IR 05000369/1998004
| ML20249A248 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20249A236 | List: |
| References | |
| 50-369-98-04, 50-369-98-4, 50-370-98-04, 50-370-98-4, NUDOCS 9806160227 | |
| Download: ML20249A248 (50) | |
Text
_ _ _
. .
U.S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket Nos: 50-369. 50-370 License Nos: NPF-9. NPF-17 Report No: 50-369/98-04. 50-370/98-04 Licensee: Duke Energy Corporation Facility: McGuire Nuclear Station. Units 1 and 2 Location: 12700 Hagers Ferry Road Huntersville. NC 28078 Dates: April 13, 1998 - April 24. 1998 Team Leader: Mike Scott. Oconee Senior Resident Inspector Inspectors: Marvin Sykes. McGuire Resident Inspector Edwin Lea Project Engineer Paul Fillion. Senior Reactor Inspector Herbert Whitener. Senior Reactor Inspector Approved by: C. Ogle. Chief. Projects Branch 1 Division of Reactor Projects
<
i Enclosure 2 l 980616'0227 980604 t
\ l C -- - _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1
._
_ _ _ _ _ _ _ _ _ -
. .
EXECUTIVE SUMMARY McGuire Nuclear Station. Units 1 and 2 NRC Inspection Report 50-369/98-04. 50-370/98-04 This two-week team inspection covered aspects of the licensee's corrective action program as defined in Nuclear System Directive 210. Corrective Action Program Directive. Revision 1. including aspects of licensee operations, maintenance engineering, and plant support. The report covered a two-week period of resident and region-based inspector Operations
. The licensee appropr ;ely identified and documented operator workaround (Section 02.1)
.
The workaround problem resolution list was managed by qualified operations personnel with a proactive approach to resolving deficiencies. (Section 02.1)
.
The licensee had identified the necessary contingencies and corrective actions to address each workaround. (Section 02.1)
.
The licensee's problem investigation process program met the requirements of 10 CFR 50. Appendix B. Criterion XVI. Corrective Actio (Section 07.1)
.
A violation was identified for two examples of failure to meet corrective action program procedural requirements for problem report )
j initiation timeliness. (Section 07.1)
.
The audits and assessments reviewed were effective in identifying problems and areas for improvement in the licensee's corrective action program. Corporate regulatory audits were effective in promoting change at the McGuire Nuclear Station. Self-assessments at tne site level were effective in finding process deficiencies and investigating new program changes. (Section 07.2)
.
The audits and assessments reviewed were performed in accordance with the licensee's Quality Assurance program and site procedures. (Section 07.2)
.
The onsite and offsite review committees have been effective in identifying and resolving safety issues at McGuire Nuclear Statio (Section 07.3)
- .
Reports to the plant review committee identifying reportable incidents
!
and Technical Specifications violations containing proposed corrective actions were not formalized in accordance with selected license commitments. This lack of procedure was identified by the licensee's i
l
_ _ _ _ _ _ _ _
_ _ _ - __
_ _ - _ - _ _ _ - -
. .
corrective action processes and new details were being incorporated into procedure (Section 07.3)
The licensee's efforts to manage the corrective action program using site specific tools appeared to be effective. (Section 07.4)
+
Most of the canceled problem reports reviewed by the inspectors were appropriately dispositioned. One of the problem reports was voided in a long series of reports on the same issue. The issue described a problem that was not resolved in a timely manner, and resulted in a non-cited violation. (Section 07.5)
.
Licensee analysis of available component mispositioning data was thorough. Recommendations based on the analysis were appropriate and were approved for implementation by management. Corrective actions were tracked in the problem report program. (Section 07.6)
The licensee's attempt to analyze mispositioning occurrences was hampered by the large number of occurrences for which the causes were undetermined. The inspectors considered the lack of determination a weakness. (Section 07.6) j
.
For a mispositioned containment isolation valve occurrence, immediate {
j corrective actions were appropriate. (Section 08.1)
{
l
The inspectors determined that an open containment isolation valve was j contrary to procedural requirements of a surveillance and was identified l as a non-cited violation. (Section 08.1)
)
.
The inspectors found that the licensee had not determined the cause for a containment isolation valve being mispositioned. (Section 08.1) '
Maintenance
.
The licensee has been aggressive in identifying equipment problem Once the licensee identified equipment deficiencies. corrective actions were identified to resolve the deficiencies. (Section M2.1)
Enaineerina
.
The Top Equipment Problem Resolution Process has been effectively implemented and managed to ensure resolution of equipment related problems that impact or may potentially impact plant reliability and sa fet (Section E2.1)
+
The licensee's Operating Experience Program was effective in capturing and evaluating available information about industry events and problems from off-site sources including equipment vendors. (Section E2.2)
I
!
-
_ _ _ _ _ _ __ __ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ - . - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _
_ _ _ - _ _ _ _ - _ - - _ _
. .
Report Details Summary of Plant Status Unit 1 Unit 1 operated at 100 percent power for the duration of the inspection perio Unit 2-Unit 2 operated at 100 percant power for the duration of the inspection-peri od .-
Review of Uodated Final Safety Analysis Reoort LUFSAR) Commitments .
While performing inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that were related to the areas inspecte The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and parameter I. Doerations 02 Operational Status of Facilities and Equipment 02.1 Ooerator Workaround Review Insoection Scooe (40500)
.The inspectors reviewed the licensee's Workaround Problem Resolution (WAPR) List,. associated documentation, and interviewed licensee
. personnel to evaluate the licensee's effectiveness in correcting equipment problems that can impair an operator's ability to understand or control plant parameters during normal or abnormal plant condition Observations and Findinas The inspectors reviewed'the licensee controlled WAPR list. The list was
' developed and maintained by the operations org3nization to formally document challenges to operators during all modes of operation. The program was outlined in Duke _ Power Nuclear System Directive (NSD) 50 Operator Workarounds. Rev. O. The inspectors determined that the licensee had initiated workarounds to support operational activities.
L and the listed workarounds were documented as required by procedure.
L For each of the operator workarounds reviewed, the inspectors confirmed l that appropriate guidance and contingencies were in place to support the l operators' ability to complete the compensatory or essential actions
[ identified. The inspectors also determined that the licensee had identified the corrective actions. or were in the process of identifying corrective actions that would reduce the number of operator workarounds.
l l
l
_ _ _ _ _ - _ - - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ -_ - -_ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _
- _ _ _ _ _ _ _
The inspectors noted that the licensee had also assessed the aggregate effect of equipment deficiencies requiring compensatory actions and/or essential actions. Compensatory actions were defined as actioris taken due to an equipment deficiency that must occur during normal operatio Essential actions were defined as actions that must be taken by a watchstander during a plant event due to an equipment deficiency. The licensee had established goals of less than one hour of compensatory action time per watchstation per shift, and less than or equal to two essential actions per watchstation per shift. The inspectors reviewed the licensee's data for selected watchstation workarounds and noted that each workstation was meeting site goals with the exception of the control room. Both units had approximately seven essential actions:
however, the licensee had planned corrective work orders to reduce the number of control room workstation workaround Conclusion The inspectors concluded that the licensee appropriately identified and documented operator workaround The WAPR list was managed by qualified personnel with a proactive approach to resolving deficiencies. The inspectors also concluded that the licensee had identified the necessary contingencies and corrective actions to address each workaroun Quality Assurance in Operations 07.1 Review of the Problem Investigation Process Inscection Scooe (71707. 40500)
The inspectors reviewed the licensee's process for identifying, documenting, and responding to problems. as established under NSD 208 Problem Investigation Process (PIP). Revision 16. dated November 17, 1997. and NSD 210. Corrective Action Program Directive. Revision dated March 21, 1996. The licensee routed the focused output of their maintenance problems, operational problems, industry event data. Duke l
'
historical event data, equipment failures, corrective action audit findings, self-assessment findings, and corrective action failures through the PIP program. The inspectors sampled the output of the PIP l
program and discussed those samples' results with appropriate Duke '
personnel and other NRC personne The PIPS were in a computer database having clear capability to generate user-defined sorts or summaries. Prior to the inspection, the inspectors screened a sample of PIP summaries. From these summaries, the inspectors selected individual PIPS for review. The selected PlPs
- were evaluated for the following attributes- l
.
Timeliness of response
- Quality of evaluation
! I l
r
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
j
_ _ - _ _ _ _ _ _ _ -
.
Effectiveness of corrective action
. Accuracy of information
.
Compliance with reporting requirements Observations and Findinas Under the licensee's program, each PIP was assigned a significance category code selected from four defined categories. Categories 1 and 2 were for more significant events (MSE). and categories 3 and 4 were for less significance events (LSE). Assignment of a category code invoked the level of response and evaluation defined by the 3rocedure for that category. The inspectors found this process meets t1e requirements for corrective action program The inspectors reviewed 59 PIPS. 23 of which were MSE For the 59 PIPS reviewed. the eve age time from initiation to closure was 139 days. The average time to evaluate the problem and define the corrective actions was 30 days. These times were in keeping with the licensee's progra The inspectort evaluated the timeliness of response to each PIP reviewed. In general, timeliness was good. However, for two PIPS described below, the initiation t*]1 ness did not meet the program requirement PIP 2-M96-1440 was written to resolve a problem with the starting air system of diesel generator 2A. On April 29, 1996, an outage surveillance test on the diesel generator indicated that a portion of the starting air system was degraded. Through discussion with cognizant engineers, the inspectors found that the licensee strongly suspected !
that the problem was with one of the four solenoids operated inlet i valves. 2VG-62. Unit 2 returned to power after the outage on May 16, 1996. PIP 1440 was initiated the next day. May 17. The inspectors noted that no troubleshooting was conducted before unit startup. Later testing and disassembly of the inlet valve showed that the valve was binding. The valve was refurbished at the next refueling outage. NSD 208. Problem Investigation Process. Revision 10. dated March 21. 199 which was in effect at the time of problem discovery. required. in
"
Section 208.6. that: .in all cases PIP initiation is to occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after realization (discovery) that a PIP should be writte PIP '1440 was written 18 days after discovery, which did not meet program requirements. The inspectors agreed that the diesel generator and starting air system were always operable during the period in questio .
i Nevertheless, the designed-in redundancy was degraded. Considering the importance of the starting air system in terms of safety system l integrity, the inspectors considered implementation of the corrective l actions described above to be marginal with regard to timelines !
