ML20237B448
| ML20237B448 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 08/14/1998 |
| From: | Berkow H NRC (Affiliation Not Assigned) |
| To: | Barron H DUKE POWER CO. |
| References | |
| TAC-MA3282, TAC-MA3283, NUDOCS 9808180277 | |
| Download: ML20237B448 (4) | |
Text
l fo -%?
I j e es p
t UNITED STATES
)
- 5 j
NUCLEAR REGULATORY COMMISSION I
WASHINGTON, D.C. 20046 4001
's..... p!
August 14, 1998 Mr. H. B. Barron Vice President, McGuire Site McGuire Nuclear Station Duke Energy Corporation 12700 Hagers Ferry Road Huntersville, NC 28078-8985
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 - NOTICE OF ENFORCEMENT DISCRETION (NO. 98-6-014) (TAC NOS. MA3282 AND
{
MA3283)
Dear Mr. Barron:
By letter dated August 12,1998, you requested that the NRC exercise discretion not to enforce compliance with the actions required by McGuire Nuclear Station, Units 1 and 2, Technical Specification (TS) Section 4.6.5.1.b.3. This requires the performance, every 9 months, of a visual inspection of flow passages in various parts of the ice condenser for accumulation of frost or ice. That letter documented information previously discussed with the staff in a telephone conversation on August 12,1998, at 1:30 p.m. (NRR Projects, NRR Technical Specifications Branch, and Region ll personnel were present.) During that discussion, the staff informed you of its conclusicn that the surveillance requirements., of TS 4.6.5.1.b.3 were not met. You stated that, because the ice condenser surveillance would not be in compliance with TS 4.6.5.1.b.3, entry into TS 4.0.3 (regarding failure to perform a surveillance requirement) was made at 2:05 p.m. on August 12,1998. The applicable Action requirement states, "With the ice bed inoperable, restore the ice bed to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 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 />."
You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercising discretion for an operating facility, set forth in Section Vll.c of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600, and that the NOED be effective for the period until issuance of a related TS amendment.
Your staff determined that Surveillance Requirement 4.6.5.1.b.3 was not being completely I
complied with, since the surveillance inspection did not include the lower inlet plenum and the tuming vanes. Therefore, McGuire Units 1 and 2 ice condensers were declared inoperable and you asked for staff enforcement discretion for those ice condenser components which are inaccessible during operation, i.e. the lower plenum support structures and turning vanes. The lower containment is not usually accessible during power operation because of high personnel radiological dose considerations. The enforcement discretion would allow continued operation \\
"3 of both units until the next refueling outages or earlier outage (s) of sufficient duration to perform l
the surveillance applicable to the ice condensers' lower inlet plena and tuming vanes.
The principal reason for the requirement that frost and ice buildup be limited stems from ste flow considerations wi'hin the ice basket matrix, i.e. uncontrolled buildup of frost / ice in this a
region can have a significant effect on the pressure drop across the ice condenser. For this l
reason, the subject surveillance requirement mentions specific structural components as having
~
9808100277 980814 P
P'
" " " " ~
PDR ADOCK 05000369 WW; P
PDR l
~ H. B. Birron ADgust 14, 1998 candidate surfaces for frost / ice buildup. The objective is the need to assure that adequate flow area is available for steam flow so that the pressure drop across the ice matrix is w2hin design limits. The lower inlet plenum and associated components (such as the tuming vanes) represent a relatively large free volume, such that the available flow area is not significantly affected by any localized frost / ice buildup within the volume. Specifically, the available flow area in the lower inlet plenum is typically 10 to 100 times the flow area within the ice basket matrix. Hence, the literal application of the subject surveillance requirement to the lower inlet plenum region has no significant physical basis.
On the basis of the preceding information, the staff has determined that it is not necessary to enforce compliance with TS 4.S.5.1.b.3 for the duration of the NOED, in that the Unit 1 and 2 ice condensers are currently capable of performing the required design function in the event of an accident and that the granting of this enforcement discretion will not result in any unavailability of the ice condensers. There are no negative safety consequences associated with the granting of this enforcement discretion, and no compensatory measures have been proposed by Duke Energy Corporation.
- The staff has reviewed your request and justification for the issuance of the NOED and agrees that it satisfies criterion 1(a) of the staffs ruidance, and that failure to implement the surveillance requirement of TS Section 4.d.5.1.b.3 should not result in the forced shutdown of Units 1 and 2. The staff concludes that the issue does not create any concerns regarding the capability of any structures, systems, or components to perform their intended safety functions.
I On the basis of the staffs evaluation of your request, the staff has concluded that a NOED is warranted because the staff is clearly satisfied that this action involves minimal or no safety.
impact and has no adverse radiological impact on public health and safety. Therefore, it is the staff's intention to exercise discretion not to enforce compliance with TS Section 4.6.5.1.b.3 for the period from 4:50 p.m. on August 13,1998, until issuance of related amendments to revise the subject TS, which was requested by your letter dated August 13,1998. This it.?er documents our telephone conversation at 4:50 p.m. on August 13,1998, when the sta verbally issued this NOED However, as stated in the Enforcement Policy, action will normally be taken to the extent that violations were involved for the root cause that led to the noncompliance for i
l which this NOED was necessary.
