ML19332E606

Notice of Violation from Insp on 890722-0912.Violations Noted:Annulus Ventilation Sys & Control Area Ventilation Sys Inoperable Since Initial Licensing

ML19332E606
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/15/1989
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19332E605	List: ML19332E606
References
50-369-89-24-01, 50-369-89-24-1, 50-370-89-24, NUDOCS 8912080006
Download: ML19332E606 (41)

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ENCLOSURE 1 NOTICE OF VIOLATICN Duke Power' Company-Docket Nos.:

50-369, 50-370 McGuire Units 1 and 2 License Nos.:

NPF-9, NPF-17 During the Nuclear Regulatory Commission (NRC) inspection conducted on July 22, 1989 through-September-12, 1989, a violation of NRC requirements was i

identified. Inlaccordance with the " General Statement of Policy and Procedures l

3' '-

,for.NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1989), the violation is-set forth below:

10 CFR: 50,. Appendix B, Criterion III, Design Control, requires in part

.that1 measures be established to assure that applicable regulatory

- requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.

It is further required that these measures provide for verifying 1the' adequacy of design, such as by the performance of design reviews, by the use of calculational methods,- or the performance of a testing program.

Contrary to the above, design control measures were inadequate in that:

1.--

In. August 1989, it was found that the Annulus Ventilation Systems on Jboth units. had been inoperable since initial licensing.

It was found that ' the Annulus Ventilation Systems were unable to produce and meintain their negative pressure requirements throughout the annulus under all possible outside air temperatures following a loss of coolant accident.

2.

In August 1989, it was found that the Control Area Ventilation System had been inoperable since initial licensing.

It was found that the l

' Control Area Ventilation System had not tnet pressurization require-ments of maintaining at least 1/8-inch water gauge positive pressure in the. control room relative.to outside atmosphere.

i This is a Severity Level IV Violation (Supplement I).

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. Pursuant ; to L the-provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory 1

Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to-

'the: Regional Administrator, Region II, and a copy to the NRC Resident Inspector within thirty (30) days of the date of the letter transmitting this Notice.

JThis reply should be clearly marked as a " Reply to a Notice of Violation" and i

should include for each violation: (1) admission or denial of the violation, (2):the reason for. the violation if admitted, (3) the corrective steps which 8912080006 891115 PDR ADOCK 05000369 g

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' Duke Power Company 2'

Docket Nos.:

50-369,L50-370 r

McGuire Units 1 and 2-License Nos.:

NPF-9, NPF-17 g

iv krc have been: taken and' the results achieved, (4) the corrective steps which will K'-

' be taken-to avoid -further violations, and (5) the date when full compliance I

will.be' achieved. Where good cause -is shown,. consideration will be given to extending the response time.

If an adequate reply is not received within the time specified in this Notice,' an order may be issued to show cause why the-

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license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION t

Stewart D. Ebneter-Regional Administrator Dated at Atlanta, Georgia

- this 15th day of November 1989 u.

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R ENCLOSURE 2 ENFORCEMENT CONFERENCE

SUMMARY

On October 20, 1989, representatives from Duke Power Company (DPC) met with the-

-NRCLin the _ Region II office in Atlanta, Georgia to discuss problems with the.

Control Room and Annulus Ventilation Systems. The issues with the control room I

centered around an incorrect pressurization reference point and compensatory actions currently implemented to assure its adequate. pressurization.

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. issues with the annulus centered around the licensee evaluations following the

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issuance'of IEN-88-76. The pressure control system did not consider tempera-ture effects on annulus pressure. Several other problems which were identified L

were also discussed.

- Following opening remarks by A1l Gibson, Region II, Acting Deputy Regional Administrator, DPC gave a presentation (Enclosures 4 and 5) on the various

issues, s

The' DPC-presentation dealt with several areas.

The first explained the relationship between the original design process of the ventilation systems and the evolution of : nuclear Heating Ventilation and Air Conditioning (HVAC)

- industryfguidance.

