ML20086R176

Forwards Response on NRC Re Violation & Deviation Noted in Insp Repts 50-369/95-13 & 50-370/95-13.C/A: Performed Engineering Tests & Calculations Immediately to Characterize Train a Yc Chiller Performance

ML20086R176
Person / Time
Site:	Mcguire, McGuire
Issue date:	07/19/1995
From:	Mcmeekin T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9507310044
Download: ML20086R176 (4)

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ll Duke 1%werCanpany . .. ..

T.C M 11a us r McGuireNuclearGenemtionDepartment ~ Vice President

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, l July 19,1995

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- U. S. Nuclear Regulatory Comrrdssion ATTN: Document Control Desk Washington, D.C. 20555

Subject:

McGuire Nuclear Station, Units 1 and 2 Docket Nos 50-369 and 50-370 )

NRC Inspection Report No. 50-369,370/95-13 Violation 50-369,370/95-13-01 and Deviation 50-369,370/95-13-02

! Reply to a Notice of Violation and a Notice of Deviation L Gentlemen:

l l' Enclosed is a response to a Notice of Violation dated June 30,1995 conceming failure to conduct a proper evaluation of design changes on safety-related et juipment and a response to a Notice of Deviation de.ted June 30,1995 conceming Standby Nuclear Se- ' a Water Dam construction. Should there be any questions conceming this response, contact Randy Cross at (704) 875-4179.

Very Truly Yours,

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f t M.A T. C, McMeekin Attachment l

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Mr. S. D. Ebneter Mr. George Maxwell Regional Administrator, Region ll Senior Resident inspector U. S. Nuclear Regulatory Commission McGuire Nuclear Station .l 101 Marietta St., NW, Suite 2900 .j Atlanta, Georgia 30323

! Mr. Victor Nerses g . U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation One White Flint North, Mail Stop 9H3 t- - Washington, D. C. 20555

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, McGuire Nuclear Station Reply to a Notice of Violation  ;

Violation 50-369. 370/95-13-01 10 CFR 50 Appendix B, Criterion Ill, Design Control as implemented by tne Duke Power Company Topical

- Quality Assurance Program, (Duke 1-A), Amendment 19, Section 17.3.2.2 and 17.3.2.3, requires that design i control measures ensure that design modifications to safety-related equipment or systems are commensurate with those applied to the original design.  !

Contrary to the above, modification NSM-52288 to Control Room Ventilation / Chilled Water (VYNC) system ,

valves did not take into consideration the effects of the increased service water flows on system reliability when the valves were in the fully opened position. As a result, the system was declared past inoperable on February 21,1995, for the periods of April 17,1994, to June 22,1994, and December 13,1994, to December 31,1994. The modification allowed Train A chiller control valves to fail fully opened on ESF actuation, increasing the probability that Train"A" of the system would be lost during periods of elevated service water flow and low service water temperatures. ,

1 This is a Severity Level IV violation (Supplement 1).

Reolv to Violation 50-369. 370/95-13-01

1. Reason for the violation:  !

The reason for the violation is an inadequate review of the cumulative effects of all field changes during the design process. '

2. Corrective steos that have been taken and the results achieved:

a) Engineering tests and calculations were immediately performed to characterize Train A YC chiller performance as a function of Nuclear Service Water (RN) system flow and RN :j system temperature.

1 b) ESF testing for the Train B YC chiller was conducted on December 31,1994. During this {

testing, the Train B YC chiller performed as designed. .

c) Manual throttling of valve 1RN-98 was implemented on December 31,1994 as a

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compensatory measure to maintain operability of the Train A .YC chiller.

d) A Heat Balance test was performed on February 7,1995 for the Train A YC chiller to [

characterize the Train A chiller performance when the RN system temperature was at its lowest point.

No similar events have occurred since implementation of these corrective actions.

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3. . Corrective steos that will be taken to avoid further violations:

a) McGuire Site Directive (MSD) 350, Identifying and Performing Plant Retesting, was revised (Rev.1) to include YC chiller test requirements. Specifically, the Regulatory Retest List was revised to add a requirement to contact the VC/YC System Engineer for an evaluation of Heat Balance retest for Chillers A and B. This corrective action was completed on June 15, 1995.

b) Engineering personnel evaluated the need for additional long term plant changes or procedural changes regarding cooling water control for the YC chillers and determined the long term solution will be to continue to manually throttle valve 1RN-98. This solution adequately meets RN flow requirements to the YC Train A chiller. This corrective action was completed on June 21,1995.

c) McGuire System Engineers will receive training on this event, including the need to consider the cumulative effects of field changes upon aesign functions. This corrective action will be completed by November 30,1995.

4. Qate when full comoliance will be achieved:

McGuire Nuclear Station will be in full compliance by November 30,1995.

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, McGuire Nuclear Station

' Reply to a Notice of Deviation Deviation 50-369. 370/95-13-02 Final Safety Analysis Report, Appendix 2G, Standby Nuclear Service Water Pond Dam Figures 2G-1 A,2G-2 and 2G-3 indicate that the Standby Nuclear Service Water Dam extends approximately 1260 feet with an Garthen berm along the entire length of the dam.

Contrary to the above, an NRC/FERC Dam inspection conducted November 14-16,1994, revealed that the earthen berm did not extend the entire length of the dam., The berm terminated approximately 200 feet short ,

of the north end of the dam.

Reoiv to Deviation 50-369. 370/95-13-02

1. Beason for the deviation :

The reason for the deviation is inappropriate Action. A review of dam construction photos taken -

during the period 1971 -1974 and interviews with construction personnel involved in construction of the dam indicate the earthen berm at the North abutment was never built. During the period of dam construction, a concrete batch plant was temporarily located near the North abutment and construction of the earthen berm at this location would have interfered with access to the batch plant.

After construction nf the McGuire plant and subsequent removal of the concrete batch plant, the ,

earthen berm was not added at the North abutment.

2. Corrective steos that have been taken and the results achieved:

a) A survey of the north abutment area was immediately initiated to ensure that accurate elevation data was available to support an operabili'y evaluation for the Standby Nuclear Service Water Pond Dam. The survey was completed on November 17,1995.

b) Engineering personnel performed an operability evaluation for the Standby Nuclear Service l Water Pond Dam that determined the dam was present operable and the dam met the >

design basis criteria. This corrective action was completed on November 21,1994.

c) Minor Modification MM-6926 was implemented to install an earthen berm on the North i abutment of the Standby Nuclear Service Water Pond Dam. This corrective action was '

completed on May 24,1995.

No similar events have occurred since implementation of these corrective actions.

3. Corrective stens that will be taken to avoid further deviations:

No additional corrective actions are planned.

4. Date when the corrective actions will be comoteted :

All corrective actions have been completed.

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