ML20140C101

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Responds to NRC Re Violations Noted in Insp Repts 50-369/97-04 & 50-370/97-04.Corrective Actions:Initiated Compensatory Measure in Order to Maintain Operability & Replaced Two 250 Watt Heater Elements in Each Safety Fwst
ML20140C101
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 06/03/1997
From: Barron H
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-369-97-04, 50-369-97-4, 50-370-97-04, 50-370-97-4, NUDOCS 9706090114
Download: ML20140C101 (7)


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Duke nnter Company H & Ban 6s AlcGuire Nuclear Genenuion Department Liu %ivat U7i)0 Hagers Ruy Road (AIGCHP)

(TUDSiblM Huntersville. NC:3078Bl0 (MI)875tSWl'n

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i DUKEPOWER June 3, 1997 U.

S. Nuclear Regulatory Commission 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, 370/97-04 Violation 50-369/97-04-01 and 50-369,370/97-04-04 Reply to a Notice of Violation Pursuant to the provisions of 10 CFR 2.201, attached is a response to a Notice of Violation dated May 5, 1997 for failure to ensure installation of correctly sized heaters in Refueling Water Storage Tank (FWST) level transmitter enclosures and failure to report a condition required by 10 CFR 50.72 in a timely manner.

Duke Power acknowledges the l

violations as stated in the Notice of Violation.

McGuire has several initiatives underway regarding FMST and freeze protection to avoid future inoperability of systems, structures and components associated with the FWST.

There are modifications currently under development to move and upgrade the level instrument enclosures and to upgrade the l

instrumentation.

Engineering is developing a self-assessment of the FWST design basis.

Very Truly Yours, l.

H68n H.

B.

Barro T EOl/g t

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Attachment 9706090114 970603 PDR ADOCK 05000369 G

PDR f

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U.

S. Nuclear Regulatory Commission v

June 3, 1997 xc:

(w/ attachment)

Mr. Luis A.

Reyes Regional Administrator, Region II U.

S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, Georgia 30323 Mr. Victor Nerses U.

S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation One White Flint North, Mail Stop 9H3 Washington, D.

C.

20555 Mr. Scott Shaeffer Senior Resident Inspector McGuire Nuclear Station i

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McGuiro Nuclscr StEtion l

Reply to a Notice of Violation l

l Restatement of Violation 50-369,370/97-04-04 l

Appendix B, Criterion V, Instructions, Procedures and Drawings requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

I Contrary to the above, prior to November 30, 1996, activities affecting quality, were not accomplished in accordance with these instructions, procedures, or drawings, in that, heater elements installed for freeze protection in the Unit 1 and Unit 2 Refueling Water Storage Tank (FWST) safety-related level transmitter enclosures were found to be of a higher capacity chan described on engineering design drawings and documents.

Specifically, two 250 watt heater elements were installed in each enclosure, whereas the applicable design documents specified one 50 watt element per enclosure.

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

Reply to Violation 50-369,370/97-04-04 1.

Reason for the violation:

The reason for the violation is changes were made to station equipment outside of the modification process.

2.

Corrective steps that have been taken and the results achieved:

a) An operability evaluation determined that the safety FWST level transmitters and the non-safety FWST level and temperature transmitters were operable but degraded.

In order to maintain operability, a compensatory measure consisting of an hourly l

conditional surveillance was initiated to verify that the temperature for each safety FWST level l

transmitter enclosure and each non-safety FWST level l

and temperature enclosure was greater than 40 degrees but less than 140 degrees.

If the temperature inside an enclosure exceeded 140 degrees, the heater breaker would be manually tripped.

This compensatory measure was implemented on November 21, 1996.

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McGuiro Nuclocr Station Reply to a Notice of Violation I

,L b) On November.22, 1996,'the two 250 watt heater i

elements in each safety FWST level transmitter I

enclosure were replaced with a 50 watt heater element to match existing design documents.

Engineering calculations were performed that verified that a 50 l

watt-heater element was large enough to prevent freezing within the enclosures during extreme cold weather conditions.