This process was also applied to the McGuire design.

~ The' presentation then addressed the Control Room Ver.tilation System and the problems encountered in having the pressure control system reference the wrong location.

The licensee's corrective actions and compensatory actions were explained. The safety significance of the wrong reference point was explained, and it was concluded that. the actual dose to control room personnel would be well below 10 CFR 100 limits.

The design-and operation of the Annulus Ventilation System was then explained.

Other problems - that have been identified were discussed in chronological order. The safety significance was discussed and it was concluded that the problems identified with the system following a design bases accident would have been within the-10 CFR 100 limits.

c The presentation was concluded with a explanation of why it took so long to get IEN-88-76 evaluated.

The NRC closed the meeting by stating that DPC's presentations had served to

enhance Region II's understanding of the issues and their corrective actions.

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. T-L ENCLOSURE 3 LIST OF ATTENDEES V

U.S.-Nuclear Regulatory Commission I

A. Gibson, Acting-Deputy Regional-Administrator E. Merschoff,-Deputy--Director, Division of Reactor Safety (DRS)

'M.~ Shymlock. Section Chief, Division of Reactor Projects (DRP)

L T. Decker, Section Chief, Division of Reactor Safety and Safeguards (DRSS)

D.{ Hood, Project-Manager, Nuclear Reactor Regulation (NRR)

P.'K. VanDoorn, Senior Resident Inspector, McGuire, DRP-p B. Orders, Senior Resident Inspector, Catawba, DRP I

B. Uryc, Senior-Enforcement Coordinator, RII e

S. Adamovitz, Radiation Specialist, DRSS L

Duke Power Company.

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.H. Tucker, Vice President, Nuclear Production Department 1

3

T. McConnell,' Station Manager, McGuire R.- Futrell,. Manager,. Nuclear Safety Assurance D. Murdock, Division Manager,' Design Engineering it R.'Weider, Engineering Superv'sor, Design Engineering 1

- B. Doland,. Engineering Supervisor, Design Engineering P. Herran, Design Engineering i

tP. Sharpe, McGuire, Compliance Manager J. Warren,-Regulatory Compliance l

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ENCLOSURE 4.

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. ENFORCEMENT CONFERENCE DUKE POWER COMPANY MCGUIRE NUCLEAR STATION

' CONTROL ROOM VENTILATION SYSTEM (VC[YC)

AND ANNULUS VENTILATION SYSTEM (VE)

OCTOBER 20,1989 NRC REGION ll - OFFICE - ATLANTA jI

• • " AGENDA *"*

1 ; OPENING REMARKS H. B. TUCKER 1

s 2.. ORIGINAL DESIGN & TEST PROCESS / -

P.-R.HERRAN

/

. INDUSTRY GUIDANCE

3. CONTROL ROOM VENTILATION SYSTEM; P.R.HERRAN i

. PRESSURIZATION REFERENCE POINT

- System Design Basis / Licensing Basis

. - System Description-

- VC Problem investigation Reports

- Root Cause/ Operability / Safety Significance

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& Corrective Actions

- Applicability To Other Duke Plants -

L4L ANNULUS VENTILATION SYSTEM; P.R.HERRAN L,

. PRESSURE CONTROL REFERENCE POINT

- System Design Basis / Licensing Basis

- System' Description

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- VE Problem investigation Reports L

- Root Cause/ Operability / Safety Significance

& Corrective Actions

-- Applicability To Other Duke Plants

- Generic Corrective Actions L

5. ' DUKE POWER'S OPERATING EXPERIENCE PROGRAM R.C.FUTRELL

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SUMMARY

STATEMENT T. L. McCONNELL

7. CLOSING REMARKS H. B. TUCKER

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ORIGINAL DESIGN e

. PROCESS 1

Duke Power Q A P 10CFR50, App. B

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Design

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. Calculations -

Specifications

. Procurement

. Drawings _

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. Assisted in Production Testing if M Programs-1 r pgq y,,,'

