable train to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next six hours 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 />.
Contrary to the above, Units 1 and 2 VX systems were found to have been inoperable in that they could not perform their intended function of preventing the accumulation of hydrogen below four percent volume in localized areas or compartments of the containment, as follows:
1.
'On October 18, 1988, as found flow measurements of Unit i VX system indicated that the "A" train pressurizer cavity and both "A" and "B" trains in the reactor vessel head areas had low flows.
Prior to the Unit 1 shutdown of October 11, 1988, the reactor was operated in Modes 1 through 4 in excess of-the LCO time limit since initial plant startup.
2.
On July 19, 1988, as found flow measurements of the Unit 2 VX system indicated that the VX dampers in the reactor vessel head area were closed and low flows existed in several other containment compartments. Prior to the Unit 2 shutdown on May 27, 1988, the reactor was operated in Modes 1 through 4 in excess of the LC0 time limit since initial plant startup.
B.
10 CFR 50.59, Changes, Test, and Experiments, states that the holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety j
analysis report without prior Commission approval, unless the proposed change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question.
Further, Section 50.59(b) states that the licensee shall maintain records of changes in the facility made pursuant to Section 50.59, to the extent that such changes constitute changes to the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question as defined in 10 CFR 50.59.
Section 6.6 of the McGuire Final Safety Analysis Report (FSAR) describes, in part, that each hydrogen skimmer fan has been sized to - - _ _ _ _ _ _ _ - _ - - _
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I assure that the flow rates for each compartment can limit hydrogen accumulation to four percent volume.
Contrary to the above, on July 21, 1988, the licensee decided to q
operate Unit 2 with several containment enclosed compartment flow rates less than that necessary to limit hydrogen accumulation to four percent volume, a condition other than that described in the FSAR, and performed a safety evaluation.that was inadequate in that it did l
not determine whether the change involved an unreviewed safety question.
Collectively, the violations have been categorized as a Severity Level III problem (Supplement I).
Cumulative civil penalty - $37,500 (assessed equally between the violations).
Reply to Violation A 1.
Admission or Denial of the Violation:
The violation is admitted as stated.
2, Reason For the Violation If Admitted:
a)
The pre-operational test performed on the VX system was insufficient to prove operability. The station personnel's understanding of the system and our dependence upon previously agreed upon testing commitments led us to omit flow balance testing from the pre-operational test program.
b)
Appropriate measures were not taken to ensure the flow balance of this system was maintained through periodic testing or control of damper positions.
c)
By design, the VX System has a single header that draws air from each of the containment compartments by use of redundant fans located on either end of the header.
Either fan is capable of drawing the total design basis flows from the areas serviced.
However, the equipment configuration of the system is such that balance of the individual compartment FSAR flow rate is unobtainable when operating the fans independently. The system is being modified to correct this deficiency.
Subsequent testing will validate the new design.
3.
Corrective Steps which have been taken and Results Achieved a)
Upon receiving concerns from NRC inspectors relating to Unit 1 VX System dampers which appeared to be closed, operations personnel inspected and verified the positions of all Unit 1 VX System dampers.
During the inspection one damper was found closed and was returned to its proper position. _ - - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
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During the Unit 2 refueling outage, while taking "as found" flow measurements, performance personnel identified two dampers l~
which were mispositioned and returned them to their proper position.
l b)
During the Unit 1 outage Performance (PRF) performed a flow balance of the Unit 1 VX system to determine optimum damper positions and appropriately marked these positions.
c)
Addenda to Technical Specification interpretations were made to reflect acceptable flow measurements for the Unit.1.VX system.
d)
Modifications to the VX syster 'were completed for Unit I which cross connected suction pipin9 to improve the flow balance capability of the system.
Also check dampers were utilized to prevent reverse flow through an idle fan.
e)
A temporary modification was made to the Unit 2 VX system which will provide an alternate source of power to close the idle fan suction damper by cross connecting the respective power suppl Ws through normally de-energized cables and a red-tagged open breaker. Appropriate revisions were approved for station emergency procedures and a training package was reviewed by on-shift operators.
f)
Operations personnel developed a method to verify and control optimum damper positions.
4.
