ML20236C996
| ML20236C996 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 03/16/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903220409 | |
| Download: ML20236C996 (8) | |
Text
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t DUKE POWER GOMPANY P.O. ISOX 33130 CitAHLOTTE. N.C. 28242 HAL 11. TUCKER,
TELEPHONE
_ vu.s emessnest (704) 373-4531
'l l
' NtNLSAB PRODUCTION
- March 16, 1989~
l U. S.. Nuclear Regulatory Commission o
Document Control Desk-
' Washington, D.C.
20555 l
9 l
Subject:
McGuire Nuclear Station
]
Docket Nos. 50-369, -370
- l Inspection Report Nos. 369, 370/88-33 l
Reply to a Notice of Violation q
Gentlemen:
Pursuant to 10CFR.201, please find attached Duke Power Company's response to-i Violation 369, 370/88-33 for the McGuire Nuclear Statlon.
1 Should there be any questions concerning this matter, contact W. T. Byers at (704) 373-6194.
a Very truly yours, lal B Tucker FORMSWTB. DOC /lcs Attachment xc:
Mr. S. D. Ebneter Regional Administrator, Region II l
U. S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta,' Georgia 30323 2
Mr. Darl Hood U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation; Washington, D. C. 20555 Mr. P. K..VanDoorn i
NRC Resident Inspector McGuire Nuclear Station p
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l 8903220409 890316
- {DR ADOCK 05000369 PDC a
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McGuire Nuclear Station Response to Violations Violation 369(370)/88-33-01 A.
Technical Specification 6.8.1 requires that' written proce-dures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, requires that. procedures be written and implemented for tests on emergency power systems.
McGuire Procedure PT/2/A/4350/02A, Diesel Generator ~2lA Operability Test, contains instructions for testing of the 2A Emergency Diesel Generator.
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Contrary to the above, procedure PT/2/A/4350/02A was not properly implemented in that the 1A Emergency Diesel Genera-tor was started on December 6, 1988 using the 2A Emergency.
Diesel Generator test procedure (PT/2/A/4350/02A).
The test was intended to be run on the 2A Emergency Diesel Generator.
This is a Severity Level IV (Supplement I) violation and applies to both units.
Response to Violation 1.
Admission or denial of the violation:
The violation is admitted as stated.
l 2.
Reason for the violation if admitted:
This violation occurred as the result of an inadequate communication of an assignment.
The Operations Procedures Supervisor did not specifically say "D/G 2A" when asking the Operations Unit 1 Supervisor for manpower support.
The Unit 3
1 Supervisor assumed the D/G to be tested was D/G 1A.
l A factor that contributed to the miscommunication was the l
fact that the Operations Unit 1 Supervisor was designated as an Operations shift manpower coordinator, involving both Unit 1 and Unit 2 work.
3.
Corrective steps which have been taken and the results achieved:
a.
The periodic surveillance test for D/G 2A was success-fully completed.
1 1
b.
This incident was reviewed with the personnel involved..
c.
Procedure " Diesel Generator Operability-Test" was l
changed to place the designation of the D/G which is I
being started at the beginning of the step instead of l
at the end.
d.
A new section to the Operations Management Procedure (OMP) was issued.
This new section addressed adequate communications, including the use of " repeat back" after verbal instructions.
'l e.
It was communicated to the McGuire Operations Shift Supervisors that a Unit Supervisor can coordinate work i
only on the unit to which he is assigned.
f '.
Identification tags were placed on the plunger relays for each D/G.
'1he tags will clearly indicate the D/G which the relay sr. arts.
.l 4.
The corrective steps which have been taken to avoid further violations-l No additional corrective actions are planned.
5.
The date when full compliance will be achieved:
The station is in full compliance with the corrective actions described above.
Violation 369(370)/88-33-03 B.
Technical Specification 3.9.4 requires, during refueling operations, that each containment penetration providing l
direct access from the containment atmosphere to the outside l
atmosphere is either:
l 1.
Closed by an isolation valve, blind flange, or manual l
valve, or l
2.
Exhausting through OPERABLE Reactor Building Contain-ment Purge Exhaust System HEPA filters and charcoal absorbers.
a.
Contrary to the above, the containment atmosphere had direct access to the outside atmosphere-during-o L
refueling operations on October 25, 1988 in that mechanical' equipment penetration E-461 was not sealed.
