IR 05000413/2014005

IR 05000413/2014005, 05000414/2014005; 10/1/2014 - 12/31/2014; Catawba Nuclear Station, Units 1 and 2; Integrated Inspection Report

ML15033A234
Person / Time
Site:	Catawba
Issue date:	02/02/2015
From:	Frank Ehrhardt NRC/RGN-II/DRP/RPB1
To:	Henderson K Duke Energy Corp
References
IR 2014005
Download: ML15033A234 (22)

Text

UNITED STATES bruary 2, 2015

SUBJECT:

CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000413/2014005, 05000414/2014005

Dear Mr. Henderson:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station Units 1 and 2. On January 5, 2015, the NRC inspectors discussed the results of this inspection with Mr. T. Simril and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or the significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at Catawba.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

Integrated Inspection Report 05000413/2014005, 05000414/2014005 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52 Report Nos.: 05000413/2014005, 05000414/2014005 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station, Units 1 and 2 Location: York, SC 29745 Dates: October 1, 2014 through December 31, 2014 Inspectors: A. Hutto, Senior Resident Inspector L. Pressley, Resident Inspector M. Meeks, Senior Operations Engineer (Section 1R11)

Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000413/2014-005, 05000414/2014-005; 10/1/2014 - 12/31/2014; Catawba Nuclear

Station, Units 1 and 2; Integrated Inspection Report The report covered a three-month period of inspection by the resident inspectors and one Region-based reactor inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5.

One violation of very low safety significance (Green), which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.

Unit 2 operated at or near 100 percent RTP for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Adverse Weather Conditions: The inspectors reviewed the licensees severe weather actions following a tornado watch issued on October 14, 2014. This included a review of actions required by RP/0/A/5000/007, Natural Disaster and Earthquake, Enclosure 4.1 to verify that the design features and implementation of the licensees procedures protected mitigating systems from adverse weather effects. Documents reviewed are listed in the Attachment.

Readiness for Seasonal Extreme Weather Conditions: The inspectors reviewed the licensees preparations for adverse weather associated with cold ambient temperatures.

This included field walkdowns to assess the material condition and operation of freeze protection equipment (e.g., heat tracing, instrument box heaters, area space heaters, etc.), as well as other preparations made to protect plant equipment from freeze conditions. The inspectors conducted discussions with operations personnel responsible for implementing the licensees cold weather protection program to assess the licensees ability to identify and resolve deficient conditions associated with cold weather protection equipment prior to cold weather events. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdowns: The inspectors performed three partial system walkdowns during the activities listed below to assess the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors performed walkdowns to identify any discrepancies that could impact the function of the system and, therefore, potentially increased risk. The inspectors reviewed applicable operating procedures and walked down system components, selected breakers, valves, and support equipment to determine if they were in the correct position to support system operation. The inspectors reviewed protected equipment sheets, maintenance plans, and system drawings to determine if the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program.

Documents reviewed are listed in the Attachment.

• Unit 1 A train of component cooling water system due to the 1B1 component cooling water pump out of service for planned preventive maintenance

• Unit 2 B train of auxiliary feedwater system due to the 2A auxiliary feedwater pump out of service for motor planned maintenance (PM)

• 1B diesel generator (DG) due to the 1A DG out of service for maintenance and inspections Complete System Walkdown: The inspectors conducted one detailed walkdown/review of DG 2B. The inspectors used licensee procedures and licensing and design documents to verify that the system (i.e., pump, valve, and electrical) alignment was correct; valves and pumps for diesel support systems did not exhibit leakage that would impact their function; major portions of the system and components were correctly labeled; hangers and supports were correctly installed and functional; and essential support systems were operational. In addition, pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the systems functions. Inspectors reviewed outstanding maintenance work requests/work orders and of open problem investigation program reports (PIPs) to verify that the licensee had appropriately characterized and prioritized safety-related equipment problems for resolution in the corrective action program. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Protection Walkdowns: The inspectors walked down accessible portions of the five plant areas listed below to assess the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors observed the fire protection suppression and detection equipment to determine whether any conditions or deficiencies existed which could impair the operability of that equipment. The inspectors selected the areas based on a review of the licensees safe shutdown analysis probabilistic risk assessment and sensitivity studies for fire-related core damage accident sequences. Documents reviewed are listed in the Attachment.