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Construction HVAC System Fabrication and Installation

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. Contractor Fabrication and Installation

. Contract Administrated by DED

. Contractor Performed installation L

Testing As Prescribed By DED

. Contractor Assisted in Production I I-p Testing Programs r

Production

HVAC System Operation and Testing t

• Developed Pre-operational, Operational

- and Surveillance Test Procedures

. Performed Pre-operational, Operational L

and Surveillance Testing H

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lEVOLU310N OF NUCLEAR HVAC i

INDUSTRY GUIDANCE u

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(ilndustryl Guidance Was:And is Evolutionary c# Evolved From Non-nuclear: Safety industrial x ! Standards To Nuclear Safety Grade I

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L McGuire Design & Evolution of Nuclear HVAC Industry

' - J',g 7 Guidance

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- SECTION VM,IX (1)

- ASHRAE (1)

SMACNA (1)

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IND. VENT (1) 1.52(2) 1.78(2)

N-510(2) ' N-500 59.2

' 56.6 -

NSIC45 (1)

SECTION N (1),(2) 1.53 (2)

AG-1 Af05-XXX 70 71-73

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1/81 8981

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START VC/YC Unit i VC/YC Commercial

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HVAC VE Systm Operation, Unit 1

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DESIGN VE-System Turned i

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Production Production -

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i (1) HVAC Specification Requirement i

(2) Reg. Guide On Nuclear Industry Std. Fully Or Partially Committed To 4

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EVOLUTION OF NUCLEAR HVAC INDUSTRY GUIDANCE n

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n. Original.HVAC Design - Nuclear Industry guidance available

-General Design Criteriat

.-^10CFR50,: Appendix A, GDC 19 Regulatory-

... Regulatory Guide'1.52 Design Testing and Maintenance Criteria

• for Atmosphere Cleanup System Air Filtration and Adsorption-Units of Light Water Cooled Nuclear Power Plants

. Regulatory Guide-1.53 Application for the Single Failure Criterion

to Nuclear Power P1 ant Protection System.

.' Regulatory Guide-1.78-Assumptions for Evaluating the Habitabil.ity-of. eiNucidar Power Plant Control. Room During

'a. Postulated Hazardous Chemical Release' ASME'

. SectionsIII (1971')- Nuclear Power Plant Components i

.Section VI.II: PressureJVessels; 1

.-Section;IX Welding Qualifications

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.. ANSI: N-509-1976L-Nuclear Power. Plant Air Cleaning Units and Components

. ANSI.N-510-1975. Testing of Nuclear Air Cleaning Systems Commercial'HVAC Standards

. ASHRAE..American Society of Heating,: Refrigeration, and Air Conditioning Engineers

. Industrial Ventilation - By American Conference of Governmental. Industrial Hygienists 1

. SMACNA - Sheet Metal Air Conditioning Contractors National e

Association Other'

.-ORNL/NSIC-65 (US-AEC) Burchsted and Fuller; Design, Construction,'.and1 Testing of High Efficiency Air Filtration

. Systems'for Nuclear Applications

~.PresentLHVACDesign-NuclearIndustryguidanceavailable ASME'AG-1-1985 -' Code on Nuclear Air and Gas Treatment (Pre-op.

-and Surveillance Testing Sections still under development, except for

-.fil ters).

- ANSI /ANS-59.2-1985 - Safety Criteria for HVAC Systems Located Outside Primary Containment ANSI /ANS-56.6-1986 - Pressurized Water Reactor Containment Ventilation Systems.

._ Future HVAC Design _ Nuclear Industry Guidance

. ANSI /ANS-XXX - Control Room Habitability (Under development) 4

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CONTROL ROOM VENTILATION SYSTEM; L PRESSURIZATIONREFERENCEPOINT na t

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wSystem Design Basis / Licensing Basis 3

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Maintain the temperature environment in l

L the> Control Room

. Provide positive pressure in the Control Room, with respect to the outside.