---.-----__-;
_ _ _ ______ ___ - __ -____ _ _
. .
i
! The inspectors'also observed during the review of PIPS 1-M97-1904 and 0-
!: M97-1933 involving mispositioned valves, that the circumstances of the problems in the two PIPS were very similar. In 1-M97-1904, while performing the reactor coolant system (NC) fill and vent procedure, the seal . return containment isolation valve 1NV-95 was closed resulting in a Hi and Hi-Hi vibration alarm when NC pump 1A was started. Valve 1NV-95 l
-
was required open when NC pumps were started. The pump was secured-immediately and an engineering evaluation indicated no pum) damage. In 0-M97-1933. when-performing the engineering safeguards (ES:) test, the l suction pressure of the auxiliary feedwater (CA) pump 1A was
,
a) proximately zero pounds )er square inch gauge-(psig). Valve ICA-4 i w1ich aligns the pump to t1e upper storage tank for testing. was found closed resulting in a suction path through the hotwell. The inspectors-
! verified that the corrective actions were appropriate and were
- implemented. However. -the timeliness of the issuance of PIP 0-M97-1933 did not meet NSD 208 requirements. The ESF test was performed on May . The PIP was issued May 7. 1997. In the meantime, another mispositioning occurred. PIP 1-M97-1904. on May 6, 199 The situations described above for PIPS 2-M96-1440 and 0-M97-1933 represent 'a violation of- 10 CFR 50. Criterion V. Instruction Procedures and Drawings, in that the two PIPS did not meet procedure requirements in terms of time to initiate a PIP after discovery of a proble In the case of the starting air system, delay in PIP initiation meant delay in licensee management awareness of the problem, which contributed to delay in initiating troubleshooting for an l- important component. In the case of the mispositioned valve delay in t
the PIP precluded dissemination of information, which could have prevented a subsequent similar event. The violation (VIO) is identified as 50-369.370/98-04-01. Failure to Follow Procedure for Time to Initiate a PIP.
l The inspectors found that the quality of the evaluations and the ;
,
effectiveness of corrective actions for the 59 PIPS reviewed were '
l generally good. In one case, a corrective action was not properly-documented for en LSE PIP (96-1256). In another case, the corrective action for an LSE PIP was not performed nor tracked (96-1827). and this PIP was re-opened. These problems, when put in perspective of all the PIPS reviewed, were not seen as indicating any programmatic problem by ;
the inspectors. The inspectors were aware that the licensee was taking !
steps to more effectively track corrective actions, which should help
- preclude the problem of the lost corrective action in the futur The inspectors found four PIPS where the cause code was either not correct or not entered. The inspectors found one PIP where the system
-
l
'
. code was incorrect. These codes were used for trending purposes. The
. inspectors did not consider coding errors in about six percent of the PIPS reviewed a significant proble L__-__________-__________
. _ _ _ _ - _ _ _ - _ _ _ _ - - _ _ _ _ _ _ - - _ _ _ - _ - - - - - - - - - - - -- -
. .
The inspectors did not identify any problems with reporting requirements in reviewing the 59 PIP Conclusions
!
A sample of identified problem reports was selected from the Problem Investigation Process database. Each report in the sample was reviewed against the requirements of the licensee's controlling procedure. The program met the requirements of 10 CFR 50. Appendix B Criterion XV Corrective Actio A violation was identified for two examples of failure to meet corrective action program procedural requirements for problem report initiation timelines .2 Ouality Assurance Audits and Assessments Insoection Scope (40500)
Audit and assessment reports were reviewed for compliance with 10 CFR 50 Appendix B requirements. the Duke Power Company Quality Assurance Program Topical Report (Duke-1-A), the McGuire Technical Specification NSD 208 dated November 1997. Problem Investigation Process, and NSD 607. dated June 1997. Self-Assessments. These audits and assessments were done on various licensee activitie Observations and Findinas Audits The inspectors reviewed the following audit reports performed by the Regulatory Audit Group from the Duke Power General Office: SA-97-14(MC)(RA): Consolidated Performance Audit. January 9.1997 SA-97-09(MC)(SITA)(CA): Auxiliary Feedwater System. October 3 . SA-97-08(MC)(RA): Corrective Action. April 14. 1997 SA-97-12(MC)(RA): Corrective Action. October 1. 1997 SA-98-05(MC)(RA)(SITA): Corrective Action Implementation. March 20. 1998 The inspectors observed that the audits were adequate in content and identified valid issues and caused positive change in the licensee's corrective action progra _ _ _ _ _ _ .
-_ _- -__ _ _____- _-_- _ _ - ___ - _ - ____ - __-_____ -__ - - _
. .
The inspectors determined.that the McGuire management group generally responded well to the audit findings. The general office audit groups returned multiple times on inspections to ensure organization was tracking with corporate and regu,the McGuire compliance latory expectation Based on a Duke audit item stemming from a Catawba Nuclear Station licensing submittal a compliance problem was identified. PIP 97-3544 identified that' valves SA-1 and SA-2. that are containment isolation-valves, are not in the McGuire UFSAR as isolation valves and that these valves were not in compliance with General Design Criteria 57. of.10 CFR 50. Appendix A. These auxiliary steam supply manual isolation valves are normally locked open for auxiliary feedwater actuation purposes to-supply steam to the turbine driven auxiliary feedwater pump. There is no automat' closure on-those lines. Catawba had submitted a license exemption'on similar valves at that site that was still being_ reviewed by NRR. The subject McGuire PIP was still open and had been open since September 30. 1997. The PIP text showed that Catawba UFSAR list their valves as containment isolation valves. Further, the PIP indicated that McGuire Nuclear Station was awaiting the response to the Catawba plant exemption request before preceding with an action. Based on the present lack of direction for the PIP, the inspectors-identified an Item (URI)
50-369.370/98-04-02 GDC 57 Implementation and UFSAR Actions on Valves SA-1 and SA-2, to evaluate licensee follow-u Self- Assessment Self assessment activities were specified in NSD 607. Self Assessment Generally, a small internal team perform assessments in each subsection of the site organization. These assessments were annual reviews divided ,
into quarterly sections with a written approved plan signed by the grou !
manager. The assessment included to)ics important to safety and l
. reliability, areas of identified weatness (such as findings indicated by l Institute of Nuclear Power. NRC, Nuclear Safety Review Board. auditors, i and others)., new or recently revised programs and processes, and !
personnel safety issues. Assessment findings and recommendations were l entered into the PIP database. The following self- assessments were '
reviewed by the inspectors:
PIP Department I Assessment Date Number Number l
97-1159 Chemistry SA97-1 3/20/97 Training SA97-1 3/25/97 97-1255 Engineering SA97-1 3/26/97 97-1600 Operations SA97-2 4/10/97 97-1892 Operations SA97-10 5/5/97
'
97-2268 Operaticns SA97-6 6/4/97 97-3378 Maintenance SA97-8 9/17/97 97-4142 Commodities SA97-19 11/4/97 and Facilities l e_ _____ _ _ _ _ -
_ _ _ . -_ _ . _ _ _
._ __- _ ___________ -_______ _ _ - ___ _ _
( -
l i
l
The assessments were useful to the plant, had a safety focus, and met their defined purposes. .The findings were tracked to completion. In several cases, again responding to corporate audit findings, the later assessments referenced operational event information relevant to the McGuire sit Conclusion The audits and assessments reviewed were effective in identifying problems and areas for improvement in the licensee's corrective action program. Corporate regulatory audits were effective in promoting change at the McGuire Nuclear Station. Self-assessments at the site level were effective in finding process deficiencies and investigating new program change The audits and assessments reviewed were performed in accordance with the licensee's Quality Assurance program and site procedure .3 Onsite and Offsite Review Committee Insoection Scooe (40500)
The inspectors evaluated licensee compliance with Technical Specifications (TS) Selected License Commitments (SLC) and the licensee administrative procedures regarding Plant Operations Review Committee (PORC) and Nuclear Safety Review Board (NSRB) activitie The inspectors also evaluated the ability of these organizations to effectively identify, assess. and resolve significant plant safety issue Observations and Findinos Plant Goerations Review Committee The inspectors reviewed several documents including NSD 308. SLC 16-13-2. and SLC 16.13-3 that established the operating guidelines for the McGuire PORC. The PORC was established to evaluate plant operation and provide a cross-disciplinary management review of complex issues that have the potential to impact safe operation of the station. The inspectors reviewed PORC minutes and noted that the PORC was fairly consistent in accurately characterizing the significance of plant issues and the potential impact on plant safety. The PORC considered equipment ,
functionality, regulatory requirements, and overall extent of the adverse condition in their decision-making proces The inspectors confirmed that the PORC membership included representatives from each of the necessary organizations including operations, engineering. maintenance, safety assurance and plant support. This PORC membership had a good breadth of knowledge regarding
- _ _ _ _ _ _ - - _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _
- _ - _ _ _ _ _ _ _ - _ - - _ _ - - - _ _ _ _ _ _ _ - - - _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
.
integrated plant operations and was effective in seeking out and resolving issues in areas needing improvemen The inspectors noted a minor discrepancy in that NSD 308. PORC, did not incorporate guidance to provide a report to the Station Vice President and PORC of incidents reportable to the NRC pursuant to TS and all TS violations. as well as, proposed corrective actions in accordance with SLC 16.13-3 The licensee had been communicating this information to station organizations: however, no specific reporting method was established for PORC members. An internal audit (see below) identified the problem. initiated a PIP, and corrective action was in process. The licensee recognized this oversight and has_ responded by initiating changes to NSD 308 to incorporate instructions for developing and issuing a formal report to the Station Vice President and PORC members for all incidents reportable pursuant to TS. TS violations, and_onsite environmental release The inspectors also reviewed McGuire Safety Review Group Evaluation Report SA-97-45. Comparison of SLC and NSD 308 PORC Review Requirements that had been performed to outline discrepancies between the SLC and NSD 308. .The report accurately identified the deficiencies in the NSD that were incorporated into the _ PIP program for evaluation and resolutio Nuclear Safety Review Board The inspectors reviewed TS 6.5.2 and NSD 309. which outline the responsibilities and requirements of the NSRB. The NSRB serves as an independent review boarc. providing a backup review to the normal station organization reporting to the Executive Vice President. Nuclea The NSRB monitors and evaluates trend information provided by the McGuire safety review group (SRG) and proposes recor.endations when warranted. The NSRB also provided independent review and audit of designated licensee activities to identify items needing increased management attentio The inspectors reviewed NSRB meeting summaries for the 1997 calendar year and first quarter 1998. Based on the review, the inspectors noted that NSRB focused on technical issues consistent with inspection and third party findings. The NSRB utilized inputs from regulatory agencies and various industry sources to assess plant safety performance. The NSRB made observations and recommendations regarding plant specific and
>
generic . issues requiring increased management attentio , Conclusions
,
The inspectors concluded based on reviews of licensee documents and discussions with PORC members and NSRB staff. that the onsite and offsite review committees have been effective in identify and resolving ;
safety issues at McGuire Nuclear Station. The NSRB operated in '
accordance with McGuire TS 6. The McGuire PORC provided good onsite e
i i
'
l C____._______.____._-_____ _ _ _ _ _ - _ _ - - - - - - - - - - - - - - - - - - -
-__-__-__----_--- - -- - - - -
. .
reviews of station activities. However, reports to the plant review committee identifying reportable incidents and TS violations containing proposed corrective actions were not formalized in accordance with selected license commitments. This lack of procedure was identified by the licensee's corrective action processes and new details were being incorporated into procedure .4 Manacement involvement in Corrective Action Process Insoection Scope (40500)
The inspectors reviewed the process and internal controls for implementation of the corrective action progra Observations and Findinas Through reviews of documentation and interviews with station personnel, the inspectors determined that station management responded positively to general office auditors in making improvements to the corrective action process. Management created process tools to track corrective action timeliness and quality. Although these management review processes were not proceduralized. they provide a real-time, highly responsive methodology to the proces Site management initiated two management review panels, the Ten Oldest Open Ones Meetings (T000M) and the Corrective Action Review Board (CARB). to oversee the process. The inspectors attended a weekly T000M panel during the inspection reviewed the output of both meetings, and reviewed their charter The mission statement of T000M was to ensure timeliness of corrective actions while maintaining safe and reliable operation. The charter objectives were to focus on keeping MSE PIP age less than six months old and LSE PIPS age less than eighteen months old. During the meeting. the site managers discussed the oldest item in their area and this was adequately reviewed by the site manager The CARB charter objectives were to review completed root cause analysis. to understand the causal factors contributing to selected PIP initiating events, and to review the solutions being proposed to prevent or mitigate the recurrence. The CARB and the T000M meet weekly. The managers sponsoring a particular root cause and their root cause evaluators would present the root causes at the CARB. As a part of the review. the CARB would provide feedback and additional directio The T000M and CARB meetings are well-attended meetings with an agenda established by the SRG. The SRG tracked the output of the meetings and provided a reference and technical source for the meetings. The T000M meeting attended by the inspectors was chaired hv the Station Vice President and staffed by the major site manager.. which included the Plant Manage The T000M reviewed the oldest open items and questioned the reason for exceedino established goal As of April 1. 1998, there
- _ _ _ _ _ - _ _
- _ _ _ _ _ _ - _ _ _ _ _ _ .