• Unit 1 594 electrical penetration room, fire area 20

• Unit 1 560 electrical penetration room, fire area 6

• Unit 2 DG room B, fire area 28

• Unit 1 electrical penetration room, 577 level, fire area 13

• Unit 2 electrical penetration room, 577 level, fire area 12 Fire Drill Observations: The inspectors observed a fire brigade drill on November 21, 2014 involving a simulated lubricating oil fire in the Unit 1 main turbine oil tank room.

The inspectors verified the fire brigades use of protective gear and firefighting equipment; that firefighting pre-plan procedures and appropriate firefighting techniques were used; that the directions of the fire brigade leader were thorough, clear and effective; and that control room personnel responded appropriately to the simulated fire events. The inspectors also attended the subsequent drill critiques to assess whether they were appropriately critical, included discussions of drill observations and identified any areas requiring corrective actions. Documents reviewed are listed in the

.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the updated final safety analysis report (UFSAR), individual plant examination, and flood analysis documentation associated with internal plant areas to determine the effect of flooding. The inspectors reviewed the licensees internal flood protection features for the flood walls constructed in the 568 foot elevation in the Unit 1 and Unit 2 turbine buildings to protect electrical switchgear and transformers against flooding caused by the rupture of circulating water system piping or components. The internal areas were selected and walked down based on the flood analysis calculations.

Through observation and design review, the inspectors reviewed sealing of doors, holes in penetrations, potential flooding sources, and water intrusion detection instrumentation.

The inspectors reviewed corrective action program documents to verify that the licensee was identifying issues and resolving them. Documents reviewed are listed in the

.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification (LOR) Program and Licensed Operator Performance

.1 Quarterly Resident Inspector LOR Activity Review

a. Inspection Scope

The inspectors observed Simulator Exercise Guide S-22 on October 30, 2014 to assess the performance of licensed operators during a license operator requalification simulator training session. The exercise included a load rejection, followed by a small break loss of coolant accident with a loss subcooling. The scenario was complicated by a loss of the A train vital electrical power and the B train safety injection pump failing to start.

The inspectors assessed overall crew performance, clarity and formality of communications, use of procedures, alarm response, control board manipulations, group dynamics and supervisory oversight. The inspectors observed the post-exercise critiques to determine whether the licensee identified deficiencies and discrepancies that occurred during the simulator training and exam. Documents reviewed are listed in the

.

b. Findings

No findings were identified.

.2 Quarterly Resident Inspector Licensed Operator Performance Review

a. Inspection Scope

The inspectors observed operators in the main control room during a power reduction for and performance of control valve movement testing, and the performance of auxiliary safeguards surveillance testing. The inspectors assessed the following:

- operator compliance and use of procedures

- control board manipulations

- communication between crew members

- use and interpretation of plant instruments, indications and alarms

- use of human error prevention techniques

- documentation of activities, including initials and sign-offs in procedures

- supervision of activities, including risk and reactivity management Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.3 Annual Review of Licensee Requalification Examination Results:

a. Inspection Scope

On August 29, 2014, the licensee completed the comprehensive biennial requalification written examinations and the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. During the week of December 1, 2014, the inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the two activities listed below for items such as:

(1) appropriate work practices;

(2) identifying and addressing common cause failures;

(3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule;

(4) characterizing reliability issues for performance;

(5) trending key parameters for condition monitoring; (6)charging unavailability for performance;

(7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and

(8) appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2)and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). For each item selected, the inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. Documents reviewed are listed in the Attachment.

• PIP C-14-8608, Unit 1 containment air release and addition system declared Maintenance Rule (a)(1) based upon repetitive maintenance preventable functional failures

• PIP C-12-08415, Maintenance Rule (a)(1) status for (29Y11) status indicator lights

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the following four activities to determine if the appropriate risk assessments were performed prior to removing equipment for work. When emergent work was performed, the inspectors reviewed the risk assessment to determine that the plant risk was promptly reassessed and managed. The inspectors reviewed the use of the licensees risk assessment tool and risk categories in accordance with Nuclear System Directive (NSD) 415, Operational Risk Management (Modes 1-3), to verify there was appropriate guidance to comply with 10 CFR 50.65(a)(4). Documents reviewed are listed in the Attachment.

