ML20245L437

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Notice of Deviation from Insp on 890622-28.Deviation Noted: Method Used by Licensee to Indicate Bypass at Sys Level Failed to Comply W/Paragraph 4.13 of IEEE 279-1971 & Reg Guide 1.47
ML20245L437
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 08/08/1989
From: Herdt A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245L400 List:
References
RTR-REGGD-01.047, RTR-REGGD-1.047 50-369-89-16, 50-370-89-16, NUDOCS 8908220119
Download: ML20245L437 (2)


Text

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t ENCLOSURE 2 NOTICE OF DEVIATION Duke Power Company Docket No.50-369 and 50-370 McGuire Units 1 and 2 License No. NPF-9 and NPF-17 The following deviation was identified during a Nuclear Regulatory Commission (NRC) inspection conducted on June 2-28, 1989.

Section 7.8.2 of the McGuire FSAR states:

"It is our intention to fully comply with the intent of the require-ments stated in Paragraph 4.13 of IEEE 279-1971 and the position explained in NRC Regulatory Guide I.47."

Paragraph 4.13 of IEEE 279-1971 states:

"If. the protective action of some part of the system has been bypassed or deliberately rendered inoperative for any purpose, this fact shall be continuously indicated in the control room."

The regulatory position of Regulatory Guide 1.47 is:

1.

Administrative procedures should be supplemented by a system that automatically indicates at the system level the bypass or deliberately induced inoperability of the protection system and The systems actuated or controlled by the protection system.

2.

The indicating system above should also be activated automatically by the bypassing or deliberately induced inop?rability of any auxiliary or supporting system that effectively bypasses or renders inoperable the protection system and the systems actuated or controlled by the protection system.

3.

Automatic indication should be provided in the control room for each bypass or deliberately induced inoperable status that meets all of the following conditions:

a.

Renders inoperable any redundant portion of the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting systems that muy. be operable for the protection system and the systems it actuates to perform their safety-related functions; b.

is expected to occur more frequently than once per year; and c.

is expected to occur when the affected system is normally required to be operable.

8908220119 spogog DR ADOCK 05000369 f

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Duke Power Company 2

Docket Nos. 369 and 370

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McGuire Units 1 and 2 License Nos. NPF-9 and NPF-17 I

4.

Manual capability should exist in the control room to activate each system-level indicator provided."

4 Contrary to' the above, the method used. by the licensee to indicate at the system-level, the bypass or deliberately induced inoperability of the Control Room Area Ventilation System (VC/YC) fails to fully comply with the intent of paragraph 4.13 of IEEE 279-1971 and Regulatory Guide 1.47 in that when an operable train of VC/YC is not actually running the Bypass Indication System indicates that train is bypassed.

Therefore, if the trair is actually bypassed or rendered inoperable, there would be no change to the Bypass Indication System to indicate such.

Please provide to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, in writing within 30 days of the date of this Notice, the reasons for the deviations, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further deviations, and the date when your corrective action will be completed. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION k

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Alan R. Herd, Chief Reactor Projects Branch Division of Reactor Projects Dated at Atlanta, Georgia this 8th ay of August 1989 d

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