. .
-
L 10 i
Lwere 30 MSE PIPS older than six months and 20 LSE PIPS older than 18 1 months, i i
The licensee has a scorecard on the site's corrective action MSE PIP i program that presented the status of the program. This is a part of a <
proactive Duke corporate management initiative to evaluate and track the
,
'. corrective action 3rograms at each of the three nuclear facilitie i This snapshot of t1e program was published monthly in the Performance J Measures Status Report at all Duke sites and was based on how well MSE '
PIPS were being addressed. The snapshot was based on the average evaluation scores in seven areas. The numbers were derived from the !
- site PIP coordinators scoring of each site's MSE PIPS. In areas scored, the McGuire lowest ratings were in root cause analysis quality and timeliness. Appropriate corrective action received the highest scor ,
! Conclusion ;
The licensee's efforts to manage the corrective action program using site specific tools appeared to be effectiv .5 Canceled Problem Reoorts '
a- Insoection scooe (40500)
In 1997, the licensee canceled 125 problem reports. The inspectors sampled the canceled reports to decide if there were valid reasons for canceling the reports examined. During the conduct of the review, the inspectors s30ke with site personnel involved with the PIPS and evaluated otler licensee document Observations and Findinos The inspectors examined 10 canceled problem reports generally finding no-unacceptable reasons for the cancellations. The support information regarding the cancellation was mainly found in the PIP data bas Eight duplicate PIPS were cancele Several were voided'due to error or misunderstandin The inspectors successfully tracked the duplicates to a completed corrective action or a specific action.' In one instance, an tissue on accessibility to the power operated relief valves had a long problem report history (PIPS 97-2468. 97-1892, and 97-15). The canceled '
PIP occurred after final resolution had been achieved. This issue had been-reviewed over several years and the issue had a licensee defining study done (PIP 97-15). The. final actions blended cost and need. The inspectors determined that the operations management (Nuclear Operations L Shift Manager) involved were satisfied with the existing corrective l action and those actions met regulatory guidanc ;
I One issue, regarding main feedwater isolation valves, had a history of f problem reports. two of which had been canceled (97-273 and 96-3415): '
On November 27. 1996, valve ICF-26AB had a mechanical problem that required work. The valve was worked at a reduced reactor power level of
___ _ _ - _ _ _ _ N
_ _ _ _ _ _ _ - _ _ _ - - - - - - - - - - - - - - - - - - -- -~ -
28 percen The valve was controlled under the auspice of TS 3.3.2. which has a six hour Limiting Condition for Operation for the feedwater isolation valve s] edification. During the work. the valve was left open longer than four 1our The following PIPS had been written on the subject:
Number Date TS 3.6.3 Position 96-3409 11/27/96 Valve exempted 96-3415 11/28/96 Voided due to PIP 96-3409 96-3588 12/17/96 Valve exempted 97-273 1/23/97 Voided due to PIP 96-3588:
treat valve as TS valve 97-1069 3/15/97 Valve under TS: issue LER 369/97-1 and Revision 1 Per PIP 96-3409 (Section 9), the licensee had changed a TS interpretation for TS Sections 3.6.1.1. and 3.6.1.2. and 3.6.3 in June 3. 199 The CF-26AB valve was exempted from TS 3.6.3 to establish containment integrity by having closure capability as it is listed in UFSAR Table 6-112 and is identified as Leak Class 1 and Leak Reference B (as shown on the pages 9 and 14 of Table 6-112). The Technical Specification 3.6.3, which is the containment isolation TS section, has four hour limits for its applicable valve When the valve failed in Nnvember 1996, a licensee dialogue was initiated regarding the applicability of TS 3.6.3. This discussion continued through the above listed PIPS until May 19, 1997, when the licensee issued Revision 1 of LER 369/97-01. Failure to Comply with Technical Specification 3.6.3 Following Valve ICF-26AB Inoperabilit The LER text discussed the fact the licensee had made an incorrect interpretation at the time of the valve failure and was reporting the noncompliance and concluded that the event did not result in any uncontrolled releases, personal injuries, or radiation overexposur Misinterpretation of reference documents caused the failure to comply with requirements of TS in a timely manner regarding applicability of TS 3.6.3 to this valve. The inspectors determined that the corrective actions of the LER have been accomplishe The licensee was not timely in arriving at the above corrective actio The requirements of 10 CFR 50 Apaendix B, Criterion XVI. Corrective Action, apply in that measures slall be established to assure that conditions adverse to quality, such as failures, defective material and equipment, and noncompliance are promptly identified and corrected. In this case, the licensee took longer than four months to arrive at a
_ _ _ _
-- - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - - _ _ - _ _ _
. .
correct decision. The above events are considered non-repetitive, licensee identified and corrected violation that is identif_ied as a non-cited violation (NCV) consistent with Section VII.B.1 of the NRC Enforcement Policy. . This is identified as NCV 50-369/98-04-03. Failure
,to' Complete Timely Corrective Action. This LER and its revision are close Conclusions Most of the canceled problem reports reviewed by-the inspectors were
, appropriately dispositioned. One of the problem reports was voided in a long series of reports on the same issue. The issue described a problem that was.not resolved in a timely manner, and resulted in a non-cited violatio .6 Assessment and Trendina of Miscositionina Events InsoectiortScoce (40500)
The inspectors. reviewed the licensee's assessment and trending of mispositioning occurrence Observations and Findinas The licensee is reporting, tracking and trending mis]ositioning occurrences. For Duke nuclear facilities in 1997, t1e data were as-follow McGuire Non-consequential occurrences 89 Consequential Events 1 Catawba Non-consequential occurrences 46
.
Consequential Events 2 Oconee Non-consequential occurrences 85 Consequential Events 5 The inspectors reviewed the licensee Assessment Report of Mispositioned Components (SA-98-02 (MC)(SRG)) dated February 25, 199 In this report the licensee reviewed and analyzed dispositions due to o)eration chemistry, and maintenance for the period of 1996 throug, October 199 A total of 133 disposition PIP reports at the MSE and LSE levels were reviewed during the assessment. Causes were known for 43 occurrence Causes for the remaining 90 were unknown. Of the MSE reports, there were no consequential events reported in-1996 and only one consequential event in 1997. However, the LSEs had increased by 25 percent from 1996 to 1997. This was attributed to 170 days in refueling outages (more opportunities .for component manipulations or inadvertent contact with components) and a lower threshold of reportin ,
L. . _ _ , _ _ , , _ _ . _ _ _ . _ . . _ . _ - _ _ _ _ . - - - - - - - - - -- -
--_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
. .
Of the 43 mispositionings with known causes 31 were assigned to the the
!
area of operations. Causes contributing to operations' mispositioning, L which heavily involved procedural inadequacies, were:
-
Procedure did not return a component to the desired position;
-
Incorrect component position specified by procedure:
-
Vague procedure steps: an Failure of personnel to effectively utilize program barriers designed to prevent error Examples of barriers to dispositions were administrative tools such as self-checking. Stop-Think-Act-Review, and Qualify-Validate-and-Verification of information and procedure From the analysis, a number of corrective action recommendations were made that management had a] proved for implementation. These actions were in progress and were 3eing tr6cked in the PIP progra Conclusions The inspectors considered that the analysis of the mispositioning available data was thorough. Recommendations based on the analysis were appropriate and were approved for implementation by managemen Corrective actions which were in progress were being tracked in the PIP program. However, the licensee's attempt to analyze the mispositioning occurrences was hampered by the large number of occurrences for which the causes were undetermined. The inspectors considered the lack of determination a weaknes Miscellaneous Operations Issues (92712. 92902)
0 (Closed) Unresolved Item (URI) 50-370/97-18-01: Mispositioned Containment Isolation Valve During Unit 2 Refueling Operations On December 2. 1997, the outboard containment isolation valve 2NC-66B for the pressurizer relief tank spray line, penetration M-216. was found open during refueling operations. Immediate corrective actions by the operator were a]propriate. The valve was closed and operators were dispatched to t1e Unit 2 containment to verify that the inboard j isoletion valves were closed. No breach of containment had occurre This issue was made an URI pending the licensee's investigation of the root caus The licensee investigated the mispositioning and documented the results in PIP 2-M97-4517. From the operators aid computer it could be determined that valve 2NC-56B was documented closed in the co m inment i
- _ _ __
penetration status sheet at 2:45 a.m. on November 29. 1997. The computer data indicated that the valve was re-opened at 10:11 p.m. on November 29. 1997. The three operators on duty in the control room indicated that they could not recall manipulating 2NC-56B from the control board. A retiew of maintenance history showed that no maintenance had been performed that could have caused the valve to 03e An engineering evaluation reviewed several scenarios and concluded t1ey were improbable. However. a work order was written to examine the limit switch. The most probable cause of the mispositioning was that an operator inadvertently pushed or bumped the open switch long enough to allow the valve seal-in circuit to activate and stroke the valve full ope The inspector determined that the open containment isolation valve 2NC-56B was cont. ry to the procedural requirements of PT/2/A/4200/002C for penetration status during refueling operations. This non-repetitive licensee identified and corrected violation is identified as an NCV consistent with Section VII.B.1 of the NRC Enforcement Policy: NCV 50-370/98-04-04: Containment Isolatiori Valve 2NC-568 Not Aligned According to Containment Integrity Penetration Status Shee The inspectors conclusions are summarized as follows:
.
For the mispositioncd containment isolation valve occurrence, immediate corrective actions were appropriate:
.
The licensee had not determined the reason for the valve disposition: an .