• equipment protection plan for the 2A decay heat removal (ND) pump while the 2B ND pump was out of service for maintenance (yellow risk condition)

• equipment protection plan for the 2B DG while the 2A DG was out of service for governor replacement flywheel measurements (yellow risk condition)

• equipment protection plan for the 2B ND pump while the 2A ND pump was out of service for maintenance (yellow risk condition)

• equipment protection plan for the 1B DG while the 1A DG was out of service for maintenance and inspections (yellow risk condition)

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors evaluated the technical adequacy of the five operability evaluations or functionality assessments listed below to determine if technical specification (TS)operability was properly justified and the subject components and systems remained available such that no unrecognized increase in risk occurred. The inspectors reviewed the operability determinations to verify that they were made as specified by NSD 203, Operability. The inspectors reviewed the UFSAR to determine that the systems and components remained available to perform their intended function. Documents reviewed are listed in the Attachment.

• PIP C-14-9987, 1B nuclear service water (RN) pump discharge flow fell below 4000 gpm for approximately 2 minutes

• PIP C-14-10069, 15 drop per minute fuel oil leak on 1A diesel generator cylinder 4L

• PIP C-14-10174, The 2A containment spray pump had a total of 4 lead box cover bolts missing

• PIP C-14-11343, Oil film found on 4R petcock following 1B diesel generator bar and roll

• PIP C-14-11598, 1RN strainer fillet weld less than the required 3/8 inch

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the five post-maintenance tests listed below to determine if procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensees test procedures to determine if the procedures adequately tested the safety function(s) that may have been affected by the maintenance activities, that the acceptance criteria in the procedures were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests and/or reviewed the test data to determine if test results adequately demonstrated restoration of the affected safety function(s). Documents reviewed are listed in the Attachment.

• 1A auxiliary feedwater pump operational test following pump motor preventive maintenance (PM)

• 1A safety injection pump performance test following PMs

• 2A containment spray pump performance test following PMs

• 1A diesel generator operability test following lubricating oil maintenance and PMs

• control room area outside air pressure filter test following control room chill water and ventilation train B PMs

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the seven tests listed below, the inspectors witnessed testing and/or reviewed the test data to determine if the SSCs involved in these tests satisfied the requirements described in the Technical Specifications, the UFSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions.

Surveillance Tests

• PT/1/A/4200/009 A, Auxiliary Safeguards Test Cabinet Test, Enclosure 13.2, Steam Line Isolation - Train B

• PT/2/A/4200/009 A, Auxiliary Safeguards Test Cabinet Test, Enclosure 13.3, Steam Line Isolation - Train A

• PT/2/A/4400/014, RN to CA Suction Piping Flow Measurement

• PT/1/A/4350/002 A, Diesel Generator 1A Operability Test

• PT/2/A/4350/002 A, Diesel Generator 2A Operability Test In-Service Tests

• PT/1/A/4200/009 A, Auxiliary Safeguards Test Cabinet Periodic Test, Enclosures 13.9 and 13.10 Auxiliary Feedwater (CA) valve stroke time requirements RCS Leakage

• PT/1/A/4150/001 D, Reactor Coolant System Leakage Calculation

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed and evaluated the licensees emergency planning performance during a drill conducted on November 25, 2014. The inspectors reviewed licensee activities that occurred in the simulator and the Technical Support Center during the simulated events. The inspectors assessment focused on the timeliness and accuracy of the event classification, notification of offsite agencies, and the overall response of the personnel involved in the drills from an operations and emergency planning perspective.

The performance of the emergency response organization (ERO) was evaluated against applicable licensee procedures and regulatory requirements. The inspectors attended the post-exercise critique for the drills to evaluate the licensee's self-assessment process for identifying potential deficiencies relating to failures in classification and notification. The inspectors reviewed the completed licensee critique documenting the overall performance of the ERO.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee data to confirm the accuracy of reported PI data for the six indicators listed below. To determine the accuracy of the reported PI elements, the reviewed data was assessed against PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Rev. 6.

Cornerstone: Initiating Events

• Unplanned Scrams per 7,000 critical hours, Unit 1 & 2

Cornerstone: Mitigating Systems

• Safety System Functional Failures, Unit 1 & 2

Cornerstone: Barrier Integrity

• Reactor Coolant System Leakage, Unit 1 & 2 The inspectors reviewed the licensees procedures and methods for compiling and reporting the PIs including the reactor oversight program mitigating systems performance indicator basis document for Catawba. The inspectors reviewed the raw data for the PIs listed above for the period of October 1, 2013, through September 30, 2014. The inspectors also independently screened TS action item logs, selected control room logs, work orders and surveillance procedures, and maintenance rule failure determinations to determine if unavailability/unreliability hours were properly reported.

