ML20247G376
| ML20247G376 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/12/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909190051 | |
| Download: ML20247G376 (6) | |
Text
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Dunn POWER GonIwxy P.O. DOX 33189 CilAILLOTTF., N.C. 28242 HAL H. TUCKEli TcLeenown WHIE PRFIS1 Dent (704) 373-4531 mutue emonwmon September 12, 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, 370/89-16 Reply to a Notice of Violation Gentlemen:
Pursuant to 10CFR.201, please find attached Duke Power Company's response to Violation 369, 370/89-16-02 for the McGuire Nuclear Station.
Should there be any questions concerning this matter, contact W. T. Byers at (704) 373-6194.
Very truly yours, Hal. Tucker WTB98/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 Office of Nuclear Reactor Regulation Washington, D. C. 20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station
'f6DI 8909190051 89071.2 I
PDR ADOCK 05000369 I l Q
PDC L-.-__-_______--_
McGuire Nuclear station l
Response to Violation yiplation 369(370)/89-16-02 10 CFR 50, Appendix B, Criterion III as implemented by Duke Topical Report, Duke-1, Chapter 17.2.3 requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of systems and components.
Also design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
Contrary to the above, design control measures for changes to the plant were inadequate leading to confusing instructions to craft personnel which resulted in installation of a non-safety-related positioner between a safety-related solenoid and the Chemical and Volume Control System Letdown Orifice Containment Isolation valve, INV-459A.
This resulted in a lack of assurance that the valve would perform its safety-related containment isolation function.
This is a Severity Level IV (Supplement I) violation.
Response to violation:
1.
Admission or denial of the violation:
McGuire admits the violation occurred as stated in LER 369/89-06-01, dated August 9, 1989.
2.
Reason for the violation if admitted:
The violation was due to a Design Deficiency because the valve positioner for valve 1NV-459A was installed in the wrong configuration as described by the incorrect Instrument Detail drawing during initial construction of Unit 1.
The functional mechanical design of the air control system was deficient because the solenoid valves must be able to fail the air supply to valve 1NV-459A to ensure the valve closes when required.
The problem was discovered during inspections resulting from Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment".
3.
Corrective steps which have been taken and the results achieved:
I 1
l The air supply to Valve 1NV-459A was retubed to the correct safety related configuration.
The Instrument Detail Drawings have been corrected.
Valve 2NV-495A was reviewed and found to have different type components with the valve positioner installed in the correct configuration.
l The review and inspections of air operated valves is accordance with Generic Letter 88-14 were continued in an effort to identify any additional similar problems.
4.
The corrective steps which will be taken to avoid future
. violations:
~
No further actions are considered to be necessary.
5.
The date when full compliance will be achieved:_
McGuire is presently in full compliance.
/
Response to Deviation
- g..
Deviation 369(370)/89-16-01 Section 7.8.2 of the McGuire FSAR states:
"It-is our intention to fully comply with the intent of the requirements stated in Paragraph 4.13 of IEEE 279-1971 and the position explained in NRC Regulatory Guide 1.47."
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 sud the systems actuated or controlled by the protection system.
2.
The indicating system above should also be activated automatict11y by the bypassing or deliberately induced inoperability 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 i
the protection system, and auxiliary or supporting systems that must 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 years and is expected to occur when the affected system is c.
normally required to be operable.
4.
Manual capability should exist in the control room to activate each system-level indicator provided.
L-_ _ __ _ _ _ _____---.--__ _ ----_--__
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 train is actually bypassed or rendered inoperable, there would be no change to the Bypass Indication System to indicate such.
Response to Deviationt Only one train of the Control Room Ventilation system (VC/YC) is intended to be used at one time.
The train "A" or train "B" select switches are used to choose the train that should be operational.
When one train is celected, the other train select switch should be in the off position, in accordance with OP/0/A/6450/011, " Control Area Ventilation / Chilled Water System".
The reason is that if train "A" is selected then train "A"
is operational including LOOP or LOCA initiation.
Specifically, when train "A" is selected LOOP or LOCA initiation of train "A" equipment, specified in Table 1, is permitted.
When train "A" is not selected this LOOP or LOCA initiation is blocked.
The same applies for the train "B" select Switch and LOOP or LOCA initiation of train "B" equipment listed in Table 2.
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."
Since a specific train's LOOP or LOCA initiation is blocked when that particular train is not selected, Design Engineering considered that train " deliberately rendered inoperative," and therefore, the bypass should be continuously indicated in the control room.
Indeed, the VC/YC system is unique and does not fit the applicable criteria very well, therefore, Design Engineering opted for the more conservative design that indicated when a train is unable to automatically actuate to perform its safety-related function.
In retrospect l Design Engineering acknowledges that the unused train is operational but is not aligned to immediately perform its safety-related functions therefore, continuous indication of a bypassed train could possibly mask inoperable conditions.
To resolve this uncertainty the interlock that provides bypass indication when a particular train is not selected will be removed.
This action will remove the constant bypass indication that presently exists for the unused train.
Emphasis should be
placed in operating procedures to assure that all operators are f
aware that one train must be selected at all times.
q A SPR will be written by September 29, 1989, to initiate a i
modification to resolved this concern.
Table 1 Train "A" Equipment that is dependent upon the train "A" select switch for LOOP cr LOCA initiation:
CRA-C-1 Control Room Area Water Chiller CRA-P-1 Chilled Water Pump CRA-AHU-l Control Room Area Air Handling Unit SGR-ANU-1A Switchgear Room Air Handling Units
-1C
-2A
-2C Table 2 Train "B" Equipment that is dependent upon the train "B" select switch for LOOP or LOCA initiation:
CRA-C-2 Control Room Area Water Chiller CRA-P-2 Chilled Water Pump CRA-ANU-2 Control Room Area Air Handling Unit SGR-ANU-1B Switchgear Room Air Handling Units
-lD
-2B
-2D l
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