ML20215G350
| ML20215G350 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/03/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-87-008, EA-87-8, NUDOCS 8704170047 | |
| Download: ML20215G350 (10) | |
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- e DUKE POWER GOMPANY P.O. BOX 33189 CHARLOTTE, N.O. 28242 HAL B. TUCKER TELEP9EONE VBt;S PERSGDENT (704) 3m831 WWCLEAR PROpt7CT905 April 3, 1987 U.-S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555
Subject:
McGuire Nuclear Station Response to IE Inspection Report 50-369/85-38, 50-370/85-39 50-369/86-39, 50-370/86-39 Response to Proposed Civil Penalty EA 87-08 Gentlemen:
By letter dated March 6, 1987, NRC issued a Notice of Violation and Proposed Imposition of Civil Penalty EA 87-08.
This was the result of inspections conducted at McGuire which reviewed overall operability of the Nuclear Service Water (RN) system and identified violations of NRC regulatory requirements.
In response to this letter, please find attached specific responses to the Notice of Violation. Within the attached, Duke is denying several violations. The bases for these denials has been previously presented to NRC by my letter dated August 8, 1986, during the Enforcement Conference of December 8, 1986 and during the supplemental conference at McGuire on December 11, 1986.
Based on this exchange of information with NRC, Duke thought that these issues had been resolved and the findings (apparent violations) would be withdrawn. We did not expect to see these issues as violations when the Civil Penalty was proposed.
Also, please find attached a check for $50,000 as payment in full of the civil penalty.
I declare under penalty of perjury, that the statements set forth herein are true and correct to the best of my knowledge.
Very truly yours, e l hf Hal B. Tucker RLG/36/sbn Attachment 8704170047 870403 4} '
PDR ADOCK 05000369 O
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U. S. Nucl00r Regulctgry Comiccion
. April 3, 1987 Page Two xc:
Dr.-J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Darl Hood Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station i
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DUKE POWER COMPANY McGUIRE NUCLEAR STATION Proposed Response to IE Inspection Report Nos.
50-369/85-38 and 50-370/85-39 Dated March 6, 1987 The responses in this report are presented in an order consistent with the Inspection Report.
Violation A:
Technical Specification (TS) 3.7.4 requires that two independent nuclear service water loops be operable for modes 1, 2, 3, and 4.
With only one loop operable, both loops must be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit be in hot standby within the next six hours and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, as of January 27, 1986, the RN system was not operable in that the system was not capable of providing the McGuire Final Safety Analysis Report (FSAR) specified flow rates to certain heat exchangers under desi;n basis accident conditions of a seismic event causing loss of Lake Norman. This condition had existed from March 1983 to January 1986. During this period the units were operated in modes requiring the RN system to be operable.
Response
(1) Admission or denial of violation Duke admits the violation occurred. A test to verify proper flow to essential equipment during a LOCA on one unit coincident to a blackout on the other unit had not been performed.
(2)
Reason for the violation During preoperational testing, the RN system preoperational test proce-dures were performed to the FSAR abstract; however, this test was not addressed in the FSAR test abstract.
(3)
Corrective steps which have been taken and results achieved On January 27, 1986 an RN flow verification test was performed on Train A of Unit 1.
This test was performed for information purposes only and revealed RN flow to some equipment was lower than FSAR requirements.
Duke reviewed the test results and issued an operability letter dated l
January 28, 1986 which would justify lower RN flow rates to the Component Cooling and Containment Spray Heat Exchangers. Another test was performed on January 28, 1986 with Unit 1 RN Train A in a LOCA alignment and Unit 2 in a blackout alignment. The same test was performed on l
Unit 1 RN Train B and Unit 2 RN Train B on January 30, 1986.
Both tests revealed the RN system could supply adequate flow to essential equipment in the event of a LOCA on one unit with a blackout on the other unit although RN flow was lower than FSAR valves.
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(4) Corrective steps planned to avoid further violations Periodic flow balance, test procedures for Unit I and 2 have been written and are performed quarterly to verify that required RN flows are met.
(5)
The date when full compliance was achieved
' Duke was in full compliance January 30, 1986.
Violation B:
10CFR 50.59 requires in part that the holder of a license authorizing opera-tion of a production or utilitation facility may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the proposed change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question.
5 Shared systems are designated in the Technical Specifications by an asterisk
(*) in the margin adjacent to the associated Technical Specifications require-ment.
1 Contrary to the above, on October 7,1985, the licensee prepared a 10CFR 50.59 evaluation and performed actions which were intended to cross-connect the 1A and 2A nuclear service water system trains. The conclusion of the 10CFR 50.59 i
evaluation was in error in that the cross-connection would have placed the RN j
system in a configuration which would involve a change to the Technical Specifications. Because Technical Specification 3.7.4 was not designated by an asterisk to indicate a shared system, cross-connecting the 1A and 2A trains was not appropriate.
