IR 05000413/2019002
| ML19226A096 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/14/2019 |
| From: | Frank Ehrhardt NRC/RGN-II, Division Reactor Projects II |
| To: | Simril T Duke Energy Carolinas |
| Reeder D | |
| References | |
| IR 2019002 | |
| Download: ML19226A096 (22) | |
Text
August 14, 2019
SUBJECT:
CATAWBA UNITS 1 AND 2 - NRC INTEGRATED INSPECTION REPORT 05000413/2019002, 05000414/2019002, 07200045/2019002, AND NOTICE OF VIOLATION
Dear Mr. Simril:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Catawba Units 1 and 2. On July 24, 2019, 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
The enclosed report documents two Severity Level IV violations. The NRC evaluated these violations in accordance with Section 2.3.2.a of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that these violations did not meet the criteria to be treated as non-cited violations because your staff failed to place the violations into your corrective action program to restore compliance and address recurrence consistent with Section 2.3.2.a of the Enforcement Policy.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.
If you contest the violation or significance of the NCV documented in this inspection report, 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 Catawba.
If you disagree with a 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 Catawba. 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. 05000413, 05000414, AND 07200045 License Nos. NPF-35 and NPF-52
Enclosure:
1. Notice of Violation 2. Integrated Inspection Report 05000413/2019002, 05000414/2019002, 07200045/2019002
cc w/ encl: Distribution via LISTSERV
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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 Report the Loss of Emergency Assessment Capability of the Technical Support Center Within Eight Hours.
Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NOV 05000413/414/2019002-01 Open Not Applicable 71111.15 The inspectors identified a Severity Level (SL) IV NOV of 10 CFR 50.72(b)(3)(xiii) for the licensees failure to report to the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the major loss of emergency assessment capability of the technical support center (TSC). Specifically, on April 28, 2019, there was an unplanned loss of emergency response facility (ERF) function, which resulted in the loss of emergency assessment capability in the TSC.
Failure to Perform Post Modification Testing Following a Design Change to the Nuclear Service Water System.
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000413/2019002-02 Open/Closed
[H.3] - Change Management 71111.22 The inspectors determined a self-revealing Green NCV of 10 CFR Part 50, Appendix B,
Criterion XI, "Test Control," for the failure to perform adequate post modification testing following a design change to the nuclear service water system (NSWS).
Failure to Provide Complete and Accurate Information in Licensee Event Report (LER)
Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NOV 05000413/2019002-04 Open Not Applicable 71153 The inspectors identified a SL IV NOV of 10 CFR 50.9, Completeness and Accuracy of Information, for the licensees failure to provide information that was complete and accurate in all material respects in LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions.
Additional Tracking Items
Type Issue Number Title Report Section Status URI URI 05000413/2019002-03 Unresolved Item (URI) MSPI Data associated with failure of the 1A EDG not reported 71151 Open LER 05000413/2019-001-00 LER 2019-001-00 for Catawba Nuclear Station, Unit 1,
Condition Prohibited by Technical Specifications -
Cooling Water Flow Path to 1A Emergency Diesel Generator Not Properly Aligned.
71153 Closed LER 05000413/2019-002-00 LER 2019-002-00 for Catawba Nuclear Station, Unit 1,
Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions 71153 Discussed
PLANT STATUS
Unit 1 operated at or near 100 percent rated thermal power for the entire inspection period.