The inspectors compared the licensees raw data against the graphical representations and specific values contained on the NRCs public web page for 2013-2014. The inspectors also reviewed the past history of PIPs for systems affecting the mitigating systems performance indicators listed above for any that might have affected the reported values. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Daily Review

As required by Inspection Procedure 71152, Problem Identification and Resolution, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees corrective action program. This was accomplished by reviewing copies of PIPs, attending selected daily site direction and PIP screening meetings, and accessing the licensees computerized database.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors performed an in-depth review of the following issue within the mitigating systems cornerstone entered into the licensees corrective action program.

• PIP C-14-08787, Transfer Cask upper seal damaged during closure lid welding operations The inspectors reviewed the actions taken to determine if the licensee had adequately addressed the following attributes:

• complete, accurate and timely identification of the problem

• evaluation and disposition of operability and reportability issues

• consideration of previous failures, extent of condition, generic or common cause implications

• prioritization and resolution of the issue commensurate with safety significance

• identification of the root cause and contributing causes of the problem

• identification and implementation of corrective actions commensurate with the safety significance of the issue Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.3 Semiannual Trend Review

a. Inspection Scope

As required by IP 71152, Problem Identification and Resolution, the inspectors performed a review of the licensees corrective action program (CAP) and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screenings discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six month period of July 2014, through December 2014, although some examples expanded beyond those dates when the scope of the trend warranted. The review also included issues documented outside the normal CAP in major equipment problem lists, plant health team vulnerability lists, focus area reports, system health reports, self-assessment reports, maintenance rule reports, and safety review group monthly reports. The inspectors compared and contrasted their results with the results contained in the licensees latest quarterly trend reports.

Corrective actions associated with a sample of the issues identified in the licensees trend report were reviewed for adequacy.

b. Findings

No findings of significance were identified. In general, the licensee has identified trends and has appropriately addressed the trends with their CAP. In NRC inspection report 05000413/414/2013005, the inspectors identified a negative trend associated with consequential or regulatory significant plant status control events (equipment mispositions) with four examples listed in the trend review. Since the licensee has implemented corrective actions, no additional occurrences of consequential or regulatory significant plant status events have been identified. The licensees current plant status index is green. As a result of the licensees improved performance in this area, the inspectors are no longer tracking this trend item.

4OA5 Other Activities

(Closed) Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.

Inspectors independently verified that the licensees interim actions will perform their intended function for flooding mitigation.

The inspectors independently verified that the licensees proposed interim actions would perform their intended function for flooding mitigation.

• Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

• Reasonable simulation, if applicable to the site

• Flood protection feature functionality was determined using either visual observation or by review of other documents.

The inspectors verified that issues identified were entered into the licensee's corrective action program.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 5, 2015, the resident inspectors presented the inspection results to Mr. Tom Simril and other members of licensee management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which met the criteria of the NRC Enforcement Policy, for being dispositioned as a non-cited violation.

• Unit 1 and 2 Facility Operating Licenses, Condition 2.C.5, Fire Protection Program, required that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Section 9.5.1 of the UFSAR as amended and approved in the safety evaluation report through Supplement 5.

Safety Evaluation Report Section 9.5.1.8, Fire Protection for Specific Station Areas, stated in part, that each DG is located in a different fire area separated by a three-hour fire rated wall and that all cable and piping penetrations through the fire rated barriers are fitted with a three-hour fire rated penetration seal.

Contrary to the above, from October 2008 until November 2014, provisions of the approved fire protection program were not maintained in effect for the DG area.

Penetration Firestop 306W102, separating 2A and 2B DG rooms, was determined to be non-functional due to inadequate filler material. This represented a degradation of the separation requirements for a three-hour fire barrier. The licensee initiated PIP C-14-10350 to address and correct this issue. This finding screened as Green according to Inspection Manual Chapter 0609, Appendix F, Fire Confinement (Task 1.4.3) due to the presence of a fully functional automatic suppression system on either side of the fire barrier.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Arlow, Emergency Planning Manager

D. Cantrell, Chemistry Manager

L. Keller, General Manager, Nuclear Engineering

R. Hart, Regulatory Affairs Manager

K. Henderson, Site Vice-President

T. Jenkins, Maintenance Manager

C. Kamilaris, Organizational Effectiveness Director

K. Phillips, Work Management Manager

P. Simbrat, Regulatory Affairs Specialist

T. Simril, Plant Manager

D. Barker, Operations Manager

J. Smith, Radiation Protection Manager

W. Suslick, Director, Nuclear Engineering

S. West, Director, Nuclear Plant Security

LIST OF REPORT ITEMS

Closed

TI 2515/190 TI Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations (Section 4OA5)