Response
(1) Admission or denial of violation l
Duke denies the violation.
1 Duke believes the 10CFR 50.59 evaluation was correct and does not present an unreviewed safety question by cross-connecting RN Train IA and 2A.
As previously presented to the NRC Staff during the December 1986, RN Enforcement Conference, the RN system is not shared in its entirety.
l McGuire T.S. 3.0.5.a states, "Whenever the Limiting Condition for l
Operation refers to systems or components which are shared by both units, the ACTION requirements will apply to both units simultaneously. This l
will be indicated in the ACTION section."
(2)
Corrective steps planned to avoid further violations Duke will initiate a T.S. change to designate the RN system as a shared i
system in T.S. 3.7.4.
The proposed T.S. change will be submitted within 120 days.
(3) The date of full compliance Full compliance will be achieved upon issuance of an amendment to the license by NRC.
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, Violation C:
10CFR 50, Appendix B, Criterion XI, requires that a test program shall be established to assure that all testing required to demonstrate that struc-tures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational' tests during nuclear power plant operation, of structures, systems, and components. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
1.
Contrary to the above, preoperational testing of the RN system did not include simultaneous alignment of both RN trains to the standby nuclear service water pond, a design basis accident configuration described in the FSAR.
Response
(1)
Admission or denial of violation Duke admits the RN system test did not include simultaneous alignment of both RN Trains to the Standby Nuclear Service Water Pond.
(2) Reason for the violation if admitted As discussed earlier, the McGuire preoperational test were performed to the FSAR abstract; however, simultaneous alignment of both RN Trains to the Standby N clear Service Water Pond was not addressed in the FSAR test u
abstract.
(3) Corrective steps which have been taken and results achieved Periodic flow balance test procedures for Unit I and 2 have been written, which include simultaneous alignment of both RN Trains to the Standby Nuclear Service Water Pond, and are performed quarterly. The tests have verified that the RN system can provide required flows during design basis accidents configurations described in the FSAR.
(4) Corrective steps planned to avoid further violations Periodic flow balance test procedures for Unit I and 2 have been written and are performed quarterly to verify required RN flows are met.
(5) Date of full compliance Duke was in full compliance April 1, 1986.
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Violation :
2.
Contrary to the above, test results indicated that systems or components, as shown below, were not able to perform as intended, and the results were not properly documented and evaluated.
a.
On December 17, 1985, testing indicated that the Unit 1 "A" train containment spray heat exchanger, control room chiller heat ex-changer, charging pump oil cooler, spent fuel pool pump room air handling unit, and containment spray pump room air handling unit flows were less than their requisite FSAR flow values.
It was not until January 1986, that the licensee formally prepared a " written" evaluation.to determine the acceptability'of the test data when requested by the NRC.
a.
Response
.(1) Admission or denial of violation i
Duke denies the violation. The test performed on December 17,1985 was intended to be an "information only" test to determine the best method to conduct a flow balance test. At that time, a determination was made that various components were in a degraded mode but were not inoperable.
The Duke design operability statements of January 1986, confirmed the opera-bility of the components that indicated low flow in December 1985.
(2)
Corrective steps which have been taken The tests used in measuring flow through the components have been changed to use better flow measurement techniques and to include acceptance 1
criteria and limits.
(3) Corrective steps planned to avoid further violations Duke performs periodic tests to ensure adequate flow through the compo-nents is achieved.
(4) Date of full compliance i
Full compliance was achieved April 1,1986.
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~5-Violation :
b.
While performing a quarterly performance test of the 1A containment spray heat exchanger on October 7, 1985, the as-found RN flow rate of 800 gallons per minute (gpm) for that heat exchanger was identified, a value significantly below previous as-found test data. This condition was not evaluated by the licensee until requested by the NRC on March 24, 1986.
Additionally, during the test, an RN flow of 4600 gpm for the 1A contain-ment spray heat exchanger was achieved rather than the 5000 gpm as specified by the procedure. The inability to perform the test at 5000 gpm was not formally evaluated by the licensee until requested by the NRC on October 15, 1985.
Response
(1) Admission or denial of violation Duke denies this violation because the test procedure, (PT/1/A/4403/04) was being used to determine differential pressure across the Containment Spray Heat Exchanger and Decay Heat Removal Air Handling Unit Heat Exchangers on a quarterly basis to trend for fouling.
It was never intended to be used to evaluate flow rates or flow balances of the RN system. It did not provide for recording data relevant to the remainder of the RN system. Furthermore, Duke considers the 800 gpm flow recorded during the October 1985 test an unusable data point with respect to determining system operability because of the manner in which the RN system was functioning at the time of the test.