Unit 2 operated at or near 100 percent rated thermal power 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 and Unit 2 service water pump structure on June 13, 2019
- (2) Safe shutdown facility on June 13, 2019
- (3) Unit 1 and Unit 2 service water pump structure on June 18, 2019
71111.04S - Equipment Alignment
Complete Walkdown (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1A emergency diesel generator system on June 13, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (6 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 2 turbine building elevation 594, fire zone TB1 on June 24, 2019
- (2) Unit 2 exterior doghouse, fire zone 50 on June 25, 2019
- (3) 1A emergency diesel generator room fire zone 25 on June 26, 2019
- (4) 2B centrifugal charging pump fire zone 18 on June 29, 2019
- (5) Unit 2 A safety injection pump fire zone 4 on June 29, 2019
- (6) Unit 1 auxiliary building corridor, elevation 574, fire zone 45 hallway on June 29, 2019
71111.06 - Flood Protection Measures
Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Condition Report (CR) 2278584, 1A emergency diesel generator room on June 23, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator
Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section
03.01)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during entry into alarm procedure AP 1/A/5500/037, Generator Voltage and Electric Grid Disturbances, on May 12, 2019
- (2) The inspectors observed and evaluated licensed operator performance in the Control Room during entry into alarm procedure AP 2/A/5500/037, Generator Voltage and Electric Grid Disturbances, on June 20, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulator scenario including loss of service water, generator voltage and grid disturbances, reactor trip, steam generator tube rupture and an emergency action level classification on May 6, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (4 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) CR 226982, Containment penetration water injection supply valve on April 24, 2019
- (2) A(3) periodic assessment performed on April 29, 2019
- (3) Work Request (WR) 20142212, Replaced 87G relay on the safe shutdown facility diesel generator on May 9, 2019
- (4) Work Order (WO) 20334666, Replace isolation amplifier for power range detector N-41 on June 13, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) 1B service water strainer motor oil leak on April 17, 2019
- (2) Yellow risk while 1A auxiliary feedwater (CA) pump was out of service for inboard oil change on April 18, 2019.
- (3) Protected equipment plan with train B standby nuclear service water pond return isolated for pre-planned maintenance on May 22, 2019
- (4) Protected equipment plan with the 1B CA pump out of service for replacement of the sump pump on June 27, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) CR 2266217, High containment temperature while running lower containment ventilation unit 1D on April 2, 2019
- (2) CR 2270172, Loss of flow to 2EMF-38/39L on April 29, 2019
- (3) CR 2273289, Rigor and Past TSC Functionality Assessments, May 16, 2019
- (4) CR 2275747, Emergency diesel generator 1B Doble testing results on June 4, 2019
- (5) CR 2279135, 1B auxiliary feedwater sump pump abnormal vibration on June 26, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Functional testing in the 2A emergency diesel generator (EDG) following preventive maintenance on diesel generator ventilation on April 9, 2019
- (2) WR 20142212, Replace 87 G relay on the standby shutdown facility diesel generator on May 9, 2019
- (3) Post maintenance test (PMT) following preventive maintenance on 2RN-28A on May 13, 2019
- (4) WO 20276444, PMT of the standby makeup pump following preventive maintenance on June 14, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
- (1) PT/1/A/4250/03C, Inservice Testing on CA Pump Turbine #1 on June 12, 2019
Surveillance Tests (other) (IP Section 03.01) (1 Sample)
- (1) PT/1/A/4350/002A, Diesel Generator 1A Operability Test on March 22, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section
03.01)
- (1) The inspectors performed an emergency planning drill evaluation which simulated a loss of the switchyard, a pressurizer power-operated relief valve failed open, a reactor trip and a safety injection on May 23, 2019.
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The inspectors evaluated a training evolution scenario which simulated a loss of the 1A centrifugal charging pump, manual reactor trip, manual safety injection and failure of safety injection valve 1NI-71 on April 11,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 submittals listed for the period from June 1, 2018, through March 31, 2019.
- (2) Unit 2 submittals listed for the period from June 1, 2018, through March 31, 2019.
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 submittals listed for the period from June 1, 2018, through March 31, 2019.
- (2) Unit 2 submittals listed for the period from June 1, 2018, through March 31, 2019.
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 submittals listed for the period from June 1, 2018, through March 31, 2019.
- (2) Unit 2 submittals listed for the period from June 1, 2018, through March 31, 2019.