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atmosphere, to prevent post accident 1

unfiltered inleakage

- Provido the Control. Room protection from toxic gas hazards.

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System Description for Control Room Ventilation System j

The Control Room Ventilation System has two redundant trains (A and B), each train i

consisting of a filter package and an air handling unit (AHU).

Each filter t

package includes a pre-heater, demister/prefilter, High Lfficiency Particulate (HEPA) filter, charcoal adsorber, and one 100% capacity Outside Air Pressure Filter Train (OAPFT) fan.

Each AHU includes a filter, water cooling coil and a r

fan.

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Chilled water for the AHU cooling coils is provided by a redundant central chilled water system consisting of two 100% redundant centrifugal chillers and i

two 100% redundant chilled water pumps.

Temperature in the Control Room is maintained by an automatic control system i

which controls the AHU and chiller operation.

Control Room pressurization is maintained utilizing the filter trains.

Outside i

l air is supplied from four independent intakes. The intakes are located in pairs on the Auxiliary Building roof, one pair or set is locatec diametrically opposite Unit l's vent and the other set is located diametrically opposite to Unit 2's vent. The vents are cross connected and the locations are approximately 400 feet apart.

The intakes are provided with isolation dampers s.ad tornado check dampers.

Radiation monitors and chlorine detectors are provided in the intakes to isolate an intake should radiation or chlorine be detected.

Outside air is taken from the intakes and mixed with a portion of return air from the Control Room.

This mixture passes through the OA filter train where any

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particulate is removed. The mixture then is supplied to the return air inlet for the AHU's.

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Chronoloav Of VC Problem investlantion Renorts

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Post Modification Testing Fan And Damper s

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7/89

+ PIR 0-M89-0161 - Check Damper On OA Fan LER 369/89-26 Discharge 7/89

+ PIR 0-M89-0163 - Control Room Pressurization LER 369/89-15 Reference Point

.7/89

+ PIR 0-M89-O'.'71 - Filter Bypass Leak Path LER 369/89-30 Design Basis Document u

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+ PIR 0-M89-0243 -

OA Intake LER N/A Tornado Missile Protection l

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PIR Root Cause/ Operability / Safety Significance /

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PIR O-M89-0163 Control Room Pressurization Reference To Cable LER 369/8915.

' Spread Room, Not Outside Atmosphere Identification

. Post Modification Testing Root Cause

. Design Deficiency - Communication Of Original (Pre Op.)

l Test Acceptance Criteria Operabilllity j

. Current - Operable - Seal C/R Doors And Open All Four OA Intakes

'. Past Inoperable W.R.T. Outside Atmosphere Reference Point Safety Significance i

- No Imphet On'Public Health And Safety l

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- Control Room Pressure Positive With Respect To Most Penetrations (Cable Spreading Room) l

- Control Room Pressure Positive With Respect To The Most Critical l

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- No Credit is Taken in The Design Basis Calculation For Dilution Of The Assumed inleakage

- Had A DBA Occured, Actual Dose (NUREG / CR-4881) To Personnel Would Have Been Well Below 10CFR100 Limits.

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LER 369/8915 j

Corrective Action 9 inspect Tornado Check Dampers (Complete) l

- No Restriction Found.

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l 4 Inspect Control Room AHU's Duct And Dampers For Leakage (Complete)

- No Excessive Lookage Found'

• Inspect Back-Flush Lines To Ensure They Are Closed (Complete)-

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- Line Closed iSeal Control Room Doors Used Infrequently With RTV (Complete)

- Work Completed 1

. Urgent Mod To Install Permanent Outside Atmosphere Reference (12/89)

Point l

. Evaluate'Feasability Of Using Non permeable Sealant For Cable (12/89)

. Penetrations

. Evaluate Upgrading Control Room Doors To Leak Tight integrity (12/89)

. Urgent Mod To Replace OAPFT Check Dampers With Tighter (10/90)

Sealing Check Dampars

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' Removal of the OAPFT fan discharge check damper

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. Post Modification Testing i

Root Cause

. Design Deficiency Operability i

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. Current - Operable - check damper was reinstalled prior t

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. Past - Inoperable - Potential existed for not being able to

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pressurize for a short period of time.

