ML20215P031
| ML20215P031 | |
| Person / Time | |
|---|---|
| Site: | Mcguire |
| Issue date: | 02/11/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8611100257 | |
| Download: ML20215P031 (2) | |
Text
s ec~ F2 a FT25 N0 : 06 February 11, 1986 Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Re: McGuire Nuclear Station, Unit 2 Docket No.'50-370 G
' Relief From1 Technical' Specification LCO (Temporary Waiver)
Dear Dr. Grace:
This letter constitutes written followup of a request for temporary waiver of technical specification requirements which was made (and subsequently granted) via telecons between Duke Power Company personnel and members of your staff on February 7, 1986. This temporary emergency relief from compliance with technical specification Limiting Conditions for Operation (LCO) avoided unnecessarily shutting down McGuire Unit 2 since the LCO's allowed outage time (A0T) was exceeded prior to completion of corrective actions.
During an exit interview held on February 7, 1986 for NRC/01E Inspection Report Nos. 50-369/86-05 and 50-370/86-05 a concern was raised by the NRC inspector regarding periodic testing of valves. Upon further investigation by Duke it was determined that valves NI-184 and NI-185 (Train B and Train A Containment Sump Isolation valves) on both McGuire units had not been tested per the requirements of ASME Boiler and Pressure Vessel Code 1980 Edition Section XI paragraph IWV-3300 which states that valves with remote position indicators shall be observed at least once every 2 years to verify that valve operation is accurately indicated.
Consequently, since Units 1 and 2 were both in Mode 1 valves INI-184 and 185 (Unit 1) and 2NI-184 and 185 (Unit 2) were declared inoperable at 1415 on February 7, 1986 pursuant to Technical Specification 3.5.2 "ECCS Subsystems - Tave > 350*F".
With one ECCS subsystem inoperable this specification provides for a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time after which the valve (i.e. flow path) would have to be restored to operable status or the unit (s) placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
However, since both the Train A and B valves were inoperable this LCO action requirement was not met and both units entered Technical Specifica-tion 3.0.3 under which action had to be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit (s) in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at least hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Successful testing of one train's valve within I hour would allow declaring that train operable resulting in the unit (s) being in the longer (72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />)
T.S. 3.5.2 action statement until the other train's valve could be tested.
Accordingly, Duke initiated efforts to test the Train B valve (NI-184) on each unit within the hour, with the Train A valves (NI-185) to follow.
However, since testing of these valves involves isolating and depressurizing the residual heat removal (ND) pumps as well' Iv{y 0 3 p*m f 3 8611100257 860211 l
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Dr. J. Nelson Grace February 10, 1986 Page 2 being located in a contaminated area it was not certain whether the testing could be accomplished within the allowed time to reach hot standby condi-tions. Consequently, on February 7, 1986 following discussions between Duke Power Company personnel and members of your staff a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the requirements of T.S. 3.0.3 was verbally granted for both units.
This relief was based on the low probability of an accident requiring use of the ECCS subsystems during this short time period, the fact that perio-dic testing had been satisfactorily performed on these valves in the past using limit switch indications in the control room (as opposed to the
' direct visual observation required by the IWV paragraph), and the desire to avoid a thermal cycle on the reactors and associated systems which has real benefits in terms of availability, component lifetime, and safety.
Testing of Unit 1 Train B valve 1NI-184 was satisfactorily completed and the ECCS subsystem train declared operable at 1525 on February 7, 1986; with the Unit 1 Train A.ECCS subsystem declared operable at 1655 following completion of testing to its valve (lNI-185). Testing of Unit 2 Train B valve 2NI-184 was begun at 1450 on February 7, 1986, but as a result of problems occurring during this testing the Train B ECCS subsystem was not declared operable until 2255 on February 7, 1986. The Unit 2 Train A valve (2NI-185) was then successfully tested and the ECCS subsystem declared operable at 2340 on February 7, 1986.
A Licensee Event Report will be submitted detailing this event. Duke would like to express its appreciation for the NRC's timely cooperation in this matter.
Should there be any questions or if additional information is required, please advise.
Very truly yours,
/& a Hal B. Tucker PBN/jgm xc:
Mr. Harold R. Denton, Director Mr. Darl Hood Office of Nuclear Reactor Regulation Office of Nuclear Reactor Reg.
U.S. Nuclear Regulatory Commission U.S. Nuclear Reg. Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Dayne Brown, Chief Radiation Protection Branch Division of Facility Services Department of Human Resources P.O. Box 12200 Raleigh, N.C.
27605 Mr. W.T. Orders NRC Resident Inspector McCuire Nuclear Station i