Corrective Steps Planned to Avoid Further Violations.
a)
Modifications to the Unit 2 VX system will be completed during the next refueling outage. These modifications will cross connect suction piping to improve the flow balance capability of the system and will utilize check dampers to prevent reverse flow through an idle fan.
b)
During the 1989 Unit 2 refueling outage, PRF personnel will perform a flow balance of the Unit 2 VX system to determine
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optimum damper positions and appropriately mark these positions, c)
"As Found" flow measurements will be performed by PRF personnel on the Steam Generator 2C compartment during the next Unit 2 refueling outage.
Item 4a, b, and c will be completed by November 1, 1989.
d)
A Special Task Force is reviewing pre-operational and periodic test procedures for selected safety related and balance of plant systems that were not supplied by Westinghouse. This will determine if the Design Bcses for condition 3 and 4 events of the system was or is verified by testing. This item will be completed by April 1, 1989. _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _
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5.
Date When Full Compliance Will Be Achieved:
McGuire will achieve full compliance by November 1,1989. This
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additional time is required to complete modifications scheduled during the next Unit 2 refueling outage.
Reply to Violation B l
i 1.
Admission or Denial of Violation The violation is admitted as stated.
2.
Reason For the Violation If Admitted An error was made by Design Engineering upen issuing an operability determination for Unit 2 by taking credit for the availability and operation of the hydrogen mitigation system to provide added assurance that hydrogen would not build up to concentrations capable of being detonated. A review of this incident also concluded that some confusion existed relating to operability determinations versus 10CFR50.59 evaluations.
3.
Corrective Steps Which Have Been Taken and Results Achieved:
a)
Design Engineering reevaluated flow rates utilizing regulatory Guide 1.7 and 10CFR 50.44 and issued a revised operability determination for Unit 2 which concluded that the present flow balance condition of the VX system was sufficient.
Present flow rates were determined by on-line flow measurements taken by performance performed utilizing a flow hood.
b)
Discussions were held with Region II NRC personnel to more clearly establish the distinctions between the process of performing Justification for Continued Operation (JCO) and an operability determination.
c)
Nuclear Production Department directives have been revised to include the following:
o The JCO, operability determination, and the PIR response process have been clearly defined and expected levels of NRC involvement have been established.
o Requirements to consider the questions addressed in 10CFR 50.59 have been established, o
Review responsibilities and approval levels for Nuclear Production personnel have been established.
d)
Procedures have been established at the station to control and track operability determinations.
4.
Corrective Steps planned to Avoid Further Violations Corrective measures to avoid further violations are complete.
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Date When Full Compliance Will be Achieved L
McGuire is presently in full compliance.
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Violation 50-369, -370/88-29 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, states in part that a test program shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in l
accordance with written test procedures while incorporating the requirements and acceptance limits contained in applicable design i
documents.
Technical Specification LCO 3.5.2, ECCS subsystems - T-AVE greater than 350 Degrees-F, requires that two independent ECCS subsystems, each of which is comprised, in part, of an operable centrifugal charging pump, one RHR pump, and a flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation, shall be operable in Modes 1, 2, and 3.
If one train is inoperable, the Technical Specification requires that operability be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or that the plant be in at least HOT STANDBY within the next six hours.
Technical Specification LCO 3.6.2, Containment Spray System, requires that the two independent Containment Spray Systems shall be operable in Modes 1, 2, 3, and 4 with each spray system capable of taking suction from the refueling water storage tank and transferring suction to the containment sump.
If one train is inoperable, the Technical Specification requires that operability be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next six hours.
Contrary to the above, the licensee's verification and post-modification testing program was inadequate in that the program failed to ensure proper installation of modifications and failed to ensure modified equipment would perform all intended functions prior to declaring the equipment operable. These failures resulted in three examples of Technical Specification violations as follows:
1.
Volume control tank outlet valve, INV-142B, was inoperable because it could not close automatically on a safety injection signal, rendering Unit 1 centrifugal charging pumps inoperable without manual operator action from November 10, 1987 until August 29, 1988, while operating in Modes 1, 2, and 3.
An open permissive signal necessary to open "A" and "B" train 2*
containment sump to containment spray pump supply valves, INS-1 and 1NS-18, was inoperable from November 8, 1987, when Unit 1 entered Mode 4, until September 3, 1988, rendering both trains of containment spray incapable of transferring suction to the containment sump, and therefore, inoperable.