Core alterations recommenced prior to.
satisfactory performance of a penetration leak test following repair to the penetration foam sealant.
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v b.
Contrary to the above, the containment atmosphere had direct access to the outside atmosphere during i
refueling operations in that mechanical equipment penetrations M-260 and E-429 were not closed during the period from 9:55 p.m. on November 12, 1988 until 3:43 p.m. on November 13, 1988.
Core alterations had begun without verifying the penetrations to be completely closed by foam-f sealaut.
This is a Severity Level IV (Supplement I) violation and applies to Unit 1.
Response to Violation 1.
Admission or denial of the violation:
The violation is admitted as stated.
2.
The reason for the violation if admitted:
The violation occurred as the result of a defective proce-dure.
None of the procedures concerning penetrations M260, E429, and E461 specified the maximum length a pipe sleeve should extend beyond the penetration flange.
Neither did it provide instructions to ensure adequate spacing between i
pipes run through the penetration to allow hookup of hoses j
with quick disconnects.
3.
_ Corrective steps which have been taken and the results achieved:
a.
When containment integrity was found breached, Opera-tions personnel immediately suspended fuel movement, b.
Personnel were dispatched to seal the leaking penetra-tions.
c.
The repairs were satisfactorily leak tested and fuel movement was resumed.
d.
The procedure " Temporary Installation of DC Slyguard Heavy Foam", has been changed to specify the maximum length a pipe sleeve that shall extend beyond a pene-tration flange.
The procedure also contains steps requiring warning signs to be placed on both sides of the penetrations when the penetrations were initially sealed.
e.
" Hold" points have been added that require a' leak
" smoke" test be performed when using the procedure,
" Periodic Testing of Temporary Foamed Penetrations".
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This procedure has also been changed to document inspections of the penetrations for leakage every 2 days.-
f.
The procedure " Temporary InstallationDof.DC'Slyguard_.
Heavy Foam", has been addeduto the preventive' work request'that is used to. install cables:through penetra-tions.M260', E429, and E461 on both' Unit 1 and 2.-
4.
The corrective steps which will be-taken'to avoid further violations:
a.
'A memo will be distributed to all applicable station l
groups stating that. documentation'will be. required--
before a component or system can be returned to opera-ble status and a work group representative.will be required tx) sign the Technical Specification: Action Item Logbook.
b.
The procedure for " Temporary Installation of.DC Slyguard Heavy Foam" will have instructions'added requiring Maintenance tech support personnel to inspect penetrations M260, E429, and'E461 prior to initial foaming of'the penetrations.
It'will also require:
inspection again prior-to_ signing the " Containment Integrity Verification During' Core' Alterations" proce-dure before fuel unloading and'reloadingioperations'.
A penetration inspection inventoryEsheet:will1 document l
the inspection.
c.
Instructions will be added to the procedure referenced above to ensure adequate spacing between the S/G' Sludge Lance pipes in penetrations E461 to allow' connection of hose quick disconnects.
5.
The date when full compliance will:be achieved:
Full compliance will be achieved by 5/1/89.
Violation 369(370)/88-33-09 C.
Technical Specification 3.0.4 requires that, entry'into an OPERATIONAL MODE shall not be made when the conditions for:
the Limiting Condition for Operation are-not met'and the associated ACTION requires a shutdown if they are not met-
-within a'specified time interval.
Technical Specification 3.7.1.2 requires'two motor driven l
Auxiliary Feedwater pumps and associated flowpaths'be l
OPERABLE in MODES 1, 2, and 3.
l Contrary to the above, entry into.an. OPERATIONAL' MODE occurred when the conditions for.the Limiting Condition for l
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Operation were not met and the associated ACTION required a' shutdown within:a specified time' interval.when. Unit-1 l
. entered' MODE.3 on December' 10, 1988 and December. 25, 1988.
On both'occasi'ons-, two motor driven Auxiliary Feedwater-(CA) pumps and associated flowpaths were not. OPERABLE in that l
valve 1CA44, B.CA pump flow control' valve to C Steam Genera--
' tor; was mis-positioned fully open instead of being in a
-throttled position.-
This is a Severity Level IV (Supplement I). violation and applies'to' Unit.l.
Response to Violation 1.
