ML20135H676
| ML20135H676 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/20/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | Adensam E, Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20135H677 | List: |
| References | |
| NUDOCS 8509240124 | |
| Download: ML20135H676 (6) | |
Text
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DUKE POWER GoMPANY P.O. BOX 33180 CHARLOTTE, N.C. 28242 HAL B. TUCKER TELEPHONE vuos,emessen (704) 373-4538 September 20, 1985
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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. C. Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Ms. E. G. Adensam, Chief Licensing Branch No. 4
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370 Temporary Extension of Allowed Outage Time for Unit'1 VA System
Dear Sir:
Attached are proposed license amendments to facility operating licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2 respectively. The pro-posed amendments would temporarily increase the time allowed to restore an inoperable unit I auxiliary building filtered ventilation exhaust (VA) system train to operable status from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days in order to allow adequate time to replace the carbon filter bed.
Attachment I contains the proposed Technical Specification changes (specifi-cations for unit 2 are only administratively affected in that they are com-bined with unit l's specifications, the change does not apply for unit 2).
. discusses the Justification and Safety Analysis to support the proposed changes (note that additional information is provided via my submittal of September 16, 1985). Pursuant to 10 CFR 50.91, Attachment 3 provides an analysis performed in accordance with the standards' contained in 10 CFR 50.92 which concludes that the proposed amendments have been reviewed and have been-determined to have no adverse safety or environmental impact.
It is requested that the proposed amendments receive timely review and approval under the Emergency License Amendment Provision of 10 CFR 50.91 (a)(5). The unit i VA system was declared inoperable at approximately 7:00 a.m., September 20, 1985 following performance of a routine 18 month surveillance test and the current Technical Specification requires initiation of unit shutdown to begin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter the declaration of inoperability. Failure to grtnt the requested change within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will result in shutdown of the unit since 5 to 7 days are required to change out and test.the large carbon filter bed. Consequently, neither the normal 30 day Federal Register public comment notice period (10 CFR 50.91 (a)(2)) nor the 15 day Exigent Circumstances notice period (10 CFR 50.91 (a)(6)) would allow for approval by this date.
Duke Power could not have avoided this situation and has not delayed this application to take advantage of the emergency license amendment provision of 10 CFR 50.91.
The Unit i VA system has been in continuous operation since February, 1985 when it was dceided to run it in the filter more continuously to remove any resin particles that may be in the duct work following a minor spillage (reference LER 369/85-09). The VA system is required to have routine monthly and 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal absorber operation surveillance testing in k
accordance with specification 4.7.7.
(In addition, the 18 month surveillance b
8509240124 850920
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Mr. Rarold R. Denton, Dir%ctor Sept:mber 20, 1985
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1 of Technical Specification 4.7.7.b.1 was due by September 25, 1985.) The surveillance and testing of the unit i VA system since February,1985 has been more frequent (due to continuous operation) and not indicative of any abnormal operation. The charcoal samples of the VA filter have been tested every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation and found to meet all the Technical Specification requirements. The failure of the filter due to 4% bypass leakage was unexpected. It is normal practice to perform most testing that can be done with the unit on line (such as the 18 month surveillance of the VA filters) during operation of the plant rather than during a refueling or other extended outage. Due to the time and manpower restrictions generally only allowing performance of testing and modifications that require shutdown conditions. The first indication that problems with the unit 1 VA system might exist was while getting ready to perform the Freon bypass leakage test last week. The setting up of Freon generator involves sending a b'trst of Freon through the filter. It is at this time, the McGuire station staff entertained their first suspicion that the filter may not pass the bypass leakage test. The amount of Freon detected down stream following a burst of Freon injection did not lend confidence to the station personnel that the carbon filter would pass the bypass leakage. test. The Freon detected down stream seemed to rise and decay in concentration slowly, a fact indicative of "no cracking" in the filter. However, the concentration of the Freon. detected appeared to be larger than what was considered u'sual by the station staff. Since the station personnel were only in process of setting up the Freon generator and the actual testing of the filters was not scheduled for another few days the station staff advised management that the possibility of failing bypass leakage test for the VA system existed and this could potentially have disruptive effect on the plant operation. The station staff felt that the filter would pass a "3 peak" test but not a "5 peak" test as required. The station staff also opinioned that a successful "5 peak" test could be performed with more sophisticated equipmcat. NRC (Darl Hood, et. al.) was contacted within a few hours to discuss this development in a conference call with the McGuire Licensing and Station staff. The station staff attributed faster than usual passage of the Freon through the carbon due to excessive humidity in air for the past several days of the filter operation.