The open containment isolation valve was contrary to procedural requirements of a surveillance that was identified as an NC .2 (Closed) URI 50-369.370/98-02-03: Followup on Licensee's Previous Industry Experience Review Regarding Multiple Rod Drop Events The inspectors requested the licensee's o)er6 ting experience review
.
group to make a word search of their data]ase covering the time period l
of January 1.1994. to April 22, 199 ~
They made a search on the words rod drop." ~ dropped rod." ~ rods dropped." and ~ rods falling.' The initial search generated a list of 80 items. This list was reviewed by i
the licensee and the NRC inspectors to select only those items that may l relate to the URI. This refined search produced a list of 17 item Each of the 17 items had come from the nuclear network, which was generated from information supplied by the NRC about daily events or Institute of Nuclear Power Operations notifications. The inspectors reviewed the full text of these communications. The earliest item was dated April 1995. and three of the items were about the McGuire rod drop event in February 1998. Several of the events on the list were similar to the McGuire event in that multiple rods dropped and the operator responded by manually tripping the reactor. Several event descriptions
. - - _ - _ . _ _
_ _ _ _ - - _ - - . - - _ -
' - ' ' ~
indicated that the particular plant had instructions in the operating procedures to manually trip the reactor in the event of multiple rod drops. None of the event descriptions indicated that thece was any actual requirement to immediately manually trip the reactor upon multiple rod drops. Therefore, this item is close II. Maintenance M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Material Condition of Facility Inspection Scone (40500)
The inspectors acsessed material condition of the facility to gain insights as to the effectiveness of the licensee's corrective action program in identifying and correcting problems. This assessment was accomplished through walkdowns of various plant areas and by reviews of the operator workaround list and Major Equipment Problem Resolution (MEPR) lis Observations and Findinas The inspectors conducted walkdowns of selected areas of the turbine building and the reactor building. The walkdowns were performed to determine if the licensee was identifying equipment problems and
- corrective actions to resolve the problems once they were identifie During the walkdowris, the inspectors identified only four deficiency tags that were greater than six months old. For each of the deficiency tags identified, the inspectors verified that work request had been written to correct the problems. During the review of the work request, the inspectors determined that, for two of the deficiencies identified, the corrective actions had been complete The inspectors informed the licensee that the work request indicated that the corrective actions had been completed. The licensee promptly reviewed the work reques verified that the corrective actions had been completed, and removed the two deficiency tag Overall, the inspectors noted a low number of deficiency tags less than six months old. This was an indication that the licensee was aggressively identifying and correcting deficiencies once they were identified. The effort made by the licensee to keep the plant equipment properly operating was also evident by the excellent material condition of the plant and the relatively low number of open work item Conclusion The inspectors concluded that the licensee has been aggressive in identifying equipment problems. Once the licensee identified equipment
_--____
__ _
_ _ - _ _ - _ - _ - _ - _ _ _ - -
.
deficiencies, that corrective actions were identified to resolve the deficiencie M Alternate AC Source Testina Insoection Scope The inspector reviewed PIP 96-1493. that identified concerns associated with testing of the SSF diesel generator. The PIP was initiated by a licensee-sponsored standby shutdown facility (SSF) self-assessment tea The concerns were raised following a licensee review of industry events associated with a blackout evaluation at Maine Yankee Station. The inspectors reviewed documentation and interviewed licensee personnel concerning the response to the questions raised by the self-assessment team, Observations and rindings The PIP raised the specific concerns that no dynamic testing had been performed on the SSF diesel generator (D/G) and no periodic testing was performed to demonstrate SSF D/G loading as it would be used during an emergency. In response to questions raised in the PIP. the licensee concluded that because the D/G was manually loaded during the performance of procedure OP/0/A/6350/04 Standby Shutdown Facility Diesel Operation. and it is only loaded to 72 percent capacity. that no dynamic testing was required. The licensee also concluded that the testing performed by the manufacturer was sufficient to demonstrate dynamic load capability of the SSF 0/G. The licensee also concluded that, based on the monthly testing and tests conducted by the manufacturer, additional periodic testing of the SSF D/G during refueling outages was not necessar The inspectors questioned the licensee's methodology inquiring as to why the licensee does not adhere to guidance provided by NUMARC 87-0 Revision 1. B.10. NUMARC 87-00. B.10 stated, in part, that ~0nce every refueling outage, a timed start (within the time period specified under blackout conditions) and rated load capacity test shall be performed.'
During interviews with licensee personnel, the inspectors were informed that based on the performance of monthly surveillance PT/0/A/4200/00 Revision 19. Stand)y Shutdown Facility Operability Test. that no additional testing was required, and the requirement of NUMARC 87-00 was satisfie At the conclusion of the ins required for the SSF D/G was not clear. pectio Pending the actualNRC additional testing revie the issues associated with the testing of the SSF D/G will be tracked as IFI 50-369.370/98-04-05. Alternate AC Source Testing Per NUMARC 87-0 B.10.
- - _ _ _ _ _ _ _ _ .
_ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _
.
17 Conclusion The inspectors were unable to determine if adequate testing of the SSF D/G was being performed. Specifically, testing according to NUMARC 87-10. B.10. which required the SSF D/G be tested once every refueling outage, by performing a timed start and rated load capacity test. This issue was left as an IFl item pending further NRC review of the licensee's basis for their testing proces ,
III. Enaineerina El Conduct of Engineering E2 Enaineerina Support of Facilities and Eauipmeg E2.1 Too Eauioment Problem Resolution Process The Top Equipment Problem Resolution Process was evaluated within the previous six-months and documented in McGuire Inspection Report 98-0 During the current inspection, the inspectors performed limited reviews i to confirm the previously documented findings. As a result of the f reviews, the inspecto.'s concluded that the licensee has effectively 1 managed safety and non-safety related equipment problems that could I impact plant reliability and safet ]
E2.2 Review cf Goeratina Experience Proaram Insoection Scope (40500) )
The inspectors inspected the licensee's Operating Experience Program (OEP) program. The OEP was designed to capture information regarding industry events and problems identified outside the site and evaluate that information. The following specific inspection act,<1 ties were
.
conducted:
. Reviewed four recent randomly selected PIPS related to OEP:
. Reviewed the licensee's response to Generic Letter (GL) 83-2 ] tem 2.2. Part 2. Vendor Interface for Safety-Related Components: )
. Reviewed the licensee's responses to GL 90-03. Relaxation of Staff Position in GL 83-28. as well as the NRC's reply to the licensee I commitment: an '
. Requested a word search involving " dropped-rod events" be made on the OEP data base to demonstrate the completeness of the data and capability to generate a summary.
l l l
l
_
J
___ __- _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _
. .
18 ,
4 Observations and Findinas The OEP program was a corporate program, which applied to all three Duke sites. Review of OEP related PIPS indicated that the OEP 3rogram was evaluating events and potential problems from the other Duce sites and industry-wide. The inspectors found that evaluations were thorough and timel In reviewing the GL res)onses, the inspectors learned that a violation had been issued at anotler Duke site for a problem with the program to evaluate vendor information (letters). As ) art of the corrective actions for that violation the program had 3een recently revise The !
new program was defined in NSD 319. Vendor Technical Information Program which was an improvement over the older, less specific OEP procedure NSD 204. One basic improvement of the new program over the old was consolidation under one corporate level group, which should correct any problems caused by the older fragmented program. The inspectors '
reviewed NSD-319 finding that it implemented the commitments made with regard to GL 83-28 and GL 90-0 Review of the OEP summary of items generated by the " rod drop" word search indicated the data base was complete and good evaluations had i been performed for the item '
c. Conclusions The licensee's OEP was effective in capturing and evaluating available I information about industry events and problems from off-site sources '
including equipment vendor IV. Plant SL'ooort R1- Conduct of Radiation Protection and Chemistry ;
R1.1 General Comments (71750)
The inspectors performed tours of the controlled access area and reviewed radiological postings and worker adherence to protective l clothing requirements. Locked high radiation doors were properly '
controlled, high radiation and contamination areas were properly posted, and radiological area survey maps were updated to accurately reflect radiological conditions in the respective area V. Management Meetinos l i
X1 Exit deeting Summary L l The resident inspectors 3 resented the inspection results to members of ;
licensee management at t7e conclusion of the inspection on April 24 i
L
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
~
. .
19981 The licensee acknowledged the findings presented. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED
' Licensee Barron. H;. Vice President McGuire Nuclear Station Bhatnagar. A. , Superintendent. Plant Operations Boyle, J. , Civil / Electrical / Nuclear Systeme '.agineering Byrum, W., Manager, Radiation Protection Cash, M., Manager Regulatory Compliance
,
Dolan, B., Manager, Safety Assurance Evans.W., Security Manager Geddie. E., Manager McGuire Nuclear Station
'Loucks,_L,, Chemistry Manager Peele, J., Manager Engineering
. Thomas. K.. Superintendent. Work Control
<
Travis, B., Manager, Mechanical Systems and Equipment Engineering INSPECTION PROCEDURES USED
.IP '.71707 : Conduct of Operations-IP 40500:- Effectiveness of Licensee Controls in Identifying, Resolving. and Preventing Problems IP 92902: Maintenance - Followup-IP.90712: Licensee-Event Report Review ITEMS OPENED'AND CLOSED-OPENED 50'-369.370/98-04-01 VIO Failure to follow Procedure for Time to Initiate a PIP (Section 07.1)
50-369,370/98-04-02 URI GDC 57 Implementation and UFSAR Actions on Valves SA-1 and SA-2 (Section 07.2)
.50-369,370/98-04-03 (lCV Failure to Complete Timely Corrective Action (Section 07.5)
.50-370/98-04-04 NCV Containment Isolation Valve 2NC-56B Not Aligned
. According to Containment Integrity Penetration Status Sheet (Section 08.1)
., :50-369.370/98-04-05 IFI- Alternate AC Source Testing Per NUMARC 87-0 B.10 (Section M7.1)
.
-
O________-_______ . . . - . . b
_ - _ _ _ _ _ _ - _ - -_ _ _ - ______ _ _ _ _ _ _ _ _ - - _ _ _ - - _ _ _ _ _ _ . - _ - _ _ - - - - - _ . _ _ _
. .
I 20 k
- CLOSED i
50-370/97-18-01 URI-. Hispositioned Containment Isolation Valve During Refueling Operations (Section 08.1)
50-369.370/98-02-03 URI Followup on Licensee's Previous Industry Experience Review Regarding Multiple Rod Drop
' Events (Section 08.2)
50-369/97-01 LER Rev. O and Rev. 'l (Section 07.5)
50-369.370/98 04-03- NCV Failure to Complete Timely Corrective Action (Section 07.5)
- 50-370/98-04-04 NCV Containment Isolation Valve 2NC-568 Not Aligned According to Containment' Integrity Penetration Status Sheet (Section 08.1)
LIST OF ACRONYMS USED CA Auxiliary Feedwater CARB Corrective Action Review Board CFR Code of Federal Regulations
- D/G Diesel Generator
'
ESF -
Engineered Safety Feature GDC General Design Criteria GL- Generic Letter [NRC]
Hi- High
- IFI Inspector Followup Item IR- Inspection Report LER Licensee Event Report
- LSE- Less Significant Event MEPR Major Equipment Problem Resolution
MSE More Significant Event
- NC- Reactor Coolant System ,
NCV- Non-Cited Violation NRC- Nuclear Regulatory Commission NRR NRC Office of Nuclear Reactor Regulation
' NSD . . Nuclear Site Directive NSRB Nuclear Safety Review Board-
. NPF _ ' Nuclear Power Facility DEP' Operational' Experience Program-FDR' Public Document Room PIP Problem Investigation Process PORC Plant Operations Review Committee psig pound per square inch gage
' SLC ' Selected License Commitment SRG ' Safety Review Group 1 - SSF Safe Shutdown Facility.
m _ ____ _ _ __ _
- - - . . .
_ _ _ _ _ _ _ - _ _ - _ _-____ __
r
,
T000M Ten Oldest Open Ones' Meeting TS Technical Specifications UFSAR- ' Updated Final Safety Analysis URI; Unresolved' Item
! VIO- Violation'.
,
WAPR: Workaround Problem Resolution
..
-
I l
_ - - - - _ _ _ _ _ - - _ - . - . _ - . _ _ - - _
. _ _ . _ _ _ __
- - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
.
NOTICE OF VIOLATION i Duke Energy Corporation McGuire Units 1 and 2 Docket Nos. 50-369. 50-370 License Nos. NPF-9. NPF-17 During an NRC inspection conducted on April 13-24, 1998, a violation of NRC requirements was identifie In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG-1600, the violation is listed below:
10 CFR 50. Appendix B. Criterion V. Instructions. Procedures, and Drawings states that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedure Nuclear System Directive 208. Problem Investigation Process (PIP).
Section 208.6. stated that ' .in all cases PIP initiation is to occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after realization (discovery) that a PIP should be written."