3.
An interlock on residual heat removal valve 2ND-4, designed to close on the switchover sequence from the injection mode to the cold leg recirculation mode, was inoperable from July 2,1987 when Unit 2 entered Mode 3, until Unit 2 shutdown on May 27, 1988, rendering an RHR pump, and ECCS subsystem, inoperable on the switchover.
This is a Severity Level III violation (Supplement 1). _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. - - - _ _ _ _
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1 Reply to Violation' 50-369, -370/88-29 1.
Admission or Denial of the Violation The violation is admitted as stated.
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2.
The reason for the Violation This violation was the result of our existing functional verification program _not clearly defining the minimum functional verification requirements for a particular component. This resulted in the failure to identify open electrical links and nonfunctional control interlocks associated with the stated valves.
3.
Corrective Steps That Have Been Taken and the Results Achieved For valve 1NV-142:
a)
IAE personnel closed link L-1 and functionally verified automatic operation of valve 1NV-142.
b)
All modification packages on valve operators for both units were reviewed for adequate functional verification. Temporary test procedures were initiated where appropriate to verify operability of affected valve interlocks.
c)
Maintenance Management Procedure 1.6 (MMP-1.6)was issued which defined the minimum functional verification requirements. The revision was in progress at time if the event discovery, d)
Changes were made to procedures covering removal and installation Of valve operators, including functional verification requirements for all limit switches, associated interlocks, and automatic functions.
For valve INS-1B and INS-18A:
e)
Operations shift personnel were informed that INS-1B and 18A would have to be manually operated locally during certain accident conditions.
f)
Instrumental and Electrical (IAE) personnel implemented MEVN-1454 which returned control to the control room swite.h by placing a jumper around the open contact.
g)
A modification was completed to remove the jumper and correct the I
open contact at the valve operator.
h)
Item d above also applies to INS-1B and 1NS"18A.
i)
IAE personnel reviewed all work requests which involved safety related motor operated valve actuator work since the last ESF test on both units to ensure functional verification was performed. _
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For valve 2ND j)
All. NSM packages were reviewed for adequate functional verification.
Temporary tests were written to perform functional verification where appropriate.
k)
Item c above also applies'to 2ND-4.
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Item d above also applies to 2ND-4.
m)
All work request on safety related Motor Cperated Valve:(MOV) actuators were reviewed to ensure proper functional verification was performed.
Generic Corrective Actions That Have Been Taken:
n)
The functional verification requirements in MMP-1.6 have been fully implemented with all training completed.
o)
Changes have been made to the following procedures to give more detailed guidance for work on valve operators.
o IP/0/A/3006/01A - Removal & installation of limitorque operators I
Removal & installation or rotork operators o IP/0/A/3006/02A p)
All work has been reviewed on Unit 2 safety related MOV actuators since the last safeguards functional test and the adequacy of functional verification was examined.
Six Unit 2 valves have been identified for further evaluation.
ESF testing was completed on Unit i during the last refueling outage.
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Related instances have been reviewed with all IAE personnel.
4.
Corrective Steps p'.anned to Avoid Further Violations a)
IAE personnel will. head a review group to study the station's functional verification, retest, and post-modification testing programs to ensure proper overlap exists.
Also, the Nuclear Production Department i evaluating post maintainance testing for all three sites ar-is evaluating the methods required to insure operability is stablished prior to returning equipment to service, An Engineered safety features actuation test will be conducted b) at the end of future refueling outages to ensure that systems function as designed. This will be an ongoing process and will be conducted as a matter of routine operations for an indefinite period of time.
c)
Six (6) Unit 2 safety related Motor Operated Valves (M0V) have been identified and will be evaluated during the next Unit 2 refueling outage to verify the adequacy of functional verification. - - _ _ _ _ _ _ - ____ _ _ _ _______ --_- ___ _ __-___-.._
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Date When Full Compliance Will be Achieved McGuire will achieve full compliance by November 1, 1989 when Items a and c are completed. This additional time is needed to complete these activities during the next Unit 2 refueling outage.
Item b has been done for Unit 1.
Unit 2 will be performed during the upcoming refueling outage period.
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