The hourly conditional i

surveillance was discontinued for safety FWST level transmitter enclosures.

c) On November 24, 1996, the hourly conditional surveillance for each non-safety FWST level and 1

temperature enclosure was changed to a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance based on.the Technical Specification 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance for FWST temperature and the once every 7 day surveillance for FWST minimum volume j

l flow.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance was continued until completion of a modification to add high temperature f

alarms.

i d) An Engineering evaluation was performed - to determine the optimum heater capacity for the safety FWST level transmitter enclosures and the non-safety FWST level and temperature enclosures.

Minor Modifications MGMM-8884 (Unit 1) and MGMM-8885 (Unit 2) installed two 100 watt heaters within the safety FWST level transmitter enclosures and two 250 watt heaters within non-safety FWST level and temperature r

enclosures.

These heater capacities are large enough L

to prevent freezing within the enclosures during extreme cold weather conditions.

As part of the.

modification process, applicable design drawings and documents were rrarised to reflect these design changes.

These modifications were completed on November 30, 1996.

e) Minor Modifications MGMM-8884 and MGMM-8885 also implemented a high temperature Operator Aid Computer (OAC) alarm.in FWST instrument enclosures to provide adequate notification.to Operations of an abnormally l

high temperature condition.

After implementation of

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the OAC alarm on November 30, 1996, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance for the non-safety FWST level and i

temperature enclosures was discontinued.

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f) Engineering reviewed other plant system i

instrumentation with energized freeze protection to

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determine if the potential existed for similar over i

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j McGuiro Nuclocr Station Reply to a Notice of Violation i

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temperature induced instrumentation failures.

One

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potential failure was identified for specific condenser circulating water (RC) instrument loop local gauges and flow switches; however, Engineering l

performed an evaluation and determined there was no operability concern.

Additional protection or alarms l

were not necessary.

This corrective action was l

completed on May 22, 1997.

g) On December 12, 1994, Duke Power Company implemented j

Nuclear System Directive (NSD) 106 Configuration Management Program which consists of a set of programs and processes to ensure that plant design requirements, plant documentation and the as-built j

plant configuration are in agreement.

The Directive l

was implemented after the time period in which this violation occurred and these processes have contributed to improved plant configuration control.

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

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

No further corrective actions are planned, j

4.

Date when full compliance will be achieved:

McGuire Nuclear Station is in full compliance with Appendix B, Criterion V.

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McGuiro Nucloar Station Reply to a Notice of Violation Restatement'of Violation 50-369/97-04-01 10 CFR 50.72 (b) (2 ) (i) requires, in part, that any event, found while the reactor is shutdown, that, had it been found while the reactor was in operation would have resulted in the nuclear power plant, including its principle safety barriers, being seriously degraded or being in an unanalyzed condition that significantly compromises plant safety shall be reported within four hours of the occurrence.

Contrary to the above, between February 26 and March 12, the licensee failed to make a timely report per the requirements of 10 CFR 50.72 concerning a degraded condition identified on the Unit 1 main feedwater isolation valves during shutdown conditions.

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

Reply to Violation 50-369/97-04-01 1.

Reason for the violation:

Due to the complex nature of the operability evaluation, extensive analysis over a period of approximately two weeks was required to determine that the isolation valves were inoperable.

The evaluation and communication between Engineering and Regulatory Compliance was not timely enough to report under 10 CFR 50.72.

2.

Corrective steps that have been taken and the results achieved:

a) A 10 CFR 50.72 notification was made on March 14, 1997.

b) A training package was presented to Plant Engineering and Regulatory Compliance personnel that provided guidance on reviewing equipment operability and associated reportability issues.

This corrective action was completed on June 2, 1997.

No similar events have occurred since implementation of this corrective action.

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McGuiro Nuclonr Stction e'

Reply to a Notice of Violation e'

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

No additional corrective actions are planned.

4.

Date when full compliance will be achieved:

McGuire Nuclear Station is now in full compliance with 10 CFR 50.72 requirements.

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