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issue:
- (1) CR 2264322, Corrective actions to ensure diesel operability with B train nuclear service water return piping isolated for inspection on May 29, 2019
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors identified an adverse trend in the licensees ability to recognize the significance of deficiencies associated with equipment important to safety and then subsequently correct the deficiencies. Specifically, engineering has provided operations with analyses that are not thoroughly researched with respect to design and licensing requirements (e.g. auxiliary feedwater (AFW) sump pumps) or prior operating experience (e.g. NW) and that have not adequately considered likely changes in demands on equipment (e.g. TSC - weather, staffing.) As a result, there are multiple examples of evaluations that tend to justify the existence of the deficiency rather than challenge functionality to the extent that operability is assured (as is or through necessary corrective actions).
71153 - Followup of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample, 1 Partial)
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) LER 2019-001-00 for Catawba Nuclear Station, Unit 1, Condition Prohibited by Technical Specifications - Cooling Water Flow Path to 1A Emergency Diesel Generator Not Properly Aligned. The circumstances surrounding this LER are documented in report Section IP 71111.22 and as Green NCV 05000413/2019002-02 in the table below.
- (2) LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions. The circumstances surrounding this LER are documented as NOV 05000413/2019002-04 in the table below. (Partial Sample)
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants
Operation of an Independent Spent Fuel Storage Installation at Operating Plants (1 Sample)
- (1) May - June loading campaign VCC 92 Loading
INSPECTION RESULTS
Failure to Report the Loss of Emergency Assessment Capability of the Technical Support Center within Eight Hours.
Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000413/414/2019002-01 Open
Not Applicable 71111.15 The inspectors identified a SL IV NOV of 10 CFR 50.72(b)(3)(xiii) for the licensees failure to report to the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the major loss of emergency assessment capability of the TSC. Specifically, on April 28, 2019, there was an unplanned loss of ERF function, which resulted in the loss of emergency assessment capability in the TSC.
Description:
At approximately 10:00 PM on April 28, 2019, the licensee observed temperatures in the TSC at 84 degrees Fahrenheit and that the air handling unit (AHU) breaker had tripped open. The licensee identified a similar occurrence had also occurred on April 18, 2019. Following the breaker trip on April 18, 2019, maintenance noted that the condenser fins were bent and very dirty, which may have contributed to the breaker tripping. Using the guidance provided in RP/0/A/5000/036, Equipment Important to Emergency Response, the TSC was determined to be functional by the licensee. Procedure RP/0/A/5000/036 Enclosure 8.5 (Emergency response facility functional check) Section E states in part, If the TSC wet bulb globe is less than 86 degrees Fahrenheit and the TSC dry bulb temperature is greater than or equal to 40 degrees Fahrenheit, the TSC is habitable relative to personnel comfort. At approximately 8:00 AM on April 29, 2019, the resident inspectors questioned the licensee whether the TSC was functional and if the AHU could maintain temperature at or below 86 degrees Fahrenheit. The licensee responded and said as long as the temperature was below 86 degrees Fahrenheit the TSC was functional. Subsequently, the residents asked the licensee at what temperature would the TSC temperature plateau after staffing with no AHU and an outside air temperature of 74 degrees Fahrenheit. The licensee determined that the TSC temperature would stabilize at 105 degrees Fahrenheit. The licensee troubleshot the AHU issue on May 1, 2019, and added 3 quarts of oil and 12 pounds of refrigerant to the compressor. The inspectors consulted NRC HQ Emergency Planning technical staff concerning TSC functionality/habitability and Operating Experience Branch for reportability issues and they concurred that given the status of the TSC AHU and outside air temperatures that reasonable engineering judgement would conclude the TSC would not have been able to maintain proper functional status (temperatures less than 86 degrees Fahrenheit) had it been called upon to be fully staffed and TSC computers turned on for April 28, 2019 and therefore an unplanned loss of ERF function had occurred and that this was a reportable condition. The resident inspectors informed the licensee that in accordance with NUREG 1022, Rev. 3 Event Report Guidelines 10 CFR 50.72 and 50.73, Supplement 1, and the NRC-endorsed NEI 13-01 Rev. 0, Reportable Action Levels for Loss of Emergency Preparedness Capabilities, an unplanned loss of a primary ERF is reportable if not restored within the facility activation time specified in the emergency plan, which, in this instance, was 75 minutes. The licensee has refused to report this condition and come into compliance by issuing per 10 CFR 50.72(b)(3)(xiii) the required 10 CFR 50.72 event report.
