IR 05000413/2018003

NRC Integrated Inspection Report 05000413/2018003 and 05000414/2018003

ML18292A675
Person / Time
Site:	Catawba
Issue date:	10/18/2018
From:	Frank Ehrhardt NRC/RGN-II/DRP/RPB1
To:	Simril T Duke Energy Corp
References
IR 2018003
Download: ML18292A675 (14)

Text

UNITED STATES ctober 18, 2018

SUBJECT:

CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000413/2018003 AND 05000414/2018003

Dear Mr. Simril:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station, Units 1 and 2. On October 11, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. 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 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 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC resident inspector at the Catawba Nuclear Station.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the Catawba Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

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

Enclosure:

IR 05000413/2018003 and 05000414/2018003

Inspection Report

Docket Number(s): 50-413, 50-414 License Number(s): NPF-35, NPF-52 Report Number(s): 05000413/2018003 and 05000414/2018003 Enterprise Identifier: I-2018-003-0037 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station, Units 1 and 2 Location: York, SC Inspection Dates: July 1, 2018 to September 30, 2018 Inspectors: J. Austin, Senior Resident Inspector C. Scott, Resident Inspector A. Hutto, Senior Resident Inspector (McGuire)

B. Caballero, Senior Operations Engineer N. Lacy, Operations Engineer Approved By: Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a quarterly baseline inspection at Catawba, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Failure to Follow Maintenance Procedure Results in Damage to the 2A EDG During Testing Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green NCV H.8 - Procedure 71153 -

Systems05000414/2018003-01 Adherence Follow-up of Opened/Closed Events and Notices of Enforcement Discretion A Green self-revealed NCV of Technical Specification 5.4.1.a, Procedures, was identified for Catawbas failure to follow procedure TE-MN-ALL-0202, Transformer and Apparatus Testing, during maintenance on the 2A EDG. Specifically, the licensees failure to follow TE-MN-ALL-0202, resulted in damage to the voltage regulator circuit and the unexpected shutdown of the diesel during post maintenance testing (PMT) on June 11, 2018. The licensee entered this issue in the corrective action program (CAP) as Condition Report (CR)2212222.

Additional Tracking Items Type Issue Number Title Report Section Status Licensee 414/2018-002- Condition Prohibited by 71153 - Follow- Closed Event Report 00 Technical Specification of the up of Events (LER) 2A Diesel Generator and Notices of Enforcement Discretion Unresolved 05000414/2018- Notice of Enforcement 71153 - Follow- Closed Item(URI) 002-03 Discretion Granted from up of Events Technical Specifications and Notices of Related to the Failure of the Enforcement 2A EDG during Post- Discretion maintenance Test

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.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP

===71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection External Flooding

The inspectors evaluated readiness to cope with external flooding on September 11, 2018.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) safe shutdown facility diesel with the 2A emergency diesel generator (EDG) out of service on September 10, 2018

(2) Unit 1 and Unit 2, service water pump structure on September 13, 2018

(3) Unit 2 2B EDG on September 24, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Area TB2: Unit 2 turbine building elevation 594 on August 11, 2018

(2) Fire Area SRV: service building (electrical equipment area) on August 11, 2018

(3) Fire Areas 29 and 30: nuclear service water pump structure on August 12, 2018

(4) Fire Area 18: auxiliary building common area elevation 577 on August 15, 2018

(5) Fire Area YRD: Unit 1 and 2 transformer yard on September 17, 2018

71111.06 - Flood Protection Measures Cables

The inspectors evaluated cable submergence protection in service water conduit manholes CMH-15A and CHM-16A on September 10, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated reactor operator simulator training on September 5, 2018.

Operator Performance ===

The inspectors observed operator performance during a grid disturbance on July 10, 2018.