Safety Sionificance

. No impact on public health and safety c

- Had a design basis accident occurred during OAPFTB PMT, OAPFTB cevid have been made available.

- No credit is taken in the design basis calculation for the VA exhaust filters F

- Containment spray removal mechanism is conservatively treated in the design basis calculation

- X/Q dilution ' factor is conservatively treated in the design basis calculation

- Had a DBA occurred, actual dose to (NUREG/CR-4881) Control Room personnel would have been well below 10CFR100 limits Corrective Action-L

, Urgent modification to replace OAPFT check dampers 10/90 I

i-with tighter' sealing check dampers

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PIR 0-M89-0171 - Filter bypass leak paths in OAPFT-B housing / potential unfiltered LER369/89-30 leak path into Control Room i

Identification -

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. Stati6n identified during modification Root Cause i

. Still under review Operability

. Current - operable - Hole was immediately plugged on Train B

. Past - inoperable Safety Significance

. No impact on public health and safety

- No credit is taken in the design basis calculation for dilution of.the assumed inleakage

- No credit is taken in the design basis calculation c

for the VA exhaust filters

- Containment spray removal mechanism is conservatively treated in the design basis calculation

- X/Q dilution factor is conservatively treated in the design basis calculation

- Had a DBA occurred, actual dose (NUREG/CR-4881) to Control Room personnel would have been well below 10CFR100 limits Carrective Action

. Train A was insoected and no problem found Complete P

1 PIR 0-M89-0243 - Are Outside Air intakes protected from tornado generated LER N/A missiles identification

. Design Basis development Root Cause

. N/A Operability

. Current - operable

. Past - operable t

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SUMMARY

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f Yldentified By Existing Duke Power Programs Post Modification Testing i

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. Design Basis: Documentation i

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% SafetySignificance No impact On Public Health And Safety Actual Dose (NUREG/CR-4881) To Control y

L Room Personnel Would Have Been Well Below 10CFR100 Limits 1

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APPLICABILITY TO OTHER DUKE PLANTS CATAWBA NUCLEAR STATION

. The Applicable.VC (Control Room) lasues Have Been Evaluated For Catawba And The System is Operable.

. To Be Addressed At NRC Meeting, Scheduled For i

November,1989 OCONEE NUCLEAR STATION

. Maintain C/R At Positive Pressure s

. Surveillance Test Reference To Aux. Building And To Turbine. Building Test Using Outside Ref. Point l

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- Unit -3 Control Room By 12/89 L

- Unit -1,2 Control Room By 5/90

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i ANNULUS VENTILATION SYSTEM:

L PRESSURE CONTROL REFERENCE POINT

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1 System Design Basis / Licensing Basis

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L Provide Long-term Fission Product Removal Capability By Decay And Filtration Produce And Maintain A Negative Pressure in 4

The Annulus Following A LOCA Minimize Release Of Radioisotope, Following A LOCA By Recirulating A Large Vo!ume Of Annulus Air Relative To The Volume Discharge For Pressure Maintenance d

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9 System Description Annulus Ventilation System

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The Annulus Ventilation System consists of two redundant trains; each train consisting of a fan, moisture eliminator, pre-heater, pre-filter, HEPA filter, carbon adsorber, HEPA af terfilters, ductwork and controls.

The two trains are totally separate except for a cross-connect for fire protection.

The Annulus Ventilation System is activated by Containment high-high pressure si9.w.' (3 psig). Upon actuation, the fans start and the dampers are aligned such that air from the annulus is exhausted through the annnulus ventilation filter trains and then discharged via' the unit vent until the annulus pressure has fallen to -3.5 inches WG. At this point the dampers realign to the recirculation mode such that air is drawn from the annulus through the annulus ventilation filter trains and then discharged back into the annulus.