Corrective Actions: The licensee did not enter this reporting violation into their corrective action program, and therefore the licensee had not restored compliance.
Corrective Action References: None
Performance Assessment:
Traditional Enforcement Assessment: The licensee failure to report to the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> the major loss of emergency assessment capability of the TSC was determined to impede the NRCs ability to perform its regulatory function and is dispositioned using the Traditional Enforcement process.
Enforcement
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. Based on the examples provided in Section 6.9 of the Enforcement Policy, dated May 28, 2019, Inaccurate and Incomplete Information or Failure to Make a Required Report, the performance deficiency was determined to be a SL IV violation. Specifically, example d.9 states that a SL IV violation involves a failure to make a report to the NRC in accordance with 10 CFR 50.72.
Violation: 10 CFR Part 50.72(b)(3)(xiii), states in part, that the licensee shall notify the NRC as soon as practical and in all cases within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the occurrence of any event that results in a major loss of emergency assessment capability. Contrary to the above, on April 28, 2019, the licensee failed to notify the NRC within eight hours of a TSC condition that resulted in a major loss of emergency assessment capability. Specifically, the licensee failed to make a required event report for a TSC habitability issue that impacted the emergency assessment capability of the TSC, such that it would be significantly impaired if an emergency were to have occurred and the TSC was fully staffed.
Enforcement Action: A Notice of Violation (NOV) is attached. This violation is being cited because the licensee failed to place it in the corrective action program to restore compliance and address recurrence consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Perform Post Modification Testing Following a Design Change to the Nuclear Service Water System.
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000413/2019002-02 Open/Closed
[H.3] - Change Management 71111.22 A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, "Test Control" was identified for the failure to perform adequate post modification testing following a design change to the NSWS.
Description:
On March 22, 2019, during monthly surveillance testing of the 1A EDG, in accordance with PT/1/A/4350/002A, Diesel Generator 1A Operability Test, operators received control room annunciator alarm 1AD-12 D/1 diesel generator heat exchanger A outlet flow LO. After approximately three minutes, operators shut down the diesel and declared the 1A EDG inoperable. During troubleshooting, the licensee discovered that supply piping flush isolation valve, 1RN-P09, was closed even though the position indicator showed the valve as open. The licensee inspected the valve and discovered that the valve stem was disengaged from the actuator. The licensee repaired the valve and restored service water flow to the 1A EDG heat exchanger.
On March 11, 2019, the plant entered Technical Specification (TS) 3.7.8, Condition D for single pond return header operation to perform pre-planned maintenance on the A train return piping to the standby nuclear service water pond. The design change to support single pond return header operation was implemented under Engineering Change (EC) 406529. During normal operations, 1RN-P09 is locked closed and only used to perform infrequent flushes of the service water piping. Under EC 406529, the normal NSWS operation was changed to require this valve to be in the open position to maintain service water flow to the 1A EDG heat exchanger and ensure operability of the diesel while in TS 3.7.8, Condition D. The inspectors reviewed the EC package and noted that the licensee did not verify service water flow through the 1A EDG heat exchanger after the NSWS was changed to require operation of 1RN-P09. Procedure AD-EG-ALL-1155, Post Modification Testing, establishes the licensees post modification test control philosophy in accordance with 10 CFR 50 Appendix B Criterion XI requirements for post modification related testing. Procedure AD-EG ALL-1155, states in part, that testing is intended to verify the entire operation of the structure, system, and component (SSC) and demonstrate that SSCs will perform their intended functions. The inspectors determined that the licensee could have identified the failed valve had an adequate post-modification test been performed for EC 406529.