The RN system was not in an ESF alignment at the time of the subject test as would be required to evaluate system operability.
As previously discussed during the December 1986 RN Conference, the as found flow rate of 800 GPM is significant only in that the throttle valve was closed more than required in an accident. Since this system is manually initiated by the operators who understand system requirements, Duke is confident the valve position would not have led to a problem.
Also, the test specified that approximately 5000 gpm is required; there-fore, 4600 gpm would be acceptable for the test procedure.
(2) Corrective actions that have been taken The procedure was changed to include acceptance criteria to indicate correct data was gathered and provide data sheets for the recording of the information.
(3)
Corrective steps planned to avoid further violations None (4)
Date of full compliance Duke was in full compliance April 1, 1986.
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Violation D:
10CFR 50, Appendix B, Criterion V, states 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.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
I 1.
Contrary to the above:
i Throttle valve positions associated with RN components set during pre-1 operational testing were not incorporated into the appropriate operating and surveillance procedures. As a result, the actual valve throttle positions differed from the pre-operational test positions and operating i
procedures. This condition existed from February 1981 through January j
1986.
(1)
Admission or denial of violation l
Duke admits the violation, i
(2) Reason for the violation j
There was an improper transfer of valve positions from preoperational 1
test to operating procedures, f
(3)
Corrective steps that have been taken and the results achieved The new valve positions have been incorporated into Operation's
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procedures and RN flow balance tests have been performed proving opera-bility of the RN system.
I (4)
Corrective steps planned to avoid further violations All RN throttle valves, with the exception of two per train, are in the i
full open position. Duke will maintain awareness of these valve posi-tions for any future changes in the valve positions and take appropriate i
actions.
l (5) Date of full compliance I
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Duke was in full compliance September 3, 1986.
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U Violation :
2.
The licensee's quarterly performance test of the 1A containment spray heat exchanger, PT/1/A/4403/04, conducted periodically between June 1983 and October 1985, lacked qualitative and quantitative acceptance criteria which resulted in significant, undetected fouling and degradation of that l
l heat exchangers.
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Response
i (1) Admission or denial of violation Duke denies the violation. As previously stated (See Violation C.2.b of this response) the procedure, PT/1/A/4403/04 was used for component delta pressure data collection only and not for evaluation of RN system flow requirements.
(2) Corrective steps that have been taken 9
The procedure was changed to include acceptance criteria indicating the correct data was gathered and provided data sheets for the recording of 1
the information.
(3) Corrective steps planned to avoid further violations All procedures that will be used for data collection only will include acceptance criteria indicating the correct data to be gathered.
(4) Date of full compliance Duke was in full compliance April 1,1986.
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Violation :
3.
Licensee's procedure TT/1/A/9100/105 requires that valve IRN73A, 1A train service water diesel generator heat exchanger outlet isolation valve, be returned to its normal position at the completion of that test. On January 28, 1986, the NRC discovered that the procedure was not followed in that valve IRN73A had not been returned to its normal condition at the completion of the test earlier that day.
Response
(1) Admission or denial of violation Duke admits the violation.
(2)
Reason for the violation There was an improper transfer of valve positions from preoperational test procedures to operating procedures.
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(3)
Corrective steps that have been taken Procedure TT/1/A/9100/105, RN Train IB Flow Verification was revised to leave the service water outlet isolation valve to the Containment Spray Heat Exchangers in the tested throttle position.
(4)
Corrective steps planned to avoid further violations 2
None.
(5) Date of full compliance i
Duke was in full compliance August 19, 1986.
1 Violation :
4.
Licensee emergency operating procedures for safety injection (EP/1/A/
5000/01, EP/2/A/5000/01) and for transfer to cold leg recirculation (EP/1/A/5000/2.3, EP/2/A/5000/2.3) did not provide specific operator actions to assure proper nuclear service water flow through the diesel generator cooling water heat exchanger and containment spray heat ex-changer during accident conditions in that required flow rates were not l
specified.
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Response
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(1) Admission or denial of violation l.
Duke admits the violation.
(2) Reason for the violation This violation was an oversight during the preparation of said procedures.
(3) Corrective steps that have been taken and results achieved Operating procedures, EP/1/A/5000/01, EP/2/A/5000/01, EP/1/A/5000/2.3 and EP/2/A/5000/2.3 have been revised in order to establish adequate RN flow i
through the Diesel Generator Heat Exchanger and Containment Spray Heat j
Exchanger during safety injection and transfer to cold leg recirculation.
(4)
Corrective steps planned to avoid further violations None.
(5) Date of full compliance Duke was in full compliance August 19, 1986.