Admission or denial of the violation:
The violation is admitted as stated,'except that only one motor driven CA. pump and associated flowpaths were.not Operable.
2.
The reason for the violation-if admitted:
The violation occurred as the result of inadequate. Station Directive 13.2.2,'" Identifying and Performing Plant Retest-ing".
This directive did notiprovide-adequate requirements
.i for retesting following maintenance on CA dischargeicontrol valves.
Personnel' error contributed;to the violation because the work request on 1CA-44B had been signed off as i
complete prior to the, travel stop being reset on the valve.
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3.
Corrective steps which have been taken:
a.
The travel stop on valve ICA-44B was reset.
b.
All test procedures affecting the CA system performed on Unit 1 since 1981 were reviewed'to ensure that the travel stop on valve 1CA-44B was reset to the correct position.
c.
This incident was reviewed with the personnel involved.
4.
Corrective steps which will be taken to' avoid further violations:
a.
Station Directive 3.2.2 will be revised to include i
requirements that the CA system flow balance be evalu-ated after performing work on the CA control valves.
b.
.The' current settings for the manual throttle' valve positions and travel stops on. flow control valves in the CA, RN, NI, and KC systems will be included in the Control Room Databook.
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4 c.
Maintenance and Instrument and Electrical personnel will be responsible for resetting the travel stops following maintenance on flow control valves and 2
repositioning manual throttle valves following mainte-nance.
Applicable Mechanical Maintenance and Instru-mentation and Electrical procedures will be reviewed and revised as necessary to include steps for resetting travel stops and repositioning manual throttle. valves and documenting the as-found and as-left travel stop and throttle valve positions.
d.
Guidelines will be developed to identify on the work request flow control valves and manual thrcttle valves which require special positioning after maintenance.
5.
The date when full compliance will be achieved:
l Full compliance will be achieved June 1, 1989.
f I
Violation 369(370)/88-33-05 j
i D.
Technical Specification 3.4.9.1 requires a maximum cooldown rate of 100 degrees F in any one hour period for the reactor i
coolant system.
l
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Technical Specification 3.4.9.2 limits the pressurizer l
temperature to a maximum heatup rate of 100 degrees F in any j
one hour period and a maximum cooldown rate of 200 degrees F 3
in any one hour period.
l Contrary to the above, the reactor cooldown rate limit was exceeded on May 3, 1983; the pressurizer heatup rate limit was exceeded on July 20, 1981; and the pressurizer cooldown rate limit was exceeded on April 27, 1981 and April 21, i
1985.
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This is a Severity Level IV (Supplement I) violation and applies to both units.
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Response to Violation l
1 1.
Admission or denial of the violation:
The violation is admitted as stated.
l 2.
Reason for the violation if admitted:
i The violation occurred as the result of personnel error.
No l
discrepancies were noted by operations personnel on 3 out of j
4 procedures used during the shutdown and startup modes of j
operation.
Also, Operations personnel had erroneously j
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verified the procedures complete with all acceptance crite--
ria being met.
-contributing to the violation was a weakness in' station procedure " Surveillance Requirements for Unit Shutdown" which did not direct the RO to periodically determine the actual'cooldown rate.
The procedure required the RO to i
record.the RCS pressure and temperature and pressurizer, temperature every 30 minutes.
However, the procedure did clearly specify the allowable cooldown limits and directed the RO.to verify-that the acceptance. criteria (i.e.,
cooldown limits) were met.
3.
Corrective steps which have been taken and the results achieved:
a.
Westinghouse' performed'an engineering evaluation of.the effects of the transients on the reactor coolant i
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system's integrity and determined that the events did l
not compromise the structural integrity'of: the Unit 11 i
.and Unit-2 pressurizer and.related' systems.
l b.
The Incident Investigation Report was reviewed with a.
representative from each' Operations shift to emphasize the importance of thoroughly reviewing procedures;for discrepancies and properly completing procedures.-
c.
Based on recommendation from Westinghouse's final l
engineering evaluations, the appropriate procedures i
I were revised.
d.
An addendum to the original Incident Investigation 1
Report'was written to document the results of-the. final engineering evaluation from Westinghouse.
4.
The corrective steps which have been taken-to avoid further violations:
No additional corrective steps are planned.
l 5.
The date when full compliance will be achieved:
The station is in full compliance with actions described above.
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