Operator Requalification Program (1 Sample)

The inspectors evaluated the operator requalification program from August 1 - 27, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) CR 2213180, Maintenance Rule (a)(1) evaluation - Repetitive failure of 2B seal water injection filter on July 24, 2018

(2) CR 2221652, Repair B control area chilled water (YC) condenser divider plate gasket on July 30, 2018

(3) CR 2221797, July 2018 emergency lighting system failures on July 31, 2018

(4) CR 2213216, Maintenance Rule (a)(1) evaluation for zone 2B lockout event on August 29, 2018

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

CR 2223943, Quality control inspection for EDG power driven potentiometer (PDP)replacement on August 8, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Protected equipment plan for 2A containment penetration valve injection (NW) out of service on August 13, 2018

(2) Yellow risk condition for 2A auxiliary motor driven feedwater (CA) pump out of service on August 16, 2018

(3) Protected equipment plan for standby shutdown facility out-of-service on August 21, 2018

(4) Protected equipment plan with Unit 2, Loop B delta T channel 2 out of service on September 6, 2018

(5) Protected equipment plan with the Unit 2 turbine driven auxiliary feed pump out of service for maintenance on September 19, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) CR 2219182, Voltage pushbutton responding slowly on July 17, 2018

(2) CR 2222637, Unit 1 B EDG drifting governor on August 2, 2018

(3) CR 2224399, Feedwater check valve on August 29, 2018

(4) CR 2228544, Pressurizer heaters decrease capacity on September 3, 2018

(5) CR 2208969, Unit 1 ETB and ETA degraded voltage timers on September 19, 2018

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) PT/2/A/4350/002, Diesel generator operability test B following compensatory action to bypass non-emergency start trip on June 27, 2018

(2) PT/2/A/4200/062, Nuclear service water (RN) to containment penetration valve injection (NW) flow verification test following rebuild of 2NW8A, 2A NW surge chamber RN supply, with retainer on August 15, 2018

(3) PT/2/A/4250/03 A, Auxiliary feedwater motor driven pump A performance test following preventive maintenance on 2A auxiliary feedwater pump motor breaker on August 16, 2018

(4) PT/1/A/4200/007 C, Standby makeup #2 performance test following replacement of pump plungers, on August 29, 2018

(5) IP/2/A/3222/000 I, Channel operational test for delta T/ T average following rescale of 2B loop T hot average signal, on September 6, 2018

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: In-service

(1) PT/2/A/4200/077, EDG starting air/service water valve in-service test, on August 13, 2018

(2) PT/1/A/4200/007 A, Centrifugal Charging pump 1A Test, on September 20,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below for the period from July 2017, through June 2018.

(1) mitigating systems performance index (MSPI) residual heat removal system

(2) unplanned power changes per 7000 hours0.081 days <br />1.944 hours <br />0.0116 weeks <br />0.00266 months <br />

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CR 2222680, 2B diesel starting air (VG) compressor air leak

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 414/2018-002-00, Condition Prohibited by Technical Specification of the 2A Diesel Generator, on June 11, 2018

Notice of Enforcement Discretion (1 Sample)

The inspectors reviewed the following unresolved item (URI) that was opened during the second quarter inspection report (2018-002, ML18221A305)

(1) URI 05000414/2018-002-03, Notice of Enforcement Discretion Granted from Technical Specifications Related to the Failure of the 2A EDG during Post-maintenance Test

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation The inspectors evaluated the licensees independent spent fuel storage installation cask loadings on September 20,

INSPECTION RESULTS

Failure to Follow Maintenance Procedure Results in Damage to the 2A EDG During Testing Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green NCV H.8 - 71153 - Follow-up of Systems05000414/2018003-01 Procedure Events and Notices of Opened/Closed Adherence Enforcement Discretion A Green self-revealed NCV of Technical Specification 5.4.1.a, Procedures, was identified for Catawbas failure to follow procedure TE-MN-ALL-0202, Transformer and Apparatus Testing, during maintenance on the 2A EDG. Specifically, the licensees failure to follow TE-MN-ALL-0202, resulted in damage to the voltage regulator circuit and the unexpected shutdown of the diesel during post maintenance testing (PMT) on June 11, 2018. The licensee entered this issue in the CAP as CR 2212222.