Contrary to the above. PIP 2-M96-1440 and PIP 0-M97-1933 were not initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after realization (discovery) that a PIP should have been written. PIP-2-M96-1440 was written on May 17. 1996, and the date of discovery was April 29. 1996. PIP 0-M97 1933 was written on May 7, 1997, and the date of discovery was May 2, 199 This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201. Duke Energy Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington D.C. 20555 with a copy to the Regional Administrator Region II. and a copy to the NRC Resident Ins)ector at the facility that is the subject of this Notice. within 30 days of t7e date of the letter transmitting this Notice of Violation
.
(Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level. (2) the corrective steps that have been taken and the results achieve (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modifie suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown consideration will be given to extending the response tim Enclosure 1
__ _ _ _ _ _ _ _ _
- - _ _ - _ _ - _ - _ - _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ - -
.
Notice of Violation 2 If you contest' this enforcement action, you should also provide a copy of your response to the Director. Office-of Enforcement. U. S. Nuclear Regulatory Commission Washington D.C. 20555-000 Because your res)onse will be placed in the NRC Public Document-Room (PDR). to the extent possi)1e. it should not include any personal. privacy. proprietary, or safeguards information so that it can be placed in the PDR without-redaction. If personal privacy or proprietary information is necessary to provide-an acceptable response. then please provide a bracketed copy of your
'respor'e that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must s)ecifically identify the portions of your response that you wish to have withleld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response. please provide the level of protection described in 10 CFR 73.2 Dated at Atlanta. Georgia this 4th day of June 1998
.
f
^
< ,
u
- _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ ._
. _ . . _ - _ _ _ _-_ - ___ _ _
U.S. NUCLEAR REGULATORY COMMISSION REGION II '
I Docket Nos: 50-369. 50-370
,
License Nos: NPF-9. NPF-17 Report No: 50-369/98-04, 50-370/98-04 Licensee: Duke Energy Corporation Facility: McGuire Nuclear Station.- Units 1 and 2 Location: 12700 Hagers Ferry Road Huntersville. NC 28078 Dat'es: April 13.1998 - April 24.1998 Team Leader: Mike Scott. Oconee Senior Resident Inspector Inspectors: Marvin Sykes. McGuire Resident Inspector Edwin Lea. Project Engineer Paul Fillion. ~ Senior Reactor Inspector Herbert Whitener. Senior Reactor Inspector Approved by: C. Ogle. Chief. Projects Branch 1 Division of Reactor Projects
.,
Enclosure 2 l
L _ _ - -_ ____ _
_ _ _ _ _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
. .
EXECUTIVE SUMMARY McGuire Nuclear Station. Units 1 and 2 NRC Inspection Report 50-369/98-04. 50-370/98-04 This two-week team inspection covered aspects of the licensee's corrective action program as defined in Nuclear System Directive 21C. Corrective Action Program Directive. Revision 1. including aspects of licensee operations, maintenance, engineering, and )lant support. The report covered a two-week period of resident and region-3ased inspector Doerations
.
The licensee appropriately identified and documented operator workaround (Section 02.1)
.
The workaround problem resolution list was managed by qualified operations personnel with a proactive approach to resolving deficiencies. (Section 02.1)
.
The licensee had identified the necessary contingencies and corrective actions to address each workaround. (Section 02.1)
.
The licensee's problem investigation process program met the requirements of 10 CFR 50. Appendix B. Criterion XVI. Corrective Actio (Section 07.1)
.
A violation was identified for two examples of failure to meet corrective action program procedural requirements for problem report initiation timeliness. (Section 07.1)
.
The audits and assessments reviewed were effective in identifying problems and areas for improvement in the licensee's corrective action program. Corporate regulatory audits were effective in promoting change at the McGuire Nuclear Station. Self-assessments at the site level were effective in finding process deficiencies and investigating new program changes. (Section 07.2)
.
The audits and assessments reviewed were performed in accordance with the licensee's Quality Assurance program and site procedures. (Section 07.2)
.
The onsite and offsite review committees have been effective in identifying and resolving safety issues at McGuire Nuclear Statio (Section 07.3)
.
Reports to the plant review committee identifying reportable incidents and Technical Specifications violations containing proposed corrective actions were not formalized in accordance with selected license commitments. This lack of procedure was identified by the licensee's t
I -- -- - - - - -
- _ _ _ - _ - - - - - - - ----
--
.
correct.ve action processes and new details were being incorporated into procedure (Section 07.3)
.
The licensee's efforts to manage the corrective action program using I
site specific tools appeared to be effective. (Section 07-.4)
.
Most of the canceled problem reports reviewed by the inspectors were appropriately dispositioned. One of the long series of reports on the same issue. problem reports The issue was voided described in a a problem that was not resolved in a timely manner, and resulted in a non-cited violation. (Section 07.5)
Licensee analysis of available component mispositioning data was thorough. Recommendations based on the analysis were appropriate and were approved for implementation by management. Corrective actions were tracked in the problem report progra (Section 07.6)
.
The licensee's attempt to analyze mispositioning occurrences was hampered by the large number of occurrences for which the causes were undetermined. The inspectors considered the lack of determination a weakness. (Section 07.6)
.
For ~a mispositioned containment isolation valve occurrence, immediate corrective actions were appropriate. (Section 08.1)
.
The inspectors determined that an open containment isolation valve was contrary to procedural requirements of a surveillance and was identified as a non-cited violation. (Section 08.1)
The inspectors found that the licensee had not determined the cause for a containment isolation valve being mispositioned. (Section 08.1)
Maintenance
.
The licensee has been aggressive in identifying equipment problem Once the licensee identified equipment deficiencies, corrective actions were identified to resolve the deficiencies. (Section M2.1)
Enaineerina
.
The Top Equipment Problem Resolution Process has been effectively implemented and managed to ensure resolution of equipment related problems that impact or may potentially impact plant reliability and safet (Section E2.1)
The licensee's Operating Experience Program was effective in capturing and evaluating available information about industry events and problems from off-site sources including equipment vendors. (Section E2.2)
_ _ - _ .
_ _ _ _ _ _ _ _ _ _ - _ _ - _ - - - - - - - - - - - - - - - - - -
S Report Details Summary of Plant Status Unit 1 Unit 1 operated at 100 percent power for the duration of the inspection perio Unit 2 Unit 2 operated at 100 percent power for the duration of the inspection perio Review of Uodated Final Safety Analysis Report (UFSAR) Commitments While performing inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that were related to the areas inspecte The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and parameter I. Doerations 02 Operational Status of Facilities and Equipment 02.1 Goerator Workaround Review Insoection Stone (40500)
The inspectors reviewed the licensee's Workaround Problem Resolution (WAPR) List. associated documentation. and interviewed licensee personnel to evaluate the licensee's effectiveness in correcting equipment problems that can impair an operator's ability to understand or control plant parameters during normal or abnormal plant condition Observations and Findinas The inspectors reviewed the licensee controlled WAPR list. The list was developed and maintained by the operations organization to formally document challenges to operators during all modes of operation. The program was outlined in Duke Power Nuclear System Directive (NSD) 50 Operator Workarounds, Rev. O. The inspectors determined that the licensee had initiated workarounds to support operational activities, and the listed workarounds were documented as required by procedur For each of the operator workarounds reviewed. the inspectors confirmed that appropriate guidance and contingencies were in place to support the operators' ability to complete the compensatory or essential actions identified. The inspectors also determined that the licensee had identified the corrective actions. or were in the process of identifying corrective actions that would reduce the number of operator workaround . _ -
_ _ _ _ _ _ _ _ _
.
l
The inspectors noted that the licensee had also assessed the aggregate effect of equipment deficiencies requiring compensatory actions and/or essential actions. Compensatory actions were defined as actions taken due to an equipment deficiency that must occur during normal operatio Essential actions were defined as actions that must be taken by a watchstander during a plant event due to an equi 3 ment deficiency. The licensee had established goals of less than one lour of compensatory action time per watchstation per shift and less than or equal to two essential actions per watchstation per shift. The inspectors reviewed the licensee's data for selected watchstation workarounds and noted that each workstation was meeting site goals with the exception of the control ~ room. Both units had approximately seven essential actions; however, the licensee had alanned corrective work orders to reduce the number of control room wor (station workaround Conclusion The inspectors concluded that the licensee appropriately identified and documented operator workarounds. The WAPR list was managed by qualified personnel with a proactive approach to resolving deficiencies. The inspectors also concluded that the licensee had identified the necessary contingencies and corrective actions to address each workaroun Quality Assurance in Operations 07.1 Review of the Problem Investigation Process Insoection Scone (71707. 40500)
The inspectors reviewed the licensee's process for identifyin documenting, and responding to problems, as established under NSD 20 Problem Investigation Process (PIP) Revision 16. dated November 17, 1997, and NSD 210. Corrective Action Program Directive. Revision dated March 21, 1996. The licensee routed the focused output of their maintenance problems, operational problems, industry event data. Duke historical event data, equipment failures, corrective action audit findings. self-assessment findings, and corrective action failures through the PIP program. The inspectors sampled the output of the PIP
,
i program and discussed those samples' results with appropriate Duke personnel and other NRC pei _,nnel .
'
The PIPS were in a computer database having clear capability to generate user-defined sorts or summaries. Prior to the inspection, the inspectors screened a sample of PIP summaries. From these summarie the inspectors selected individual PIPS for review. The selected PIPS were evaluated for the following attributes:
. Timeliness of response
. Quality of evaluation
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.__ _______ - _ -
.
.
Effectiveness of corrective action
. Accuracy of information
.
Compliance with reporting requirements Observations and Findinas Under the licensee's program, each PIP was assigned a significance category code selected from four defined categories. Categories 1 and 2 were for more significant events (MSE). and categories 3 and 4 were for less significance events (LSE). Assignment of a category code invoked the level of response and evaluation defined by the arecedure for that category. The inspectors found this process meets t1e requirements for corrective action program The inspectors reviewed 59 PIPS. 23 of which were MSE For the 59 PIPS reviewed. the average time from initiation to closure was 139 days. The average time to evaluate the problem and define the corrective actions was 30 days. These times were in keeping with the licensee's progra The inspectors evaluated the timeliness of response to each PIP reviewed. In general, timeliness was good. However, for two PIPS described below, the initiation timeliness did not meet the program requirement PIP 2-M96-1440 was written to resolve a problem with the starting air system of diesel generator 2A. On April 29, 1996, an outage surveillance test on the diesel generator indicated that a portion of the starting air system was degraded. Through discussion with cognizant engineers, the inspectors found that the hcensee strongly suspected that the problem was with one of the four solenoids operated inlet valves. 2VG-62. Unit 2 returned to power after the outage on May 16, 1996. PIP 1440 was initiated the next day May 17. The inspectors noted that no troubleshooting was conducted before unit startup. Later testing and disassembly of the inlet valve showed that the valve was binding. The valve was refurbished at the next refueling outage. NSD 208. Problem Investigation Process. Revision 10. dated March 21. 199 '-hich was in effect at the time of problem discovery. required, in
.
~
Section 208.6. that: .in all cases PIP initiation is to occur within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after realization (discovery) that a PIP should be written."