The recirculation mode is maintained until the annulus pressure increases to -0.5 inches WG.

When the annulus pressure reaches -0.5 inches WG, the system realigns to the exhaust mode and the cycle repeats.

The moisture eliminators are provided to remove entrained water droplets from the air stream prior to being filtered.

The preheaters are provided to limit the relative humidity entering the filter trains to below 70% assuming air entering at.100% relative humidity.

This ensures that the carbon beds stay dry.

The

. preheaters are controlled off the fan start signal and also receive a permissive from a differential pressure switch which ensures adequate air flow through the filter train.

L A cross-connect is installed between the suctions of the two fans.

The cross-connect isolation dampers are opened when the fans start.

The purpose of

. the cross-connect is to' maintain a minimum flow of air through the idle filter l

train to preclude the possibility of a carbon bed fire due to decay heat.

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l Chronology Of VE Prgblem Investigation Reports j

1 Operating Experience Program 9/88 IEN 88-76,

s 6/89

+ PIR 0-M89-0146 -

Harsh Winter LER 369/89-21 Temperature Effect On Annulus D/P Commercial Grade Program x

/

I r

x 7/89

+ PIR 0-M89-0154 VE Pre-Heater Wiring LER 369/89-17 l

l 7/89

+PIR 0-M89-0160 - VE Filter Train LER N/A-Cross Connect 8/89-

+ PlR 0-M89-0219 -

VE LER N/A Transmitter Failure x-Surveillance inspection & Testing 7

x 8/89

+ PlR 0-M89-0207 - VE Duct Subjected To l

LER N/A Standing Water 9/89

+ PIR 0-M89-0245 - VE Pre-Heater Flow LER 369/89-27 Switch 4

t

PIR Root Cause/ Operability / Safety Significance /

Corrective Actions PIR O-M89-0146 - Based On Outside (Winter) Air Temperature The Difference in Air LER 369/89 21 Densities Of The Annulus And Outside Can Affect Tl;e D/P (Pressure Differential) Reading.

Identification l

. Operating Experience Program, (information Notice 88-76) lEN Regarding BWR Secondary Containment. See Sequence of Events.

)

Root Cause L

. Design Deficiency - Not Analyzed Operating Scenarlo I

i Operabilllity l

l

. Current Operable - Changed Transmitter Setpoints

. Past - Inoperable W.R.T. Setpoints, Safety Significance o

l

. No impact On Public Health And Safety i

- No Mechanical Or Electrical Penetrations in The Reactor Building Are Located Above The Elevation Where A Positive Pressure Might Have Occurred.

(D/P Transition Point is Approx. El. 340' Based On -10* F Outside Air l

Lowest Recorded Outside Temperature is -5* F)

- Positive Pressure Would Have Existed Less Than Half The VE Cycle Time.

L L

- No Credit is Taken In The Design Basis Dose Calculation For The Aux.

I Bldg. Exhaust Filters.

l Containment Spray Removal Mechanisms is Conservatively Treated in J

The Design Basis Dose Calculation,

- Had A DBA Occured, Doses Would Have Been Within 10CFR100 Limits.

L Corrective Action

. Refer To Generic Corrective Action a

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PIR 0-M89-0146 SEQUENCE OF EVENTS i

9/88 Information Notice 88-76 lasued By NRC.

2/89 Design Engineering Received Information 1

Notice 88-76 And Benan Evaluation.

5/89 Design Engineering Evaluated As Not l

Significant.

- Confirmation Testing Proposed.

i 7/6/89 PIR 0-M89-0146 Generated For Analytical 1

Evaluation Based On Data Taken.

t 8/24/89 Design Engineering Completed Ventilation l

System Analysis.

i

- Declared Inoperable.

