ML19332E746

Responds to NRC 891103 Ltr Re Violations Noted in Insp Repts 50-413/89-29 & 50-414/89-29.Corrective Actions:Control Room Penetrations Inspected & Changes Will Be Made to Performance Surveillance Test Procedure

ML19332E746
Person / Time
Site:	Catawba
Issue date:	11/30/1989
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912120065
Download: ML19332E746 (4)

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November 30, 1989-i' s N. S. Nuclear Regulatory Commission f

( . Attn:l-Document Control Desk Washington, D. C. 20555' )

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Subject:

Catawba huclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 .

( NRC Inspection Report Nos. 50-413 & 50-414/89-29 Reply to a Notice of Violation

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Request for Extending Response Time i e 1

- Gentlemen:

-U - Region II Branch Chief Alan R. Ilerdt's letter of November 3, 1989 transmitted a Notice of Violation which identified three Level IV violations at Catawba 4 Nuclear Station. These violations involved inadequate post maintenance r f testing associated with an electrical circuit breakers inadequate design  :

control measures associated with the Annulus Ventilation System; and inadnquate peribdic testing of the Control Room Ventilation System.

'As discussed-in Attachment 1. I admit that a violation occurred with respect

.s to the testing of the Control Room: Ventilation System. At this time, however,

..I am'not prepared to formally address the remaining two violations, and-request that the required response time be extended by three weeks. This has-been'previously discussed with Mr. H. B.~ Shymlock of Region II. Justification ,

for this request-is.given below.

Duke: Power's Design Engineering Department will be evaluating the violation associated with the Annulus Ventilation System. The issues leading up to this particular incident.as well as the corrective actions-taken have been previously discussed with the Region and the_ site resident inspectors. There continuco to be a misunderstanding, however, as to whether the Annulus

Ventilation System could perform its required safety function and how this relates to the~-0.5 inches water column throughout the Annulus. I request a meeting

with the Region to clarify this issue prior to responding to the aviolation.

I i To fully evaluate the factors leading to the violation associated with the llydrogen Skimmer Fan' electrical breaker, pertinent information must be .

obtained from Westinghouse Electric Corporation. Westinghouse conducted testing on the type of breaker in question and recently issued a Part 21 t m notification of defect / noncompliance on this particular component. I cannot make an admission or denial of this violation until evaluating the

- Westinghouse test data.

8912120065 891130 PDR g(

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"V yy" e-L: s U.;S. Nuclear Regulatory Commission November 30, 1989 Page Two -

I appreciate the Region's consideration of the above issues and trust that suf ficient -justification for granting the response time extension has been .

l' shown, ii .

l Very Truly Yours, F-E p --

p g:/k p - 11. B. Tucker RGM/11218901 Attachment xc Mr. Stewart D. Ebneter Regional Administrator

~U. S. Nuclear Regulatory Commission Region II

-101 Marietta-St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. M. B. Shymlock

-Section Chief.

Division:of Reactor Projects U. S. Nuclear Regulatory Commission Region-11

101 Marietta St. , NW, Suite 2900

, Atlanta, Georgia 30323 Mr. W. T. Orders NRC Resident Inspector Catawba-Nuclear Station 1

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l .i F ATTACIIMENT 1 DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 4 413/89-29-02 I Technical Specification 3.7.6 requires that each VC train be capable of 4 maintaining the Control Room (CR) at a positive pressure greater than or  !

equal to 0.125 inches of water gauge (inwg) relative to adjacent areas with pressurization flow of less than or equal to 4000 cubic feet per minute r (cfm). If one train becomes inoperable while either unit is in Mode 4, or above, the inoperable train must be returned to operable status within seven days, or the operating units must be shutdown.

\

On September 15, 1989 A train of the Control Room Area Ventilation-(VC) l System was declared inoperable due to inadequate pressurization of the i Control Room with only one of two outside air intakes open. Train B of VC l was already inoperable for maintenance. At 1315 hours0.0152 days <br />0.365 hours <br />0.00217 weeks <br />5.003575e-4 months <br />, with both Units in  !

Mode 1 Technical Specification 3.0.3 was entered due to both trains of VC  ;

being inoperabic.

h RESPONSE:

1. Admission or Denial of Violation Duke Power Company admits the violation j

2. Reasons for Violation if Admitted -l Inadequate pre-operational and surveillance testing procedures. The test procedures did not test each train of VC to verify that the acceptance criteria could be satisfied with only one outside air intake open. The incident has also been attributed to equipment malfunctions of dampers 2CR-D-4, 9 and 10. Increased leakage, over a period of time, .

past the above dampers enabled cross train flow which lessened the  !

ability of VC train A to pressurize the CR. ,

3. Corrective Actions Taken and Results Achieved

a. All CR penetrations were inspected.

b. Train A's return air damper was adjusted and then tested satisfactorily.

c. From 9/15/89 to 9/16/89, compensatory measures were taken to limit burning in the area of the intakes, to establish a fire watch in the g

intake areas, to restrict movement of chlorine cylinders in the plant, and to instruct the Operators on actions to take if one or both intakes became isolated.

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d. Train B was tested satisfactorily in all-intake alignments and Train ,

M A was. balanced-(returning Train A's returniair damper to its .i

original position) and tested satisfactorily in all' intake ,

alignments._ '

e .~ - Design Engineering _ revised the criteria for Control Room and Control Room Area pressurization' flow rates.

i I' f.- A VC: flow balance. procedure'was developed to ensure adequate l p pressurization.in all alignments and to-ensure all-appropriate VC fans maintained proper flow., All testing was completed with .;

' acceptable results on 10/20/89. a F g.- Dampers 2CR-D-4, 9 and-10 were repaired and SWR's have been developed to inspect dampers every six months.

-4. Corrective Actions to be Taken to avoid further Violations a .1 Changes will be made to PT/0/A/4450/08,: Performance Surveillance test: procedure. to verify ~ adequate Control Room pressure.in all .

intake alignments.  ;

b.--All appropriate ventilation pre-operational-and performance 3r '

surveillance tests will be reviewed to assure adequate testing to design ~ bases.

5 '. Datc~of Full Compliance Changes will.be-incorporated into PT/0/A/4450/08 before the next test-but no later_than 2/1/90.- Action'b stated in Section 4 above wlll be in place by'2/1/90..

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