PIP 1440 was written 18 days after discovery, which did not meet program requirements. The inspectors agreed that the diesel generator and starting air system were always operable during the period in questio Nevertheless. the designed-in redundancy was degrade Considering the importance of the starting air system in terms of safety system integrity the inspectors considered implementation of the corrective actions described above to be marginal with regard to timeliness.
l
_ . _ _ . _ . _ _ _ _ _ _ _ _ _ _ _
__ . _ _ ._ _ _ _ _____-__-_____ _ ____
l -
l 4 The inspectors also observed during the review of PIPS 1-M97-1904 and 0-
.
f- M97-1933-involving mispositioned valves. that the circumstances of the problems in the two PIPS were very similar. In 1-M97-1904 while performing the reactor coolant system (NC) fill and vent procedure the seal return containment isolation valve 1NV-95 was closed resulting in a Hi and Hi-Hi vibration alarm when NC pump 1A was started. Valve INV-95 was required open when NC pumps were started. The pump was secured immediately and an engineering evaluation indicated.no pump damage. In 0-M97-1933. when performing the engineering safeguards (ESF) test the suction pressure of the auxiliary feedwater (CA)
a) proximately zero pounds )er square inch gaugepsig).(pump 1A was Valve ICA-4 w11ch aligns the pump to tie upper storage tank for testing, was found closed resulting in a suction path through the hotwell. The inspectors verified that the corrective actions were appropriate and were implemented. However, the timeliness of the issuance of PIP 0-M97-1933 did not meet NSD 208 requirements. The ESF test was performed on May 2, 1997. The PIP was issued May 7. 1997. In the meantime, another mispositioning occurred. PIP 1-M97-1904, on May 6. 199 The situations described above for PIPS 2-M96-1440 and 0-M97-1933 represent a violation of 10 CFR 50. Criterion V. Instruction Procedures and Drawings. in that the two PIPS.did not meet procedure requirements in terms of time to initiate a PIP after discovery of a proble In the case of the starting air system. delay in PIP initiation meant delay in licensee management awareness of the proble which contributed to delay in initiating troubleshooting for an ,
'important component. In the case of the mispositioned valve, delay in the PIP precluded dissemination of information, which could have prevented a subsequent similar event. The violation (VIO) is identified as 50-369.370/98-04-01. Failure to Follow Procedure for Time to Initiate a PI The inspectors'found that the quality of the evaluations and the effectiveness of corrective actions for the 59 PIPS reviewed were .
generally good. In one case, a corrective action was not properly
. documented for an LSE PIP (96-1256). In another case the corrective action for an LSE PIP was not performed nor tracked (96-1827). and this PIP was re-opened. .These problems, when put in perspective of all the PIPS reviewed, were not seen as indicating any programmatic problem by l
.the inspectors. The inspectors were aware that the licensee was taking steps to more effectively track corrective actions, which should help preclude the problem of the lost corrective action in the futur ;
The inspectors found four PIPS where the cause code was either not !
correct or not entered. The inspectors found one PIP where the system J code was incorrect. These codes were used for trending purposes. The inspectors.did not consider coding errors in about six percent of the
_
PIPS reviewed a significant proble ,
l
_ _ _
__ __ ------ - - -
.
The inspectors did not identify any p oblems with reporting requirements in reviewing the 59 PIP Conclusions i
A sample of identified problem reports was selected from the Problem Investigation Process database. Each report in the sample was reviewed against the requirements of the licensee's controlling procedure. The program met the requirements of 10 CFR 50. Appendix 8. Criterion XV Corrective Actio A violation was identified for two examples of failure to meet corrective action program procedural requirements for problem report initiation timelines .2 Quality Assurance Audits and Assessments Inspection Scope (40500)
Audit and assessment reports were reviewed for compliance with 10 CFR 50 Appendix B requirements, the Duke Power Company Ouality Assurance Program Topical Report (Duke-1-A), the McGuire Technical Specification NSD 208, dated November 1997. Problem Investigation Process, and NSD 607, dated June 1997. Self-Assessments. These audits and assessments were done on various licensee activitie Observations and Findinas Audits Tie inspectors reviewed the following audit reports performed by the Regulatory Audit Group from the Duke Power General Office: SA-97-14(MC)(RA): Consolidated Performance Audit. January 9.1997 SA-97-09(MC)(SITA)(CA): Auxiliary Feedwater System, October 3 . SA-97-08(MC)(RA): Corrective Action. April 14. 1997 SA-97-12(MC)(RA): Corrective Action. October 1. 1997 SA-98-05(MC)(RA)(SITA): Corrective Action Implementation. March 20, 1998 The inspectors observed that the audits were adequate in t.ontent and identified valid issues and caused positive change in the licensee's corrective action program.
_ _-_ __-_ _
,,,,-__.-.___,.----,-r_ - , - - , ---- -- - - " - - - - - - ~ ~ ~ - - ~ ' ' - --
. .
The inspectors determined that the McGuire management group generally-responded well to the audit findings. The general office audit groups returned multiple times on inspections to ensure the McGuire compliance organization was tracking with corporate and regulatory expectation Based on a. Duke audit item stemming from a Catawba Nuclear Station licensing submittal._ a compliance problem was identified. , PIP 97-3544 identified that valves SA-1 and SA-2. that are containment isolation
. valves, are not in the McGuire UFSAR as isolation valves and that these valves-were not in compliance with General Design Criteria 57 of 10 CFR 50, Appendix A. These auxiliary steam supply manual isolation valves are normally locked open for auxiliary feedwater actuation purposes to
. supply steam to the turbine driven auxiliary feedwater pump. There is no automatic closure on those lines. Catawba had submitted a license exemption on similar valves at that site that was still being reviewed by NRR. The subject McGuire PIP was still open and had been open since September 30. 1997. The PIP text showed that Catawba UFSAR list their valves as containment isolation valves. Further, the PIP indicated that McGuire Nuclear Station was awaiting the response to the Catawba plant exemption request before preceding with an action. Based on the present lack of direction for the PIP. the inspectors identified an Item (URI)
50-369.370/98-04-02. GDC 57 Implementation and UFSAR Actioris on Valves SA-1 and SA-2. to evaluate licensee follow-u Self- Assessment Self assessment activities were specified in NSD 607. Self Assessment Generally, a small internal team perform assessments in each subsection of the site organization. These assessments were annual reviews divided into quarterly sections with a written approved plan signed by the group manager. The assessment included to]ics important to safety and reliability, areas of identified weacness (such as findings indicated by Institute of Nuclear Power. NRC Nuclear Safety Review Board, auditor and others), new or recently revised programs and processes and personnel safety issues. Assessment findings and recommendations were entered into the PIP database. The following self- assessments were 4 reviewed by the inspectors:
PIP Department Assessment Date Number Number 97-1159 Chemistry SA97-1 3/20/97 97-1242 Training SA97-1 3/25/97 97-1255 Engineering SA97-1 3/26/97 97-1600 Operations SA97-2 4/10/97 97-1892- Operations SA97-10 5/5/97 !
97-2268 Operations SA97-6 6/4/97 l 97-3378 Maintenance SA97-8 9/17/97 97-4142 Commodities SA97-19 11/4/97 and Facilities L i
!- 1 l
'
C__._. _.. __. . . . m .m.___ . _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - - _ - _ - _ _ - _ _ - -
. .
!
The assessments were useful to the plant, had a safety focus, and met !
their defined The findings were tracked to completion. In i several cases, purpose again responding to corporate audit findings, the later assessments referenced operational tvent information relevant to the !
McGuire sit l Conclusion The audits and assessments reviewed were effective in identifying !
problems and areas for improvement in the licensee's corrective action i program. Corporate regulatory audits were effective in promoting change at the McGuire Nuclear Station. Self-assessments at the site level were effective in finding process deficiencies and investigating new program j change The audits and assessments reviewed were performed in accordance with l the licensee's Quality Assurance program and site procedure .3 Onsite and Offsite Review Committee 1 Insoection Scoce (40500)
The inspectors evaluated licensee compliance with Technical Specifications (TS), Selected License Commitments (SLC). and the licensee administrative procedures regarding Plant Operations Review Committee (PORC) and Nuclear Safety Review Board (NSRB) activities. The i inspectors also evaluated the ability of these organizations to effectively identify., assess. and resolve significant plant safety issue Observations and Findinas Plant Ooerations Review Committee
'
The insoectors reviewed several documents including NSD 308, SLC 16-13- '
'
2. and SLC 16.13-3 that established the operating guidelines for the
.McGuire POR The PORC was established to evaluate plant operations, and provide a cross-disciplinary management review of complex issues that have the potential to impact safe operation of the statio The inspectors reviewed PORC minutes and noted that the PORC was fairly consistent in accurately characterizing the significance of plant issues and the potential impact on plant safety. The PORC considered equipment functionality, regulatory requirements and overall extent of the j adverse condition in.their decision-making process.
l~ The inspectors confirmed that the PORC membership included l
'
representatives from each of the necessary organizations including !
operations. engineering, maintenance, safety assurance and plant i support. This PORC membership had a good breadth of knowledge regarding
E_ __ _ - -- - - - - -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
. .
