ML20056G735

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Informs That Based on Review of Justification,Course of Action Involves Minimum or No Safety Impact & Discretion to Not Enforce Compliance Will Be Exercised on one-time-only Basis
ML20056G735
Person / Time
Site: McGuire 
Issue date: 08/18/1993
From: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Mcmeekin T
DUKE POWER CO.
References
93-2-003, 93-2-3, NUDOCS 9309070102
Download: ML20056G735 (4)


Text

,

AUG I 81993

)

Docket No. 50-369 N0ED No. 93-2-003 Duke Power Company ATTN: Mr. T. C. McHenin Vice President McGuire Site 12700 Hagers Ferry Road Huntersville, North Carolina 28078

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR DUKE POWER COMPANY REGARDING MCGUIRE 1

)

8y letter dated August 17, 1993, you requested the U. S Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the l

requirements Technical Specification (TS) Surveillance 4.8.1.1.2.e.8 to avoid an unnecessary shutdown of McGuire Unit 1.

You requested approval on a one-time basis to allow the performance of a hot restart test on the "lA" and "lB" Diesel Generators (DG) while at power to satisfy the TS Surveillance requirement. You informed the NRC that the "lA" and "lB" DGs would not be in compliance with TS Surveillance 4.8.1.1.2.e.8 as of September 7,1993 and 1

October 1,1993 respectively, at which time the 28-month surveillance interval plus the 25 percent grace period expires. The TS Surveillance requires the hot restart of the DG be conducted within five minutes of completing the 24-hour endurance run, the latter of which is to be performed during shutdown.

This requirement had been changed on February 1, 1993 by NRC Amendment No. 135 to facility Operating License NPF-9 and Amendment No. 117 to Facility Operating License NPF-17 for the McGuire Nuclear Station Units I and 2; however, the changes were not ncorporated into all affected procedures.

Although surveillance tests v :e conducted on the DGs while Unit I was shutdown during the spring 1993, End-of-Cycle 8 (E0C8) refueling outage, the tests were not correctly performed in accordance with the existing TS Surveillance requirements due to your failure to completely revise the applicable procedures.

You provided as justification for continued operation that the hot restart test was successfully performed on the DGs during EOC7 in accordance with the existing TS Surveillance 4.8.1.1.2.e.7 (now superseded), which required operation for one hour to achieve temperature stability and within five minutes perform TS Surveillance 4.8.1.1.2.e.6.b, the ESF

  • test. This is the basis for current operability. Since the procedure that was used to conduct the surveillance testing had not been revised for the EOC8 outage, the hot restart was performed on both DGs as it had been during the E0C7 outage.

During EOC8 a hot restart test was performed on the "1A" DG following a 3-hour, 57-minute run, and on the "1B" DG following a 1-hour, 46-minute run.

9309070102 930818

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i AUG I 81993 Duke Power Company 2

These tests deviated from the existing TS Surveillance because they were not preceded by the 24-hour endurance run and that the DGs were automatically loaded in response to a simulated loss-of-offsite power in conjunction with an ESF signal, instead of verifying that the DG achieves rated voltage and frequency within 11 seconds.

In addition, you identified compensatory measures to include the performance of a hot restart test on both DGs while the Unit is at power during the next scheduled monthly test.

Each DG will be run for two hours at or near full load followed by a hot restart within five minutes of shutdown, in order to ensure that the DG has reached an acceptable temperature for conducting the hot restart. A footnote exists in the TS Surveillance which allows the hot restart test to be performed prior to completing the 24-hour run provided the DG has operated for at least two hours at or near full load. This footnote is included to address the possibility of a test failure during the 24-hour run and precludes excessive testing of a DG simply to achieve an acceptable temperature for conducting the hot restart test. Operation of the DG for two hours tied to the offsite grid is not significantly greater than the DG tests that are routinely performed with the

  1. nit at power to satisfy TS Surveillance 4.8.1.1.2.a.

Initiation of a hot restart will add one additional start cycle to cach DG but will not cause wear any greater than other routine tests. The hot restart tests on the Unit 2 DGs were successfully performed during the current Unit 2 refueling outage.

On the basis of our review of your justification, including any compensatory measures identified above, the staff has concluded that this course of action involves minimum or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective. Therefore, it is our intention to exercise discretion not to enforce compliance, on a one-time-only basis, with the requirements of TS Surveillance 4.8.1.1.2.e.8 until you conduct a hot restart test for each DG at power. The duration of the discretion will be for the time it takes to perform the tests which are to be performed in conjunction with your next j

scheduled monthly test of each DG. However, we will consider enforcement action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.

Sincerely,

~

Original signed by Stewart D. Ebneter Regional Administrator cc:

R. O. Sharpe Compliance Duke Power Company 12700 Hagers Ferry Road Huntersville, NC 28078-8985 (cc cont'd - See page 3)

AUG I 81993 Duke Power Company 3

(cc cont'd)

G. A. Copp

)

Licensing - EC050 Duke Power Company P. O. Box 1007 i

l Charlotte, NC 28242 A. V. Carr, Esq.

I Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 J. Michael McGarry, III, Esq.

Winston and Strawn 1400 L Street, NW Washington, D. C.

20005 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. O. Box 27687 Raleigh, NC 27611-7687 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, NC 28202 T. Richard Puryear Nuclear Technical Services Manager Carolinas District Westinghouse Electric Corporation P. O. Box 32817 Charlotte, NC 28232 Dr. John M. Barry, Director Mecklenburg County Department of Environmental Protection 700 North Tryon Street Charlotte, NC 28203 Karen E. Long Assistant Attorney General N. C. Department of Justice P. O. Box 629 Raleigh, NC 27602 bec:

(See page 4)

.a Duke Power Company 4.

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V. Nerses, NRR R. Watkins, RII-i:

.M. S. Lesser, RII A. R. Herdt, RII S. Ebneter, RII E. Merschoff, RII

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J. Johnson,, RI I A. Gibson RII.

M. Lesser, KII

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J. Partlow, ~ nRR i-W.: Russell, NRx S. Varga, NKR J. - Lieberman, nRR i

D. Matthews, NRK l'

G. Jenkins..R11 Document Control ~ Desk NRC Resident' Inspector

.U.S. Nuclear Regulatory Corraission

'12700 Hagers Ferry Road Huntersville, NC 28078-8985 l

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