Corrective Actions: The licensee repaired the valve and restored service water flow to the 1A EDG heat exchanger.
Corrective Action References: This issue was entered in the CAP as CR 2264322.
Performance Assessment:
Performance Deficiency: The failure to perform adequate post-modification testing in accordance with AD-EG ALL-1155, Post Modification Testing, following a design change to the NSWS was a violation of 10 CFR Part 50, Appendix B, Criterion XI and a performance deficiency.
Screening: This performance deficiency was more than minor because it affected the mitigating systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems and components that respond to initiating events to preclude undesirable consequences (i.e. core damage). Specifically, the 1A EDG was inoperable due to a lack of service water flow from March 11, 2019, when the plant entered single pond return operation until the valve was reopened on March 22, 2019.
Significance: A detailed risk evaluation was performed by a regional senior reactor analyst in accordance with NRC Inspection Manual Chapter 0609 Appendix A using the NRC SPAR model with input from the licensees fire probabilistic risk assessment model. The major analysis assumptions included: a 268 hour0.0031 days <br />0.0744 hours <br />4.431217e-4 weeks <br />1.01974e-4 months <br /> exposure period, no credit for the emergency supplemental power system or Flex equipment, treatment of the performance deficiency as a non-common-cause failure, and limited recovery credit via opening an alternate service water valve from the main control room. The dominant sequence was a weather-related loss of offsite power leading to a station blackout (SBO) with failure of the 1A EDG due to the performance deficiency and failure to recover service water with a failure to run of the 1B EDG. Following the SBO, there was initial success of turbine driven auxiliary feedwater and the reactor coolant system pilot operated relief valve, no reactor coolant pump seal LOCA, failure to recover an EDG or offsite power and late failure of AFW leading to a loss of core heat removal and core damage. The risk was mitigated by the potential recovery of service water and the relatively short exposure period. The analysis determined that the performance deficiency resulted in an increase in core damage frequency of <1 E-6/year, a GREEN finding of low safety significance.
Cross-Cutting Aspect: H.3 - The inspectors determined the finding had a cross-cutting aspect of change management in the area of human performance because the licensee failed to ensure that appropriate post modification testing was performed following a design change to the nuclear service water system.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program shall be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Procedure AD-EG-ALL-1155, Post Modification Testing, establishes the licensees post modification test control philosophy in accordance with 10 CFR 50 Appendix XI requirements for post modification related testing. Procedure AD-EG ALL-1155, states in part, that testing is intended to verify the entire operation of the SSC and demonstrate that SSCs will perform their intended functions.
Contrary to the above, as of March 11, 2019, the licensee failed to perform an adequate post-modification test to demonstrate that the 1A EDG heat exchanger would perform satisfactorily in service. Specifically, the licensee failed to identify that 1RN-P09 was in the closed position and service water flow through the 1A EDG heat exchanger was not available following a design change to the nuclear service water system. As a result, the 1A EDG was unable to perform its design function from March 11, 2019 until March 22, 2019. The licensee repaired the valve and restored service water flow through the 1A EDG heat exchanger.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Unresolved Item (URI) MSPI Data associated with failure of the 1A EDG not reported 05000413/2019002-03 71151
Description:
During an inspection conducted in the second quarter 2019, the inspectors identified that the performance indicator data for Unit 1 Emergency AC system did not include the unavailability associated with a failure of the 1A EDG during the first quarter. The MSPI unavailability was associated with an EDG heat exchanger cooling water valve 1RN-P09 being found broken and in the closed position during a surveillance test on March 21, 2019. From March 11 to March 21, cooling water to the 1A EDG was isolated and unavailable. At the time of the failure, the licensees mitigating systems performance indicator (MSPI) basis document description of the service water system did not match the actual in-plant configuration. The MSPI basis document did not show the valve in the system boundary for the EDG or cooling water system. Engineering Change 406529 was completed in August 2018 and changed the method of how cooling water was delivered to the 1A EDG when the plant was in T.S. 3.7.9, Nuclear Service Water System.
