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EA-99-094 - Catawba 1 & 2 (Duke Energy Corporation)July 22, 1999 EA 99-094 Duke Energy Corporation SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-413/99-10 AND 50-414/99-10) Dear Mr. Peterson: This refers to a special inspection conducted on March 14 through April 24, 1999, at the Catawba Nuclear Station. The purpose of this inspection was to followup on an earlier configuration control problem that rendered the Standby Shutdown System (SSS) inoperable. The results of the inspection, including one apparent violation, were discussed with members of your staff at an exit meeting on May 3, 1999, and formally transmitted to you by letter dated May 10, 1999. An open, predecisional enforcement conference was conducted at the NRC Region II office in Atlanta, Georgia, on July 12, 1999, to discuss the apparent violation, the root cause, and your corrective actions. A list of conference attendees, copies of the Nuclear Regulatory Commission's (NRC) slides, and Duke Energy Corporation's (DEC) presentation materials are enclosed. Based on the information developed during the inspection and the information you provided during the conference, we have determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report. The violation involved the failure to comply with Technical Specification (TS) 3.7.13, when the misalignment of two electrical breakers rendered the SSS inoperable from December 16 through 29, 1998. On December 16, 1998, in preparation for scheduled SSS maintenance, the two breakers were tagged and placed in the "off" (open) position. Upon completion of scheduled maintenance on December 18, plant personnel failed to return the two breakers to the normally "on" (closed) position. The misaligned breakers were discovered by DEC personnel on December 29, 1998, while conducting a plant procedure validation. Upon discovery of the open breakers, DEC personnel promptly positioned the breakers to their correct position to restore the SSS to operable status. TS 3.7.13 required that with the SSS inoperable, restore the inoperable equipment to operable status within seven days or be in at least hot standby within the next six hours and in at least hot shutdown within the following six hours; however, the SSS was inoperable for a total of 13 days and required actions were not taken to place the units in at least hot standby within the six hours and in at least hot shutdown within the following six hours. The root cause of the breaker misalignment was an oversight by DEC personnel in not referring to plant procedure OP/1/A/6350/001, Normal Power Checklist, to determine proper breaker position after the completion of maintenance, and in not specifying the correct position on system restoration procedures. Although the SSS is not considered a safety-related system, its design basis is to provide an alternate means for achieving and maintaining a hot standby condition for 72 hours during certain events, including station blackout (SBO) events. During a postulated SBO, the SSS provides electrical power via a dedicated diesel generator to the standby makeup pump and its suction and discharge valves (one pump and two valves for each unit), such that the pump can provide seal cooling flow to the reactor coolant pumps (RCP). The facility design requires restoration of RCP seal cooling flow in the event of an SBO within ten minutes to prevent seal damage and loss of seal integrity. However, with the two breakers in the incorrect position, the ability of the SSS to provide electrical power to open the standby makeup pump suction and discharge valves in a timely manner to provide RCP seal cooling flow within ten minutes could not be ensured. Although this condition did not result in any actual safety consequences, the potential existed for this condition to cause a loss of RCP seal integrity, had an actual SBO occurred. A violation that causes a system designed to prevent or mitigate serious safety events to be unable to perform its intended safety function is generally characterized as a Severity Level II violation in accordance with the "General Statement of Policy and Procedures for Enforcement Actions" (Enforcement Policy), NUREG-1600. During the enforcement conference, you presented the results of your bounding risk analysis, assuming RCP pump seal damage after ten minutes. Your analysis concluded that the increase in core damage frequency was small and below the accident precursor threshold of 1E-6 per year. Based on your analysis, we determined that this violation would not be properly characterized at Severity Level II. However, we have determined that this violation represents a significant failure to comply with the Action Statement of a TS Limiting Condition for Operation where the appropriate action was not taken within the required time. Therefore, this violation has been characterized in accordance with the Enforcement Policy as a Severity Level III violation. In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III violation. Because your facility has been the subject of an escalated enforcement action within the last two years(1), we considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit for Identification is warranted because the violation was identified by DEC personnel while conducting a plant procedure validation. Credit also is warranted for Corrective Action because of your immediate corrective action to restore the SSS to operable status and because of long-term corrective actions to preclude recurrence. These corrective actions included: discussions with plant operators to reinforce plant requirements to refer to procedures to determine breaker restoration positions and to maintain independence between plant personnel in the removal and restoration process; placement of permanent warning labels on the two breakers; and other corrective actions that were discussed at the conference. Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized by the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty. The NRC has concluded that information regarding the reason for the violation and the corrective actions taken and planned to correct the violation and prevent recurrence is already adequately addressed on the docket in NRC Inspection Report No. 50-413,414/99-10, Licensee Event Report 50-413/98-019 dated January 28, 1999, and in the materials you presented at the conference. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be placed in the Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If you have any questions regarding this letter, please contact Loren Plisco, Director, Division of Reactor Projects, at (404) 562-4501.
Enclosures: Docket Nos. 50-413 and 50-414
cc w/encls:
Enclosure 1 NOTICE OF VIOLATION
During an NRC special inspection conducted on March 14 through April 24, 1999, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
This is a Severity Level III violation. (Supplement I) The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in NRC Inspection Report No. 50-413,414/99-10 and Licensee Event Report 50-413/98-019 dated January 28, 1999. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you chose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, any response shall be submitted under oath or affirmation. If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 22nd day of July 1999
Nuclear Regulatory Commission L. Reyes, Regional Administrator, Region II (RII) Duke Energy Corporation (DEC)
G. Peterson, Vice President, Catawba Nuclear Station (CNS) 1. A Severity Level III problem was issued on June 11, 1998, for violations associated with the Unit 2 auxiliary building filtered exhaust system.
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