IR 05000413/1999010

Discusses Insp Rept 50-413/99-10 & 50-414/99-10 on 990314- 0424 & Forwards Notice of Violation Re Failure to Comply with TS 3.7.13,when Misalignment of Two Electrical Breakers Rendered SSS Inoperable from 981216-29

ML20210H194
Person / Time
Site:	Catawba
Issue date:	07/22/1999
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gordon Peterson DUKE POWER CO.
Shared Package
ML20210H199	List: IR 05000413/1999010 ML20210H221
References
50-413-99-10, 50-414-99-10, EA-99-094, NUDOCS 9908030299
Download: ML20210H194 (5)

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I July 22,1999 EA 99-094 Duke Energy Corporation ATTN: Mr. G. . Site Vice President Catawba Nuclear Station 4800 Concord Road York, SC 29745 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-413/99-10 AND 50-414/99-10)

Dear Mr. Peterson:

This refers to a specialinspection 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 ll 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 rnisalignment 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 personnelin not referring to plant procedure OP/1/A/6350/001, Normal Power Checklist, to determine proper breaker

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position after the completion of maintenance, and in not specifying the correct position on system restoration procedures.

c 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during ;

certain events, including station blackout (SBO) events. During a postulated SBO, the SSS I provides e_lectrical 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 ptimp can provide seal coolinD flow to the reactor coolant pumps (RCPl. 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 sealintegrity. However, with the two breakem 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 sealintegrity, had an actual SBO l

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 ll 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

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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 11 However, l 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 lli violation.

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I in accordance with the Enforcement Policy, a base civil penalty in the amount of S55,000 is considered for a Severity Level lli violation. Because your facility has been the subject of an ;

escalated enforcement action within the last two years', we considered whether credit was warranted for Identification and Corrective Actipn 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 Acjt on 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 personnelin the removal and restoration process; placement of permanent waming labels on the two breakers; and other corrective

- actions that were discussed at the co,nference.

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I A Severity Level 111 problem was issued on June 11,1998, for violations associated with the Unit 2 auxiliary building filtered exhaust system.

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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 t

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 .

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therein does not accurately reflect your corrective actions or your position. In that case, or if you I 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.

Sincerely, Original signed by LAR Luis A. Reyes i Regional Administrator j i

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Enclosures: 1. Notice of Violation 2. Conference Attendees I 3. Material Presented by NRC  ;

4. Material Presented by DEC '

Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 l

cc w/encis'. (see page 4) l

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Distribution w/encis:

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WTravers, EDO FMiraglia, DEDR MKnapp, DEDE

, DDambly, OGC l

EJulian, SECY 8 Keeling, CA Enforcement Coordinators Rl, Rlli, RIV JLieberman, OE GCaputo, O!

WBeecher, OPA HBell, OlG CEvans, Ril SSparks, Ril MSatorius, OEDO LPlisco, Ril BMallett, Ril COgle, Ril HBerkow, NRR PTam, NRR DNelson, OE RCarroll, Ril VOrdaz, NRR OE:EA File (BSummers, OE)(2 letterhead)

PUBLIC NRC Resident inspector U.S. Nuclear Regulator Commission 4830 Concord Road York, SC 29745 s N

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SENDTdPUBLICDOCUMENTR00M7 YES / ll OFFICE Mll:EICS Rll:DRP RII:DRS Ril:0RA RII:0g /

Signature $' g gf NW , g NAME SSPARKS LISCO BMALLETT CEVANS ! JOHN DATE "I/72/99 N / \L~ /99 M $ /99 w 5 /99 '7/ A/99 / /99 COPYt VES NO \ES NO '

YYESI NO 6ESl NO YE/NO ) YES NO OFFICIAL RECORD COPY DOCUMENT NAM 64*f:\ENf 0RCE\99 CASES \99094 CAT.DIR\F NAt@PD

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[ DEC- 4 cc w/encis: Peggy Force G. D. Gilbert Assistant Attorney General Regulatory Compliance Manager N. C. Department of Justice Duke Energy Corporation P. Box 629 4800 Concord Road Raleigh, NC 27602 York, SC 29745-9635 Saluda River Electric Lisa Vaughn Cooperative, Inc. ff

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Legal Department (PB05E) P. O. Box 929 Duke Energy Corporation Laurens, SC 129360 422 South Church Street Charlotte, NC 28242 County Manager of York County York County Courthouse -

Anne Cottingham . York, SC 29745 Winston and Strawn 1400 L Street, NW Piedmont Municipal Power Agency Washington, D. C. 20005 121 Village Drive Greer, SC 29651 North Carolina MPA-1 Suite 600 L. A. Keller, Manager P. O. Box 29513 Nuclear Regulatory Licensing Raleigh, NC 27626-0513 Duke Energy Corporation -

526 S. Church Street Virgil R. Autry, Director Charlotte, NC 28201-0006 Div. of Radioactive Waste Mgmt.

S. C. Department of Health j Steven P. Shaver and Environmental Control Senior Sales Engineer 2600 Bull Street Westinghouse Electric Company Columbia, SC 29201 5929 Carnegie Boulevard, Suite 500 Charlotte, NC 28209 Richard P. Wilson, Esq.

Assistant Attorney General S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Michael Hirsch ~

Federal Emergency Management Agency 500 C Street, SW, Room 840

. Washington, D. C. 20472 North Carolina Electric

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Membership Corporation P. O. Box 27306 Raleigh, NC 27611 ,

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