Description:

On June 11, 2018, at 4:08 a.m. the licensee declared the Unit 2A EDG inoperable in order to perform scheduled maintenance on the voltage regulator module. At 9:11 p.m. during the post maintenance test, when the 2A EDG reached 5100 kw, the diesel and associated output breaker 2ETA-18 tripped on an actuation of lockout relay 86D.

During troubleshooting, the licensee identified two disconnected cables in the voltage regulator circuit. These two cables connect the current transformer to the linear reactor. The licensee determined that the disconnected wires caused an electrical transient that occurred during the post maintenance test. Visual inspections of the electrical cabinet revealed damage to two silicon rectifier circuits (SCR) and the voltage regulator module.

The licensee determined that the two cables were left disconnected following recently performed doble testing of the current transformers. The controlling procedure for the maintenance activity was TE-MN-ALL-0202, Transformer and Apparatus Testing, and technicians used Attachment 15 of the procedure to document the leads that were lifted during the maintenance activity. Section 3.2 of TE-MN-ALL-0202, requires that all connections added or changed from their normal condition during performance of this procedure be recorded on Attachment 15, Configuration Control Sheet. Before testing, the technicians removed four leads for each phase (X, Y and Z) to prevent damage to the current transformers, but failed to document the removal of two leads for the X phase current transformer. After the test was complete, a different crew of technicians reconnected the leads using the data on Attachment 15, failing to reconnect the X phase leads. Additionally, a quality control inspector reviewed the work and signed off that the leads were rewired per

15.

Corrective Action(s): The licensee took corrective actions to replace the current transformers, two SCRs and the voltage regulator module. The 2A EDG was returned to service and declared operable at 2106 on June 14, 2018.

Corrective Action Reference(s): CR 2212222

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to follow procedure TE-MN-ALL-0202 during maintenance on the 2A EDG was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to follow TE-MN-ALL-0202, resulted in damage to the voltage regulator circuit and the unexpected shutdown of the diesel during post maintenance testing on June 11, 2018. The time to replace the components exceeded the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> required action time for Technical Specification 3.8.1 and a notice of enforcement discretion from the NRC was granted to allow continued operation of Unit 2 while the licensee made repairs.

Significance: The inspectors assessed the significance of the finding using IMC 0609, 4, Initial Characterization of Findings, dated October 7, 2016, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012. The inspectors determined that a detailed risk assessment was required because the performance deficiency represented an actual loss of function of at least a single train for greater than its TS allowed outage time. An SDP detailed risk evaluation (DRE) for this performance deficiency was performed by a regional SRA in accordance with NRC IMC 0609 Appendix A using the NRC Catawba SPAR model and input from the licensees Catawba fire probabilistic risk assessment model. The major analysis assumptions included:

treatment of the performance deficiency as a non-common cause start failure with an eighty nine hour exposure period, and consideration of standby shutdown facility success (SSF) as a safe and stable end state. The dominant sequence was a site-wide grid related loss of offsite power with A train power lost due to the performance deficiency, B train EDG in test and maintenance, failure of the SSF diesel generator and failure to recover an EDG or offsite power in two hours. The DRE estimated the risk increase due to the performance deficiency to represent an increase in core damage frequency less than 1E-6/year, a GREEN finding of very low safety significance.

Cross-cutting Aspect: The inspectors determined the finding had a cross-cutting aspect of procedure adherence in the area of human performance, because the licensee failed to follow the procedure during maintenance on the 2A EDG on June 11, 2018.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Licensee procedure TE-MN-ALL-0202 is the plant procedure used to doble test voltage regulator components for the emergency diesel generators. Section 3.2 of Procedure TE-MN-ALL-0202, requires that all connections added or changed from their normal condition during performance of this procedure be recorded on Attachment 15, Configuration Control Sheet.