8 integrated plant operations and was effective in seeking out and resolving issues in areas needing improvemen The inspectors'noted a minor discrepancy in that NSD 308. PORC, did not incorporate guidance to provide a report to the Station Vice President and PORC of incidents re violations, as well as, portable to the proposed NRC pursuant corrective actions intoaccordance TS and all with TS
'SLC 16.13-3e. The licensee had been communicating this information to station organizations: however, no specific reporting method was established for PORC member An internal audit (see below) identified the problem. initiated a PIP and corrective action was in process. The licensee recognized this' oversight and has responded by initiating changes to NSD 308.to incorporate instructions for developing and issuing a formal report to the Station Vice President and PORC members for all incidents reportable pursuant to TS. TS violations, and onsite environmental release The inspectors also reviewed McGuire Safety Review Group Evaluation Report SA-97-45.. Comparison of SLC and NSD 308 PORC Review Requirements that had been performed to outline discrepancies between the SLC and NSD 308. The report accurately identified the deficiencies in the NSD that were incorporated into the PIP program for evaluation and resolutio Nuclear Safety Review Board The. inspectors reviewed TS 6.5.2 and NSD 309, which outline the responsibilities and requirements of the NSRB. The NSRB serves as an independent review board. providing a backup review to the normal station organization reporting to the Executive Vice President. Nuclea The NSRB monitors and evaluates trend information provided by the McGuire safety review group (SRG) and proposes. recommendations when warranted. The NSRB also provided independent review and audit of designated licensee activities to identify items needing increased management attentio The inspectors reviewed NSRB meeting summaries for the 1997 calendar year and first' quarter 1998. Based on the review, the inspectors noted that NSRB focused on technical issues consistent with inspection and third party findings. The NSRB utilized inputs from regulatory agencies and various industry sources to assess plant safety performance. The NSRB made observations and recommendations regarding plant specific and generic. issues requiring increased management attentio Conclusions L The inspectors concluded, based on reviews of licensee documents and L discussions with PORC members and NSRB staff, that the onsite and offsite review committees have been effective in identify and resolving ;
safety issues at McGuire Nuclear Station. The NSRB operated in accordance with McGuire TS 6. The McGuire PORC provided good onsite l
i i
_ _ - . - - _ _ . - _ - . _ . _ _ _ _ . _ _ . _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
reviews of station activities. However. reports to the plant review l committee identifying reportable incidents and TS violations containing i
proposed corrective actions were not formalized in accordance with selected license commitments. This lack of procedure was identified by the licensee's corrective action processes and new details were being incorporated into procedure .4 Manaaement Involvement in Corrective Action Process Inspection Scone (40500)
l The inspectors reviewed the process and internal controls for implementation of the corrective action progra Observations and Findinas Through reviews of documentation and interviews with station personne I the inspectors determined that station management responded positively to general office auditors in making improvements to the corrective action process. Management created process tools to track corrective action timeliness and quality. Although these management review processes were not proceduralized, they provide a real-time, highly responsive methodology to the process. Site management initiated two management review panels, the Ten Oldest Open Ones Meetings (T000M) and the Corrective Action Review Board (CARB). to oversee the process. The inspectors attended a weekly.T000M panel during the inspection, reviewed the output of both meetings, and reviewed their charter The mission statement of T000M was to ensure timeliness of corrective actions while maintaining safe and reliable operation. The charter objectives were to focus on keeping MSE PIP age less than six months old and LSE PIPS age less than eighteen months old. During the meeting. the site managers discussed the oldest item in their area and this was i adequately reviewed by the site manager ;
The CARB charter objectives were to review completed root cause analysis, to understand the causal factors contributing to selected PIP initiating events, and to review the solutions being proposed to prevent or mitigate the recurrence. The CARB and the T000M meet weekly. The managers sponsoring a particular root cause and their root cause evaluators would present the root causes at the CARB. As a part of the review, the CARB would provide feedback and additional directio The T000M and CARB meetings are well-attended meetings with an agenda established by the SRG. The SRG tracked the output of the meetings and provided a reference and technical source for the meetings. The T000M meeting attended by the inspectors was chaired by the Station Vice ;
President and staffed by the major site managers, which included the '
Plant Manage The T000M reviewed the oldest open items and questioned the reason for exceeding established goals. As of April 1. 1998, there
___ ____-___
__ _ -______ - _ _
,
were 30 MSE PIPS older than six months and 20 LSE PIPS older than 18 month .The licensee has a scorecard on the site's corrective action MSE PIP program that presented the status of the program. This is a part of a proactive Duke corporate management initiative to evaluate and track the corrective action 3rograms at each of the three nuclear facilitie This snapshot of-tie program was published monthly in the Performance Measures Status Report at all Duke sites and was based on how well MSE PIPS were being addressed. The snapshot was based on the average evaluation scores in seven areas. The numbers were derived from the site PIP coordinators scoring of each site's MSE PIPS. In areas scored, the McGuire lowest ratings were in root cause analysis quality and timeliness. Appropriate corrective action received the highest scor Conclusion The licensee's efforts to manage the corrective action program using site specific tools appeared to be effectiv .5 Canceled Problem Reoorts Inspection scooe (40500)
In 1997, the licensee canceled 125 problem reports. The inspectors sampled the canceled reports to decide if there were valid reasons for canceling the reports examined. During the conduct of the review, the -
inspectors sooke with site personnel involved with the PIPS and evaluated other licensee document Observations and Findinos i The inspectors examined 10 canceled problem re] orts generally finding no unacceptable reasons for the cancellations. T1e support information regarding;the cancellation was mainly found in the PIP data bas Eight duplicate PIPS were canceled. Several were voided due to error or misunderstanding. The inspectors successfully tracked the duplicates to a completed corrective action or a specific action. In one instance, an i issue on accessibility to the power operated relief valves had a long l l 3roblem report history (PIPS 97-2468. 97-1892. and 97-15). The canceled I
'
3IP occurred after final resolution had been achieved. This issue had been reviewed over several years and the issue had a licensee defining i study done (PIP 97-15). The final actions blended cost and need. The l inspectors determined that the operations management (Nuclear Operations
'
Shift Manager) involved were satisfied with the existing corrective !
-action and those actions met regulatory guidanc One issue, regarding ma'in feedwater isolation valves, had a history of problem reports. two of which had been canceled (97-273 and 96-3415).
On November 27, 1996, valve ICF-26AB had a mechanical problem that required work. The valve was worked at a reduced reactor power level of <
e
_ _ _ - _ - _ - - _ _
_ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ _ _ _ ._ ._-
.
28 percen The valve was controlled under the auspice of TS 3.3.2. which has a six hour Limiting Condition for Operation for the feedwater isolation valve s) edification. During the work the valve was left open longer than four 1our The following PIPS had been written on the subject:
Number Date TS 3.6.3 Position 96-3409 11/27/96 Valve exempted 96-3415 11/28/96 Voided due to PIP 96-3409 96-3588 12/17/96 Valve exempted 97-273 1/23/97 Voided due to PIP 96-3588:
treat valve as TS valve 97-1069 3/15/97 Valve under TS: issue LER 369/97-1 and Revision 1 Per PIP 96-3409 (Section 9). the licensee had changed a TS interpretation for TS Sections 3.6.1.1. and 3.6.1.2, and 3.6.3 in June 3, 1996. -The CF-26AB valve was exempted from TS 3.6.3 to establish containment integrity by having closure ca) ability as it is listed in UFSAR Table ~ 6-112 and is identified as Lea c Class 1 and Leak Reference B (as shown on the pages 9 and 14 of Table 6-112), The Technical L Specification 3.6.3. which is the containment isolation TS section, has four hour limits for its applicable valve When the valve failed in November 1996, a licensee dialogue was initiated regarding the applicability of TS 3.6.3. .This discussion continued through the above listed PIPS until May 19, 1997, when the licensee issued Revision 1 of LER 369/97-01. Failure to Comply with Technical Specification 3.6.3 Following Valve ICF-26AB Inoperabilit The LER text discussed the fact the licenset had made an incorrect interpretation at the time of the valve failure and was reporting the noncompliance and concluded that the event did not result in any
,
'
uncontrolled releases, personal injuries, or radiation overexposur Misinterpretation of reference documents caused the failure to comply with requirements of TS in a timely manner regarding applicability of TS 3.6.3 to this valve. The inspectors determined that the corrective actions of the LER have been accomplished.
L The licensee was not timely in arriving at the above corrective actio .The requirements of 10 CFR 50 Appendix B. Criterion XVI. Corrective Action, apply in that measures shall be established to assure that conditions adverse to quality. such as failures, defective material and equipment, and noncompliance are promptly identified and corrected. In this case, the licensee took longer than four months to arrive at a
-_
___ _____ _ _ _ _ _ - _ - _ _ _ _ - - _ _ _ _ _ _____
_- ____-_ _ _ - - - _ _ - - . _ _ - _ _ _ -
. .
correct decision. The above events are considered non-repetitive, licensee identified and corrected violation that is identified as a non- j cited' violation (NCV) consistent with Section VII.B.1 of the NRC Enforcement Policy. This is identified as NCV 50-369/98-04-03. Failure to Complete Timely Corrective Action. This LER and its revision are '
. close j i
- Conclusions J Most of the canceled problem reports reviewed by the inspectors were appropriately dispositioned. One of the problem ieports was voided in a long series of reports on the same issue. The issue described a problem that was not resolved in a timely manner, and resulted in a non-cited '
violatio .6 Assessment and Trendina of Miscositionino Even_tji I Insoection Scope (40500)
The inspectors reviewed the licensee's assessment and trending of mispositioning occurrence Observations and Findinas The licensee is re]orting. tracking and trending mislositioning occurrences. For Juke nuclear facilities in 1997, t1e data were as follows!
McGuire Non-consequential occurrences 89 Consequential Events 1 Catawba Non-consequential occurrences 46 Consequential Events 2 Oconee Non-consequential occurrences 85 !
Consequential Events 5 j
,
The inspectors reviewed the licensee Assessment Report of Mispositioned i Components (SA-98-02 (MC)(SRG)) dated February 25, 199 In this report !
the licensee reviewed and analyzed dispositions due to o]erations, chemistry. and maintenance for the period of 1996 througi October 199 A total of 133 disposition PIP reports at the MSE and LSE levels were !
reviewed during the assessment. .Causes were known for 43 occurrence <Causes for the remaining 90 were unknown. Of the MSE reports, there were no consequential events reported in 1996 and only one consequential event in 1997. However, the LSEs had increased by 25 percent from 1996 to 1997.. This was attributed to 170 days in refueling outages (more opportunities for component manipulations or inadvertent contact with components) and a lower threshold of reporting l f
!
i w___ . -_-
l l . .
> ,
{
13 1 Of the 43 mispositionings with known causes. 31 were assigned to the the ;
area of operations. Causes contributing to operations' mispositionin which heavily involved procedural inadequacies.s. were:
l
-
Procedure did not return a component to the desired position:
-
Incorrect component position specified by procedure:
-
Vague procedure steps: an !
-
Failure of personnel to effectively utilize program barriers ;
designed to prevent error Examples of barriers to dispositions were adminisvative tools such as self-checking. Stop-Think-Act-Review. and Qualify-Validate-and- ,
Verification of information and procedure )
i From the analysis, a number of corrective action recommendations were j made that management had a) proved for implementation. These actions '
were in progress and were 3eing tracked in the PIP progra l Conclusions
The inspectors considered that the analysis of the mispositioning available. data was thorough. Recommendations based on the analysis were (
,
appropriate and were ap3 roved for implementation by managemen Corrective actions whic1 were in progress were being tracked in the PIP program. However. the licensee's attempt to analyze the mispositioning occurrences was hampered by the large number of occurrences for which the causes were undetermined. The inspectors considered the lack of determination a weaknes Miscellaneous Operations Issues (92712. 92902)
0 (Closed) Unresolved Item (URI) 50-370/97-18-01: Mispositioned Containment Isolation Valve During Unit 2 Refueling Operations On December 2.1997, the outboard containment isolation valve 2NC-56B for the pressuri.>er relief tank s open during refueling operations. pray line, penetration Immediate M-21 corrective actions bywas the found operator were a)propriate. The valve was closed and operators were dispatched to t1e Unit 2 containment to verify that the inboard isolation valves were closed. No breach of containment had occurre This issue was made an URI pending the licensee's investigation of the root caus The licensee investigated the mispositioning and documented the results in PIP 2-M97-4517. From the operators aid computer it could be determined that valve 2NC-56B was documented closed in the containment
_ _ _ _ _ _ _ _ _ - _ - _ _ .
- _ _ - _ _ _ .__ __ ._ _ _ . _ _ _ __ _. _ _ _ _ _ _ _ _ _ _
. .
penetration status sheet et 2:45 a.m. on November 29. 1997. The computer data indicated that the valve was re-opened at 10:11 p.m. on November 29, 1997. The three operators on duty in the control room indicated that they could not recall manipulating 2NC-56B from the control board. A review of maintenance history showed that no maintenance had been performed that could have caused the valve to o]e An engineering evaluation reviewed several scenarios and concluded t1ey were improbable. However, a work order was written to examine the limit switch. The most probable cause of the mispositioning was that an operator inadvertently pushed or bumped the open switch long enough to allow the valve seal-in circuit to activate and stroke the valve full ope The inspectors determined that the open containment isolation valve 2NC-56B was contrary to the procedural requirements of PT/2/A/4200/002C for penetration status during refueling operations. This non-repetitive licensee identified and corrected violation is identified as an NCV consistent with Section VII.B.1 of the NRC Enforcement Policy: NCV 50-370/98-04-04: Containment Isolation Valve 2NC-56B Not Aligned According to Containment Integrity Penetration Status Shee The inspectors conclusions are summarized as follows:
o For the mispositioned containment isolation valve occurrence, immediate corrective actions were appropriate:
.
The licensee had not determined the reason for the valve disposition; an .