- Entered T/S 3.03 Based On Expected Temperatures At That Time.

-- Discretionary Enforcement Was Granted By NRC.

- Pressure Transmitter Setpoint Change Required.

8/25!89 Design Engineering Completed Dose Analysis. Pressure Transmitter Setpoints Changed By MEVNs.

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I' PIR Root Cause/ Operability / Safety Significance / Corrective Action 4

I PIR 0-M89-0154 - Annulus Ventilation System pre-heater wiring not qualified for LER 369/89-17 environment Identification i

. Commercial Grade Program Root Cause

. Manufacturing Deficiency Operability

. Current - opcrable - compensatory action is to keep both i

filter trains operating. Do not restart failed train

. Past - inoperable due to potential for losing humidity control and not being in accordance with Tech. Specs.

Safety Significance

. No impact on public health and safety

- Continuous VE heater operation would have precluded r

formation of condensation on the heater wiring

- No credit is taken in the design basis calculation for the Auxiliary Building exhaust filters

- Containment spray removal mechanism is conservatively treated in the design basis calculation

- Had a DBA occurred, doses would have been within 10CFR100 limits Corrective Action

. Replace non-qualified VE pre-heater wiring with qualified wiring.

(1E0C-7 and 2EOC-6)

PIR 0-M89-0160 - Air flowing through cross connect with ne humidity contvol; not LER N/A accounted for in dose analysis Identification

. Resulting from evaluation of PIR 0-M89-0154 Root Cause

. N/A Operability i

. Current - operable

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. Past - operable R

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PIR 0-M89-0219 - Potential VE pressure. transmitter failure could place VE system i

LER N/A in-continuous exhaust mode i

Identification

. Resulting from ev'aluation of PIR 0-M89-0160

[

Root Cause.

. N/A t

Operability i

.. Current - operable l

. Past - operable t

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PIR 2-M89-0207 - ' Standing Water in Annulus - Effects on '.'E duct LER N/A i

Identification

. Annulus [ inspection Root Cause-N/A Operability

. Current - operable

. Past - operable PIR 0-M89-0245 - VE pre-heater flow switch not energizing heater LER 369/89-27

' Identification

. Surveillance testing

• Root Cause

. Inappropriate action, management deficiency, and design deficiency Operability

. Current - operable - Jumper out differential pressure switches

^

. Past - Inoperable due to potential for not having humidity control Safety Significance

. No impact on public health and safety

- No credit is taken in the design basis calculation for the Auxiliary Building ~ exhaust filters Containment spray removal mechanism is conservatively treated in the design basis calculation

- Had a DBA occurred, doses would have been within 10CFR100 limits Corrective Action

. Determine permanent fix for pre-heater flow sv. itch 12/89 s

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SUMMARY

I

% t Identified By Existing Duke Power Programs 6

Operating Experience Program i

s Commercial Grade Program

- ' Surveillance Inspection and Testing o

Lo Safety. Significance

- No impact On Public Health And Safety

- Doses Would Have Been Within L'

10CFR100 Limits j

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4' APPLICABILITY TO OTHER DUKE PLANTS

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CATAWBA NUCLEAR STATION i

. The Applicable VE (Annulus Ventilation System) lasues Have Been Evaluated For Catawba.

To Be Addressed At NRC Meeting, Scheduled For November,1989 OCONEE NUCLEAR STATION Oconee Does Not Have An Annulus

. None Of Identified VE Problems Are Applicable To Oconee L-i

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" " GENERIC CORRECTIVE ACTIONS

)

IIEM SCHEDULE i

i

. Post modifications Testing Program implemented (including Periodic Workshops) m 1

. Self initiated Technical Audit (SITA) / VC/YC 11/89 -1/90 i

. Design Basis Document (DBD) 5

. VC/YC DBD lesued 10/89 i

- VE DBD.

