ML20246F655
| ML20246F655 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/05/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-17, NUDOCS 8907130342 | |
| Download: ML20246F655 (5) | |
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DUKE POWER GOMPANY-P.O. BOJE 33189 CHARLOTTE, N.C. 28242 HALB. TUCKER-tuternown woe paremawr (7o4) 373-4531 wune. sam renovorune July 5, 1989 U.'S.' Nuclear Regulatory Commission Document Control Desk-Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket ~Nos.' 50-369,-370 Inspection Report Nos.'369, 370/89-11-01 Reply to a Notice of Violation Gentlemen:
Pursuant.to 10CFR.201,.please.' find attached Duke' Power Company's response to Violation 369,'370/89-11-01 for the McGuire Nuclear Station. This-reply also contains a response to the additional concerns addressed in the subject report as requested, chould there be.any questions concerning this matter, contact W. T. Byers at (704) 373-6194.
.Very,truly yours, 1
Hal B. Tucker WTB72/lcs Attachment xc:
Mr. S. D. Ebneter
-Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Darl Hood U. S. Nuclear Regulatory Commission 4
Office of Nuclear Reactor Regulation Washington, D. C. 20555 I
d Mr. P. K. VanDoorn NRC Resident Inspector l
McGuire Nuclear Station lrY 8907230342 9907o5 t3 PDR ADOCK 05000369 J
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t DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION 1
h violation 50-369(370)/89-11-01 10 CFR 50, Appendix B, Criterion V as implemented by Duke Topical Report, Duke-1, Chapter 17.2.5 requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type approp: late te the circumstances.
l Contrary to the above, Criterion V was not met as evidenced by the following
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examples:
1.
Procedures PT/1 and 2/A/4200/08, NS System Valve Stroke Timing, were inadequate, in that they did not contain instructions for filling and venting of safety systems related to the Residual Evat Removal System, resulting in a temporary loss of the Residual Heat Removal System on November 23, 1988.
2.
Procedure OP/0/A/6350/08, operation of Station Breakers, was inadequate in that it failed to provide precautions to alert operators of breaker interlocks, contributing to a partial blackout and temporary loss of the Residual Heat Removal System on November 29, 1988.
3.
Electrical drawing MCM-1399.03-0300-001 was inadequate, f-that it was not properly updated, contributing to a personnel error and temporary loss of the Residual Heat Removal System on December 1, 1988.
This is a Severity Level IV (Supplement I) violation.
Response
Example 1:
1.
Admission or denial of the violation:
McGuire admits the violation occurred as stated except the procedure being used was PT/1(2)/A/4208/02.
2.
The reason for the violation, if admitted:
1 The violation occurred due to design and procedural deficiencies. The design was inadequate in that the piping did not have adequate system vents to prevent air accumulation in the piping.
The procedure was j
inadequate in that it did not require system venting nor were there any restrictions for valve stroke timing during mid-loop operations.
The incident is also described in LER 369/88-49 (Voluntary), dated May j
15, 1989.
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i 3.
The corrective steps which have been taken and the results achieved:
i Vent valves have been added to the piping to allow proper system venting. The Performance test procedure PT/1/A/4208/02 has been changed to require system venting through these valves as a prerequisite to stroking valves INS-1B and INS-18A. Performance valve stroke procedures for the NI, NV, NS, ND, and FW systems were changed to require specific SRO review and approval prior to stroke timing each valve. The test procedures for pump tests were reviewed for possible changes though no additional changes were deemed necessary.
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4.
The corrective steps which will be taken to avoid future violations:
1 I
Operations will review and evaluate ECCS piping layouts and vent j
processes. 7111 and vent requirements will be upgraded. This will include consideration of the development of fill and vent procedures for specific evolutions.
Operations will evaluate the procedure Residual Heat removal to include an evaluation of periodic vent requirements of the ND System I
and interconnecting piping to reflect operating precautions for mid-loop and normal operations.
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The date when full compliance will be achieved:
Full compliance will be achieved by August 1, 1989.
Example 2:
1.