Contrary to the above, on June 11, 2018, the licensee failed to follow procedure TE-MN-ALL-0202 during maintenance on the 2A EDG as required by Section 9.a of RG 1.33. As a result, two leads for the current transformer were left disconnected following the maintenance activity and the 2A EDG experienced an electrical transient that damaged multiple components of the voltage regulator during the PMT on June 11, 2018. The time to repair the 2A EDG exceeded the allowable technical specifications action time and a notice of enforcement discretion was required to allow continued operation of Unit 2 while the licensee took corrective action to repair the EDG. The 2A EDG was returned to service and declared operable at 9:06 p.m. on June 14, 2018.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this finding and associated violation closes URI 05000414/2018-002-03.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On October 11, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. Tom Simril, and other members of the licensee staff.

LIST OF

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

RP/0/5000/030, Severe Weather Preparations

71111.05AQ - Fire Protection Annual/Quarterly

CSD-CNS-PFP-TB2-0594-001, Unit 2 Turbine Building Elevation 594 Pre-fire Plan

CSD-CNS-PFP-SRV-0594-001, Service Building Elevation 594 Pre-fire Plan

CSD-CNS-PFP-PA-004, Protected Area West Pre-fire Plan

CSD-CNS-PFP-AB-0543-001, Auxiliary Building Elevation 543 Pre-fire Plan

CSD-CNS-PFP-PA-002, Protected Area Northeast NSW Pump Structure Grade Level

71111.06 - Flood Protection Measures

WO 20230993-04, RN ZP CHM16A A train PFM RN Conduit manhole visual inspection

WO 20230992-04, RN ZP CHM15A A train PFM RN Conduit manhole visual inspection

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Simulator Exams: ASE-1803, Rev. 0; ASE-1804, Rev. 0; ASE-1805, Rev. 0; ASE-1806, Rev. 0

JPMs: CSF-009, Rev. 2; CLA-110, Rev. 0; NS-106, Rev. 0,

EP-019 Rev. 0; EPL-008, Rev. 26; NV-126, Rev. 0; EP1-123, Rev. 0

NI-089, Rev. 0; VX-024, Rev. 23; DG3-009, Rev. 4

Written: LOR 2018 12 B2S, 7/30/18; LOR 2018 12 A1S, 7/23/18,

LOR 2018 12 C1, Rev. 1

PI&R: CR 02225742, 08/20/18; CR 02226491, 08/23/18; CR 02068427, 11/04/16

CR 02088023, 12/23/16; CR 02074714, 10/09/16; CR 02140010, 07/25/17

Medical Records (8 files)

Simulator Tests

2017 C1C24, Simulator Core Reload and Normal Evolutions

2017 Transient Test #2, LBLOCA & LOOP

2017 Transient Test #9, Load Rejection 50%

SBT: LOR Scenario OP-CN-ASE-1803

SBT: LOR Scenario OP-CN-ASE-1804

SBT: 2017 NRC Initial Exam Scenarios #1, #2, & #3

Reactivation Packages (8 files)

Remediation Packages (2 files)

71111.12 - Maintenance Effectiveness

CR 2143475, A Train YC Chiller divider plate

CR 2157050, B Train YC Chiller Divider Plate Gasket

CR 2225758, Return PDP removed from D/G-2A to vendor-Previous part 21

CR 2223943, QC inspection for the EDG PDP replacements

71111.19 - Post Maintenance Testing

CNC-1210.04-00-0073, LD Diesel Generator Low-Low Lube oil pressure loop accuracy

CR 2182982, P Frequency does not align with uncertainty calculation

71152 - Problem Identification and Resolution

AD-AD-All-008, Duke Energy Shared Resource Program, Rev. 1

AD-AD-All-0007, Oversight of Supplemental Personnel, Rev.1

60855.1 - Operation of an Independent Spent Fuel Storage Installation

PT/0A/4600/031, ISFSI Cask Surveillance, Rev.11

CR 2225788, NOP Improvement items for ISFSI cask surveillance

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