The NRC staff expressed concern that the charcoal had degraded or was not tested at the correct temperature (of 80*C).
The charcoal samples from the filter have been again tested subsequently as reco= mended by the NRC staff and passed all tests.
The bypass leakage testing portion of the filter testing was delayed another few days to provide time for preparation and obtaining of other more accurate testing equipment. Consequently, Duke Power Company could not avoid this situation and has not created the situation to take advantage of the emergency provision.
Testing of the Unit I carbon filter for bypass leakage was performed about 5:00 a.m. September 20, 1985. The carbon sample testing had already been conducted. As a result of somewhat larger than expected concentration of Freon that was noticed to be passing through the filter during setting up of the Freon generator and detection instrumentation about a week earlier, the testing was delayed until September'20, 1985 to procure more accurate instrumentation.
A vendor along with different equipment was present for this The bypass leakage test showed a bypass leakage of 4% as measured by test.
two different types of equipment. The type of leakage observed was not slowly i
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Mr. Harold R.'Denton, Director
' September 20, 1985 Page Three 4
' decaying concentration of Freon observed during the setting up of the equip-ment a week earlier, instead this leakage appeared to be attributed to ccetling of the filter.
Shortly thereafter the VA system was declared inoperable (approximately 7:00 a.m.).
At present Duke Power is trying to locate source of the leakage. The condensate removal lines below the filter are being examined for potentially being a path of bypass leakage around the carbon beds, and all seals are also being examined.
If the source of. bypass leakage is located necessary ser-i vicing and repair will be conducted expiditiously (along with. subsequent l
retesting) to restore the filter to operability should operability be restored within 24 hoars Duke Power will advise the NRC to void this requested amend-ment if not already issued. The carbon filter replacement will be undertaken l
if it becomes apparent that other measures will not succeed..With the approval of the requested change on one time basis the unit would be kept in operation while carbon filter maintenance and replacement is carried out (approximately a 5 day process).
i Note that an amendment for a permanent Technical Specification change has already.been submitted to the NRC (reference my letter dated September 16, t
1985) to permit sufficient time to replace VA system filters without costly j
interruption of power operation in the future. NRC has been kept informed of i
all developments in this matter.
In addition, an NRC Technical Advisor i
toured the plants VA system on September 19, 1985 as part of the NRC Staff review of the September 16, 1985 submittal.
Mr. Mel Frye, of the Radiation Protection Branch, Department of Human Resources for North Carolina has been informed by telephone regarding the failure of Unit 1 filter to a bypass leakage test and Duke's plans to replace the charcoal'within 7 days. A copy of our NRC submittals is being sent to M.- Dayne Brown as usual.
r Pursuant to 10 CFR 170.3(y), 170.12(c), and 170.21, Duke Power proposes that this application contains license amendments for.McGuire Units 1 and 2 subject to fees based on the full cost of the review (to be calcualted 4
L using the applicable professional staff rates shown in 10 CFR 170.20) and must be accompanied by an application fee of $150, with the NRC to bill Duke Power at six-month intervals for all accumulated costs for the application i
Lor when review is completed, whichever-is earlier. Accordingly, please find enclosed a check in the amount of $150.00.
Should there be any questions of if additional information is required, please i
L advise.
Very truly yours, be Hal B. Tucker
- i PBN/VMK/slb Attachments:
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J Mr. Harold R. Denton, Director September 20, 1985 Page Four e
cc: "(w/ attachments)
Dr. J. Nelson Grace, Regional Administrator i
U. S. Nuclear Regulatory Commission - Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i
Mr. Dayne Brown, Chief
. Radiation Protection Branch J.
Division of Facility Services Department of Human Resources 4
P.O. Box 12200 Raleigh, North Carolina 27605 Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station 1
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Mr. Harold R. Denton September 20, 1985 Page Six HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the McCuire Nuclear Station License Nos. NPF-9 and NPF-17 and that all statements and matters set forth therein are true and correct to the best of his knowledge.
(
- a< Actr Hal B. Tucker, Vice President i
Subscribed and sworn to before me this 20th day of September,1985.
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Not'ary Public
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My Commission Expires:
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ATTACHMENT 1 j
l PTCPosed McGuire Unit 1 and 2 Technical Specification anges h
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