Admission or denial of the violation:
McGuire admits the violation occurred as stated in LER 369/88-38, dated December 29, 1988.
2.
The reason for the violation:
The violation occurred because the Unit Supervisor did net provida-l adequate written and/or verbal instructions to the Control Room l
Operator for correctly testing the breaker. !.lso, the procedure was inadequate because it did not contain precautions to require the l
effects of breaker interlocks be investigated prior to testing breakers.
3.
The corrective steps which have been taken and the results achieved:
l A step was added to the Limits and Precautions section of Procedure OP/1&2/A/6350 'f 3, Operation of Station Breakers, to require that Operation's staff, Transmission, or IAE staff must be consulted prior to cycling any breakers in the " test" position to identify any breaker interlocks which are active in the " test position. The staff does not need to be consulted if an approved procedure is utilized to cycle the breaker in the " test position.
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4.
i A Caution statement was added to the appropriate Enclosure of j
Procedure OP/0/A/6350/08, Operation of Station Breakers, to prevent persennel from cycling the 6900V supply breakers while in manual mode and racked into the test position.
A report on the event was incorporated into the Required Reading Package for review by Operations personnel during Requalification Training.
4.
The corrective steps which will be taken No further actions are considered to be necessary.
5.
The date when full compliance will be achieved:
McGuire is presently in full compliance.
Example 3:
1.
Admission or denial of the violation:
McGuire admits the violation occurred as stated.
2.
The reason for the violation:
The violation occurred due to an inadequate procedure. The subject electrical drawing was not properly updated which caused the Technician to take inappropriate action.
Corrective steps which have been taken and the results achieved:
3.
An audit of all controlled copies of drawings has been performed; all out of dato drawings have been replaced. The method of audit has been upgraded by using the Vendor Documents Index which indicates the latest revisions to the prints in addition to the Vendor Cross Reference number list which indicates the vendor number for correct The frequency of the audits of the 7300 system filing of the prints.
controlled control room prints has been increased from annually to two I
months prior to each outage and two times during the calendar year.
The IAE crews which work on 7300 equipment and use these drawings were made aware of this incident during crew meetings.
4.
Corrective steps which will be taken:
No further actions are considered necessary.
5.
Date when full compliance will be achieved:
McGuire is presently in full compliance.
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Response to Additional Concerns In the transmittal letter for NRC Inspection Report 50-369(370)/89-11,the NRC states:
We are concerned that the operating residual heat removal system was lost on three separate occasions as described in this report and the Notice of Violation. The first situation was especially significant in that air binding of the punp occurred during mid-loop operations. Your response to this report should not only address your corrective actions in response to the Notice of Violation but also a description of your actions to prevent a recurrence of loss of decay heat removal during shutdown conditions and a schedule for their completion.
Response
on October 17, 1988, the NRC issued Generic Letter 88-17, " Loss of Decay Heat Removal".
by letter dated January 3, 1989, Duke Power provided a response to the eight recommended expeditious actions in Generic Letter 88-17. By letter dated February 17, 1989, Duke responded to the requested programmed enhancements requested by the Generic Letter. Additional clarifications were provided by Duka's letter dated March 10, 1989.
A number of actions have been taken as a result of Generic Letter to prevent any future loss of decay heat removal events. These actions includes training, administrative / procedural enhancements and the addition of control room / computer indications.
The increased awareness among all rtation groups has had an immediate, positive effect. During the Unit One tube leak outage, March - May 1989, there were no loss of decay heat removal events. For example, as documented in Mr. H.B. Tucker's letter to the NRC dated April 13, 1989, I
Duke delayed surveillance testing of valve IND-34 until Unit I was no 1
longer in mid-loop operation due to its potential effects on the ND system.
Based upon our actions in response to Generic Letter 88-17 and our actions in response to the specific incidents cited above, McGuire believes that no f
further actions are necessary to prevent a recurrence of loss nf decay heat l
removal during shutdown.
If we identify any additional actions to prevent a loss of ND event, we will take such action at the appropriate time, b
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