The open containment isolation valve was contrary to procedural ;
requirements of a surveillance that was identified as an NC '
08.2 (Closed) URI 50-369.370/98-02-01 Followup on Licensee's Previous Industry Experience Review Regarding Multiple Rod Drop Events The inspectors requested the licensee's 03erating experience review group to make a word search of their data'ase > covering the time period of January 1.1994, to April 22. 199 They made a search on the words
" rod drop." ~ dropped rod." " rods dropped.~ and ~ rods falling." The initial search ge"erated a list of 80 items. This list was reviewed by the licensee and tne NRC inspectors to select only those items that may relate to the URI. This refined search produced a list of 17 item Each of the 17 items had come from the nuclear network, which was generated from information supplied by the NRC about deily events or i Institute of Nuclear Power Operations notifications. The inspectors reviewed the full text of these communications. The earliest item was l' dated April 1995, and three of the items were about the McGuire rod drop i event in February 1998. Several of the events on the list were similar to the McGuire event in that multiple rods dropped and the operator responded by manually tripping the reactor. Several event descriptions l
f
_ - _ _ _ _ _ _
___ __
. .
indicated that the particular plant had instructions in the operating procedures to manually trip the reactor in the event of multiple rod drops. None of the event descriptions indicated that there was any actual requirement to.immediately manually trip the reactor upon multiple rod drops. Therefore, this item is close II. Maintenance M2 Maintenance and Material Condition of Facilities and Equipment M2.1' Material Condition of Facility Inspection Scooe (40500)
The inspectors assessed material condition of the facility to gain insights as to the effectiveness of the licensee's corrective action program in identifying and correcting problems. This assessment was accomplished through walkdowns of various plant areas and by reviews of the operator workaround list and Major Equipment Problem Resolution (MEPR) lis Observations and Findinas The inspectors conducted walkdowns of selected areas of the turbine building and the reactor building. The walkdowns were 3erformed to determine if the licensee was identifying equipment pro)lems and corrective actions to resolve the problems once they were identifie During the walkdowns, the inspectors identified only four deficiency tags that were greater than six mcnths old. For each of the deficiency tags identified, the inspectors verified that work request had been written to correct the problems. During the review of the work reques the inspectors determined that, for two of the deficiencies identified, the corrective actions had been completed. The inspectors informed the
. licensee that the work request indicated that the corrective actions had been complete The licensee promptly reviewed the work retues verified that the corrective actions had been completed _ anc removed the two deficiency tag Overall, the inspectors noted a low number of deficiency tags less than six months old. This was an indication that the licensee was aggressively identifying and correcting deficiencies once they were identified. The effort made by the licensee to keep the plant equipment properly operating was also evident by the excellent material condition of the plant and the relatively low number of open work item Conclusion L The inspectors concluded that the licensee has been aggressive in
!
identifying equiomen' problems. Once the licensee identified equipment
.
!
!
_ _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _______ ___-_____ _ -__ _ ______ _ _ _
'
,
i 16 l l deficiencies, that corrective actions were identified to resolve the deficiencie M Alternate AC Source Testino l Insoection Scoce !
l The inspector reviewed PIP 96-1493. that identified concerns associated i with testing of the SSF diesel generator. The PIP was initiated by a l licensee-sponsored standby shutdown facility (SSF) self-assessment tea The concerns were raised following a licensee review of industry events associated with a blackout evaluation at Maine Yankee Station. The inspectors reviewed documentation and interviewed licensee personnel i concerning the response to the questions raised by the self-assessment i tea ,
I Q. observations and findinas
'
The PIP raised the specific concerns that no dynamic testing had been performed on the SSF diesel generator (D/G) and no periodic testing was performed to demonstrate SSF D/G loading as it would be used during an emergency. In response to questions raised in the PIP, the licensee concluded that because the D/G was manually loaded during the Performance of procedure OP/0/A/6350/04. Standby Shutdown Facility l
)iesel C,2 ration, and it is only loaded to 72 percent capacity. that no dynamic testing was required. The licensee also concluded that the testing perforced by the manufacturer was sufficient to demonstrate
,
'
dynamic load capability of the SSF D/G. The licensee also concluded :
that, based on the monthly testing and tests conducted by the !
manufacturer, additional periodic testing of the SSF D/G during refueling outages was not necessar The inspectors questioned the licensee's methodology inquiring as to why the. licensee does not adhere to guidance provided by NUMARC 87-0 Revision 1, B.li NUMARC 87-00. B.10 stated, in part, that ~0nce every refueling outage, a timed start (within the time period specified under blackout conditions) and rated load capacity test shall be performed." l
'
During interviews with licensee personnel, the inspectors were informed that based on the 3erformance of monthly surveillance PT/0/A/4200/00 Revision 19. Standay Shutdown Facility Operability Test, that no additional testing was required, and the requirement of NUMARC 87-00 was satisfie required fo.r the At the SSFconclusion of clea D/G was not the inspection the actualNRC Pending additional testing revie ,
l the issues associated with the testing of the SSF D/G will be tracked as IFl 50-369.370/98-04-05. Alternate AC Source Testing Per NUMARC 87-00.
,
B.1 i t
w __ _ __
_ _ _ _ _ _ _ _ _ _ _
-
.
17 Conclusio_q The inspectors were unable to determine if adequate testing of the SSF D/G was being Jerformed. Specifically, testing according to NUMARC 87-10. 8.10. whic1 required the SSF 0/G be tested once every refueling outage by perfo. ming a timed start and rated load capacity test. This issue was left as an IFI item pending further NRC review of the licensee's basis for their testing proces III. Enoineerina El Conduct of Engineering E2 Enaineerina Support of Facilities and Eauipment E2.1 Top Eauioment Problem Resolution Process The Top Equipment Problem Resolution Process was evaluated within the 3revious six-months and documented in McGuire Inspection Report 98-0 Juring the current inspection, the inspectors performed limited reviews to confirm the previously documented findings. As a result of the reviews the inspectors concluded that the licensee has effectively managed safety and non-safety related equipment problems that could impact plant reliability and safet E2.2 Review of Operatina Exoerience Proaram Insoection Scope (40500)
The inspectors inspected the licensee's Operating Expericnce Program (DEP) program. The OEP was des'gned to capture information regarding industry events and problems identified outside the site, and evaluate that information. The following specific inspection activities were conducted:
.
Reviewed four recent randomly selected PIPS related to OEP:
.
Reviewed the licensee's response to Generic Letter (GL) 83-2 Item 2.2. Part 2. Vendor Interface for Safety-Related Components:
. Reviewed the licensee's responses to GL 90-03. Relaxation of Staff I Position in GL 83-28. as well as the NRC's reply to the licensee '
commitment: an .
Requested a word search involving " dropped-rod events" be made on the OEP data base to demonstrate the completeness of the data and capability to generate a summary.
l
}
)
-_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
,
-
!
18 Observations and Findinas I
The OEP program was a corporate program, which applied to all three Duke site Review of OEP related PIPS indicated that the OEP 3rogram was evaluating events and potential problems from the other Duce sites and industry-wide. The inspectors found that evaluations were thorough and timel In reviewing the GL resaonses, the inspectors learned that a violation had been issued at anotler Duke site for a problem with the program to evaluate vendor information (letters). As aart of the corrective actions for that violation the program had aeen recently revised. The new 3rogram was defined in NSD 319. Vendor Technical Information Program whici was an improvement over the older. less specific OEP procedure NSD 204. One basic improvement of the new program over the old was consolidation under one corporate level group, which should correct any problems caused by the older fragmented program. The inspectors reviewed NSD-319 finding that it implemented the commitments made with regard to GL 83-28 and GL 90-0 Review of the OEP summary of items generated by the ~ rod drop" word search indicated the data base was complete and good evaluations had been performed for the item c. Conclusions The licensee's DEP was effective in capturing and evaluating available information about industry events and problems from off-site sources including equipment vendor IV. Plant Support R1 Conduct of Radiation Protection and Chemistry R1.1 General Comments (71750)
The inspectors performed tours of the controlled access area and reviewed radiological postings and worker adherence to protective clothing requirements. Locked high radiation doors were properly controlled, high radiation and contamination areas were properly posted, and radiological area survey maps were updated to accurately reflect radiological conditions in the respective area V. Manaaement Heetinas X1 Exit Meeting Summary The resident inspectors ) resented the inspection results to members of licensee management at t7e conclusion of the inspection on April 2 _ _ _ _ _ _ _ _ - _- - __
H
, .
i i 19 1998. The licensee acknowledged the findings presented. No proprietary information uas identifie PARTIAL LIST OF PERSONS CONTACTED Licensee Barron, H.. Vice President. McGuire Nuclear. Station Bhatnagar, A. . Superintendent. Plant Operations Boyle, J., Civil / Electrical / Nuclear Systems Engineering Byrum. W., Manager. Radiation Protection Cash. M... Manager, Regulatory Compliance Dolan, B. , Manager Safety Assurance Evans _ W. . Security Manager .
Geddie. F., Manager, McGuire Nuclear Station Loucks u.. Chemistry Manager Peele, J., Manager. Engineering Thomas, K..' Superintendent, Work Control
.Travis, B. , Manager, Mechanical Systems and Equipment Engineering INSPECTION PROCEDURES USED IP 71707: Conduct of Operations
'IP 40500: Effectiveness of Licensee Controls in Identifying Resolving, and
, Preventing Problems IP 92902: Maintenance - Followup IP 90712: Licensee Event Report Review ITEMS OPENED AND CLOSED OPENED 50-369,370/98-04-01 VIO Failure to Follow Procedure for Time to Initiate a PIP (Section 07.1)
50-369.370/98-04-02 URI GDC 57 Implementation and UFSAR Actions on Valves SA-1 and SA-2 (Section 07.2)
50-369,370/98-04-03 NCV Failure to Complete Timely Corrective Action (Section 07.5)
50-370/98-04-04 NCV Containment Isolation Valve 2NC-56B Not Aligned According to Containment Integrity Penetration Status Sheet (Section 08.1)
50-369,370/98-04-05 IFI Alternate AC Source Testing Per NUMARC 87-00.
L B.10 (Section M7.1)
L L
l
_ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ _ _ - ______ -
.. .
!'
l l
CLOSED 50-370/97-18-01 URI Mispositioned Containment Isolation Valve During Refueling Operations (Section 08.1)
50-369,370/98-02-03 URI Followup on Licensee's Previous Industry Experience Review Regarding Multiple Rod Drop Events (Section 08.2)
50-369/97-01 LER Rev. O and Rev.1 (Section 07.5)
50-369.370/98-04-03 NCV Failure to Complete Timely Corrective Action (Section 07.5)
.50-370/98-04-04 NCV Containment Isolation Valve 2NC-56B Not Aligned According to Containment Integrity Penetration Status Sheet (Section 08.1)
LIST OF ACRONYMS USED CA Auxiliary Feedwater CARB Corrective Action Review Board CFR Code of Federal Regulations D/G Diesel Generator ESF Engineered Safety Feature GDC General Design Criteria GL Generic Letter [NRC]
Hi High IFI Inspector Followup Item IR Inspection Report LER Licensee Event Report LSE Less Significant Event MEPR Major Equipment Problem Resolution MSE More Significant Event NC Reactor Coolant System i
NCV Non-Cited Violation 5 NRC Nuclear Regulatory Commission NRR NRC Office of Nuclear Reactor Regulation NSD Nuclear Site Directive NSRB Nuclear Safety Review Board NPF Nuclear Power Facility OEP Operational Experience Program PDR Public Document Room PIP Problem Investigation Process {
PORC Plant Operations Review Committee psig -pound per square inch gage SLC Selected License Commitment
.SRG Safety Review Group i SSF Safe Shutdown Facility
_ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . _ _ . _ _ _ _ . . _ . _ . . _ _ . . . _ _ _ _ _ _ . _ . . _ .
-_ _
. _ _ _ - _ - _ - _ _ _ _ . _ _ _ _ _ __ - ____ _ ___ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
T000W Ten Oldest Open Ones Meeting TS Technical Specifications UFSAR Updated Final Safety Analysis
.URI' Unresolved Item VIO Violation WAPR Workaround Problem Resolution
.
i i'