Planned Closure Actions: The residents will review the licensees justification for not reporting the total number of unavailability hours associated with the failure of the 1A EDG on March 21, 2019.
Licensee Actions: Catawba engineering reported approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> of unavailability instead of the 268 hours0.0031 days <br />0.0744 hours <br />4.431217e-4 weeks <br />1.01974e-4 months <br /> in the second quarter submittal due to the failure of the 1A EDG on March 21, 2019.
Corrective Action References: CR 2275533
Failure to Provide Complete and Accurate Information in Licensee Event Report (LER)
Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000413/2019002-04 Open
Not Applicable 71153 The inspectors identified a SL IV NOV of 10 CFR 50.9, Completeness and Accuracy of Information, for the licensees failure to provide information that was complete and accurate in all material respects in LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions.
Description:
On June 10, 2019, the licensee submitted LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions and stated that the sump pumps for all three trains of the AFW pumps are required to remain functional to support operability of the AFW pumps. The AFW System consists of two motor driven auxiliary feedwater (MDAFW) pumps and one steam turbine driven (TD) pump configured into three trains. Each AFW pump is mounted in a separate pit so each pit has a sump and safety-related sump pump of corresponding channel to prevent flooding of the AFW pump. The steam driven AFW pump pit has two sump pumps, assuming single failure of the other pump or power supply. The licensee documented that there were several instances within the last three years when the MDAFW pumps should have been declared inoperable for the corresponding times that the sump pump was out of service. Licensee Event Report 05000413/2019-002-00 states in part that On January 19, 2019, during performance of a test procedure enclosure the TDAFW pump #1 was inoperable due to both TDAFW #1 sump pumps discharge valves being closed. Additionally, both the 1A and 1B MDAFW trains were inoperable due to closing their respective sump pump discharge valves [and control hand switch taken from standby to off]. The test procedure resulted in a condition prohibited by TS with three inoperable AFW trains as action was not initiated to immediately restore one AFW train to OPERABLE status. The discharge valves were reopened [and control hand switch taken from off to standby] at a later time on the same day (January 19, 2019).
The inspectors determined that the event on January 19, 2019, met the reporting criteria for an event or condition that could have prevented fulfillment of a safety function described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 3. Section 3.2.7, states, in part, that for SSCs within the scope of this criterion, a report is required when: 1)there is a determination that the SSC is inoperable in a required mode or other specified condition in the TS Applicability; and 2) the inoperability is due to one or more personnel errors, including violations; equipment failures; inadequate maintenance; or design, analysis, fabrication, equipment qualification, construction, or procedural deficiencies, and 3) no redundant equipment in the same system was operable. The inspectors noted that following this event the test procedure was revised to require the plant to be in Modes 5, 6 or no mode, when the AFW pumps are not required to be operable. The inspectors concluded that the inadequate test procedure resulted in all three trains of the AFW being inoperable and that the licensee failed to report an event or condition that could have prevented fulfillment of a safety function as required by 10 CFR 50.73(a)(2)(v)(A), (B) and (D).
Corrective Actions: The licensee did not enter this violation into their corrective action program, and therefore the licensee had not restored compliance.
Corrective Action References: None
Performance Assessment:
Traditional Enforcement Assessment: The licensee failure to provide information that was complete and accurate in all material respects in LER 05000413/2019-002-00 was determined to impede the NRCs ability to perform its regulatory function and is dispositioned using the Traditional Enforcement process.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. Based on the examples provided in Section 6.9 of the Enforcement Policy, dated May 28, 2019, Inaccurate and Incomplete Information or Failure to Make a Required Report, the performance deficiency was determined to be a SL IV violation. Specifically, example d.10 states that a SL IV violation involves a failure to identify all applicable reporting codes on a Licensee Event Report that may impact the completeness or accuracy of other information (e.g., performance indicator data) submitted to the NRC.