Sincerely, ORIGINAL SIGNED BY:
Herbert N. Berkow, Director Project Directorate li-2
)
Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation i
Docket Nos. 50-369 and 50-370 Distribution BBoger OGC I
Docket File JZwolinski ACRS cc: See next page PUBLIC JLieberman K.Campe,0-8 H7 PDil-2 RF R.Giardina,0-13 H15 HThompson COgle, Ril e-mail BSheron LPlisco, Ril NRCWEB NOED WBeckner SCullins/FMiraglia DOCUMENT QME: G:\\MCGulREWICG3282.LTR To receive a copy (th p document. indicate in the box: "E" = Copy N" = No copy OFFICE PMPpp l IPDll-2/LA l6 DSSA/D l Ril l
- PIMWD, l
NAME FMnaldiEn L LBerry Pro GHolahan*
COgle*
HBdkow
~
DATE T /l4/98 f ' #//V/98 8 / 14 /98 8 / 14 /98 R / W /98
- OFFICIAL RECORD COPY
- See previous concurrence
H. B. Barron candidate surfaces for frost / ice buildup. The objective is the need to assure that adequate flow area is available for steam flow so that the pressure drop across the ice matrix is within design limits. The lower inlet plenum and associated components (such as the tuming vanes) represent a relatively large free volume, such that the available flow area is not significantly affected by any localized frost / ice buildup within the volume. Specifically, the available flow area in the lower inlet pienum is typically 10 to 100 times the flow area within the ice basket matrix. Hence, the literal application of the subject surveillance requirement to the lower inlet plenum region has no significant physical basis.
On the basis of the preceding information, the staff has determined that it is not necessary to enforce compliance with TS 4.6.5.1.b.3 for the duration of the NOED, in that the Unit 1 and 2 ice condensers are currently capable of performing the required design function in the event of an accident and that the granting of this enforcement discretion will not result in any unavailability of the ice condensers. There are no negative safety consequences associated with the granting of this enforcement discretion, and no compensatory measures have been proposed by Duke Energy Corporation.
The staff has reviewed your request and justification for the issuance of the NOED and agrees that it satisfies criterion 1(a) of the staff's guidance, and that failure to implement the surveillance requirement of TS Section 4.6.5.1.b.3 should not result in the forced shutdown of -
Units 1 and 2. The staff concludes that the issue does not create any concems regarding the capability of any structures, systems, or components to perform their intended safety functions.
On the basis of the staff's evaluation of your request, the staff has concluded that a NOED is warranted because the staff is clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Therefore, it is the staff's intention to exercise discretion not to enforce compliance with TS Section 4.6.5.1.b.3 for the period from 4:50 p.m. on August 13,1998, until issuance of related amendments to revise the subject TS, which was requested by your letter dated August 13,1998. This letter documents our telephone conversation at 4:50 p.m. on August 13,1998, when the staff verbally issued this NOED. However, as stated in the Enforcement Policy, action will normally be taken to the extent that violations were involved for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, 1
. v5,
w
/
Hdrbert N. Berkow,' Director i
Project Directorate ll-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370 cc: See next page
McGuire Nuclear Station
)
cc:
Mr. Paul R. Newton Ms. Karen E. Long Legal Department (PBOSE)
Assistant Attorney General Duke Energy Corporation North Carolina Department of 422 South Church Street Justice l
Charlotte, North Carolina 28242 P. O. Box 629
)
Raleigh, North Carolina 27602 County Manager of Mecklenburg County L. A. Keller 720 East Fourth Street Manager - Nuclear Regulatory Charlotte, North Carolina 28202 Licensing Duke Energy Corporation Michael T. Cash 526 South Church Street j
Regulatory Compliance Manager Charlotte, North Carolina 28242 l
Duke Energy Corporation l
McGuire Nuclear Site Regional Administrator, Region il 1
12700 Hagers Ferry Road U.S. Nuclear Regulatory Commission Huntersville, Notth Carolina 28078 Atlanta Federal Center l
61 Forsyth Street, S.W., Suite 23T85 J. Michael McGarry, I!!, Esquire Atlanta, Georgia 30303 I
Winston and Strawn 1400 L Street, NW.
Elaine Wathen, Lead REP Planner Washington, DC 20005 Division of Emergency Management 116 West Jones Street 3
Senior Resident inspector Raleigh, North Carolina 27603-1335 c/o U.S. Nuclear Regulatory Commission Mr. Richard M. Fry, Director 12700 Hagers Ferry Road Division of Radiation Protection Huntersville, North Carolina 28078 North Carolina Department of Environment, Health and Natural Dr. John M. Barry Resources Mecklenberg County 3825 Barrett Drive Department of Environmental Raleigh, North Carolina 27609-7721 Protection 700 N. Tryon Street Mr. T. Richard Puryear Charlotte, North Carolina 28202 Owners Group (NCEMC)
Duke Energy Corporation Peter R. Harden, IV 4800 Concord Road Account Manager York, South Carolina 29745 Energy Systems Sales J
Westinghouse Electric Corporation
)
P. O. Box 7288 j
l l
Charlotte, North Carolina 28241-7288 i
l t