6/90

- DBD is Planned For The Following Ventilation

'91

'95

. Systems:

VX - Containment Air Return And Hydrogen Skimmer System VD - Diesel Building Ventilation System VA - Auxiliary Building Ventilation System i

VF - Fuel Pool Building Ventilation System -

l

VH - Tech. Support Facility Ventilation System L

.VI-Lower Containment Ventilation System VP-Reactor Building Purge System i

VU - Upper Containment Ventilation System i

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GENERIC CORRECTIVE ACTIONS y

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i SCHEDULE iTH 4 Review Of All Safety Related Ventilation j

i:> System D/P TransmittersThat Indicate or

Control Building Pressurization.

I Ii 12/89

- MCGUIRE 12/89

- CATAWBA 12/89 1

.- OCONEE i

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. ENCLOSURE 5 e; % Ja

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ISSUE:

UNTIELY PROCESSING OF OPERATING EXPERIENCE, P

SPECIFICALLY IEN 88-76 l

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OPERATING EXPERIENCE l

PROGRAM (OEP) ELEMENTS e

i RECEIPT SCREENING EVALUATION CORRECTIVE ACTION ESCALATION l

IMPLEMENTATION L

TRACKING L

EFFECTIVENESS i

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9 INVOLVED A 11/10/87 LER DESCRIBING THE DISCOVERY OF A PHEN 0ENON NOT PREVIOUSLY CONSIDERED IN THE DESIGN OF THE SECONDARY CONTAINENT PRESSURE CONTROL SYSTEM AT NINE NILE POINT UNIT 2 (BWR) lI O

NOTICE ISSUED 9/19/88 l

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SEQUENCE OF EVENTS:

IEN 88-76 J

q DAvs LAPSED I

9/19/88 NOTICE ISSUED BY NRC

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10 l

o 9/29/88 NOTICE RECEIVED BY G.O. REGULATORY l

COMPLIANCE AND FILED l

118 1/25/89-SUPERVISION MET TO DISCUSS RECEIPT AND PROCESSING 0F'IENs.

IDENTIFIED IEN 88-76 HAD NOT BEEN ENTERED INTO DEP 6

1/31/89 NOTICE RECEIVED BY ONSA 22 2/22/89 NOTICE SENT TO DESIGN ENGINEERING DEPARTMENT-(McGUIRE AND CATAWBA DIVISIONS)

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DAYS l LAPSED' A

I 5/18/89 EETING HELD TO DISCUSS RESULTS- 0F EVALUATION. -CONFIRMATION TESTING e

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'7/6/89-PIR 0-M89-0146. ISSUED BY. DESIGN ENGINEERING DEPARTMENT TO INITIATE eY

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OPERABILITY EVALilATION BASED ON 6/23/89 T 'P

. TEST DATA.

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!8/24-25/89-

. ANALYSIS AND OPERABILITY EVAMIATION COMPLETED-BY DESIGN' ENGINEERING, VE SYSTEM DECLAREDLINOPERABLE, PRESSURE-f TRANSMITTER SETPOINTS CHANGED, DECLARED Le, s

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OPERABLE.

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IEN 88-76 i

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FAILURE OF THE CLERK TO PROPERLY FORWARD THE NOTICE TO THE OEP COORDINATORS FOR PROCESSING.

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CORRECTIVE ACTIONS L

.9 MANAGEENT HAS EMPHASIZED TO CLERICAL PERSONNEL THE

~IMPORTANCE OF THEIR RESPONSIBILITY TO PROPERLY RECEIVE AND-PROCESS IENs AND OTHER DEP ITEMS.

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COMPLETED AUDIT 0F 1988 AND 1989 ISSUED-IENs AND THOSE PROCESSED THROUGH THE OEP ON 9/26/89.

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- FORMALIZED THE PERIODIC CHECK TO ENSURE PROPER RECEIPT OF IENs AND 0THER. SELECTED DEP ITEMS (E.G.,'SOERs, SERs,-VILs,

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ETC.), EFFECTIVE.10/2/89..

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