Violation: 10 CFR Part 50.9(a), states that Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. Contrary to the above, on June 10, 2019, the licensee failed to provide complete and accurate information in LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions. Specifically, the LER failed to accurately state that the auxiliary feedwater sump pump condition that occurred on January 19, 2019, represented an event or condition that could have prevented fulfillment of a safety function, as required by 10 CFR 50.73(a)(2)(v)(A), (B) and (D). This information is material to the NRC because it is used to determine compliance with reportability requirements, and is used in NRC regulatory oversight functions, including licensee performance assessment, and inspection.
Enforcement Action: A Notice of Violation (NOV) is attached. This violation is being cited because the licensee failed to place it in the corrective action program to restore compliance and address recurrence consistent with Section 2.3.2 of the Enforcement Policy.
LER (Discussed)
LER 2019-002-00 for Catawba Nuclear Station, Unit 1, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions.
05000413/2019-002-00 71153
Description:
The inspectors identified a Severity Level (SL) IV NOV of 10 CFR 50.9, Completeness and Accuracy of Information, for the licensees failure to provide information that was complete and accurate in all material respects in LER 05000413/2019-002-00, Condition Prohibited by Technical Specifications due to Auxiliary Feedwater Sump Pump Conditions. This is discussed in the table above as NOV 05000413/2019002-04.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 24, 2019, the inspectors presented the integrated inspection results to Tom Simril and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
CNC-1211.00-00-
0067
Corrective Action
Documents
AR 202217202217
CR 1988325
CR 2261030
CR 2262828
CR 2263059
CR 2263179
Engineering
Changes
Revised UH DBD and TAC Sheets per AR 2050553
Miscellaneous
UFSAR Chapter 9.4 "Air Conditioning, Heating, Cooling, and
Ventilation System"
Operating Experience Summary U.S. DOE OE Summary 2016-03
Catawba White Paper "TSC A/C Functionality vs Emergency
Assessment Capability"
Catawba Program Inspection and PI Verification
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PT/1/A/4200/009
Engineered Safety Features Actuation Periodic Test
RP/0/B/5000/013
NRC Notification Requirements
Work Orders
Calculations
CNC 1223.59-01-
21
1A EDG Jacket Water to Reach 200F with No Nuclear Service
Water
Corrective Action
Documents
Drawings
CN-1609-01.00
Miscellaneous
ENG White paper - "NRC Questions about 1AEDG Calc"
Work Orders
Calculations
CNC 1223.42-00-
0089
Evaluation of Doghouse Flood on Motor Driven CA Operability
CNS-1592.CA-00-0001, Auxiliary Feedwater System (CA) Design
Basis Specification CNS-1581.WZ-00-0001, Groundwater
Drainage System (WZ) Design Basis
CNC-1206.03-00-
0001
Flood Levels For Structures outside the Reactor Building
CNC-1223.15-00-
22
Orifice Sizing for Doghouse Drains Catawba Updated Final Safety
Analysis Report (UFSAR), Chapter 11
CNC-1223.15-00-
0049
"Analysis of the Liquid Radwaste C & D Floor Drain and Auxiliary
Corrective Action
Documents
CR 01453587
CR 02270638
CR 02275149
Engineering
Changes
CD501674-add restriction/cover plates at drains in int. dh.
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Specification CNS-
1565.WL-00-0001
Design Basis Documentation for the Liquid Waste System
Procedures
PT/1/A/4700/020
WL/WN
WL/WN Sump Pumps and Check Valves lnservice Test
Rev. 18 & 15
Work Orders
WP 20322343