ML110620718
| ML110620718 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/03/2011 |
| From: | Croteau R Division Reactor Projects II |
| To: | Morris J Duke Energy Carolinas |
| References | |
| Download: ML110620718 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 March 3, 2011 Mr. J. R. Morris Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745-9635
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR CATAWBA NUCLEAR STATION [NOED NO. 11-2-002]
Dear Mr. Morris:
By letter dated March 1, 2011, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Catawba Nuclear Station (CNS), Unit 1, Technical Specification (TS) Limiting Condition for Operation (LCO) 3.8.1, Required Action B.4, TS LCO 3.7.8, Required Action A.1, TS LCO 3.7.5, Required Action B.1, and TS LCO 3.6.6, Required Action A.1. Your letter documented information previously discussed with the NRC staff in a telephone conference on February 25 at 3:00 p.m. (all times refer to Eastern Standard Time).
The principal NRC staff members who participated in the telephone conference are listed in the Enclosure. The NRC staff determined that the information in your letter requesting the NOED was consistent with your oral request.
You stated that, on February 23 at 4:32 a.m., the 1B diesel generator (DG) was declared inoperable due to problems experienced during its TS-required 24-hour run. Unit 1 entered into TSs listed above and the 72-hour completion time associated with the actions would have expired on February 26 at 4:32 a.m. At that point, Unit 1 would have been required to be placed in Mode 3 by 10:32 a.m., Mode 4 by 4:32 p.m., and Mode 5 by February 27 at 4:32 p.m. You requested that a NOED be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, set out in Section 3.8 of the General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy), NUREG-1600, and that the NOED be effective until February 28 at 4:32 a.m. This letter documents our telephone conversation on February 25 at 4:55 p.m., when we orally granted this NOED request. We understand that the condition causing the need for this NOED was corrected, allowing CNS to exit from the TSs listed above and from this NOED on February 27 at 2:54 p.m.
On February 22, the 1B DG was started to perform a 24-hour test. Approximately fifteen hours into the test, the DG experienced voltage, power factor, and load swings outside the normal control band and was shut down and declared inoperable. TS LCO 3.8.1 was entered due to the inoperability of the 1B DG. TS LCO 3.7.8 was affected because the 1B DG is required to be operable for the Nuclear Service Water System (NSWS) Train 1B to be considered operable.
TS LCO 3.7.5 and TS LCO 3.6.6 were also affected due to the inoperable NSWS train.
Following additional evaluation, you determined that the mechanical governor was the cause of the problem. You performed a common mode failure evaluation and determined that the problem was not transportable to the other three DGs. You also initiated a Unit Threat Team and performed a replacement of the mechanical governor.
DEC 2
The NRC staff determined that the requested NOED was necessary to avoid an unnecessary transient as a result of compliance with the license conditions and, thus, minimize potential safety consequences and operational risks (Part 9900, Section B.2.1, criterion 1.a). The NRC staffs basis for this discretion considered: (1) your commitment to defer non-essential surveillances and other maintenance activities in the switchyard to reduce the likelihood of a loss of offsite power; (2) your commitment to defer non-essential surveillances and other maintenance activities on risk-significant equipment including the 1A DG, the auxiliary feed water (AFW) turbine-driven pump, and the Standby Shutdown System; (3) your posting of a dedicated operator available to throttle key AFW valves that supply flow to the steam generators prior to the depletion of the vital batteries, thereby preventing steam generator overfill and thus protecting the steam supplies to the AFW turbine-driven pump; (4) your plans to complete maintenance on the 1B DG, conduct required testing, and perform required system realignments in order to restore to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; (5) that your calculated Incremental Conditional Core Damage Probability and Incremental Conditional Large Early Release Probability values did not exceed the threshold guidance provided in Inspection Manual Part 9900 Technical Guidance and were consistent with values calculated by NRC regional analysts; (6) that the cause and proposed path to resolve the situation were understood such that there was a high likelihood that planned actions to resolve the situation could be completed within the proposed NOED time frame; (7) that the noncompliance would not be of potential detriment to the public health and safety; and (8) independent verification of some of these conditions and actions by our inspection staff.
On the basis of the NRC staffs evaluation of your request, we have concluded that granting this NOED is consistent with the Enforcement Policy and NRC staff guidance and has no adverse impact on public health and safety or the environment. Therefore, as we informed you at 4:55 p.m., on February 25, 2011, we exercised discretion to not enforce compliance with TS LCO 3.8.1, Required Action B.4, TS LCO 3.7.8, Required Action A.1, TS LCO 3.7.5, Required Action B.1, and TS LCO 3.6.6, Required Action A.1 for the period from 4:55 p.m., on February 25, 2011, until 4:32 a.m., on February 28, 2011. As stated during the conference call and in your letter, you have determined that a follow up license amendment is not necessary; however, you plan to perform a design study to evaluate extended TS Completion Times for the DGs and associated equipment. The NRC staff agrees with this determination.
As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely,
/William B. Jones RA for/
Richard P. Croteau, Director Division of Reactor Projects Docket No.:
50-413 License No.: NPF-35 cc w/encl: (See page 3)
__ML110620718 __
G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP NRR:DORL SIGNATURE JHB /RA/
WBJ /RA for/
Via email NAME JBartley RCroteau JGitter DATE 03/03/2011 03/03/2011 03/03/2011 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO
DEC 3
cc w/encl:
Division of Radiological Health TN Dept. of Environment & Conservation Electronic Mail Distribution Randy D. Hart Regulatory Compliance Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Dept of Health and Environmental Control Electronic Mail Distribution Dhiaa M. Jamil Group Executive and Chief Nuclear Officer Duke Energy Carolinas, LLC Electronic Mail Distribution C. Jeff Thomas Fleet Regulatory Compliance & Licensing Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Kathryn B. Nolan Senior Counsel Duke Energy Corporation 526 South Church Street-EC07H Charlotte, NC 28202 Lara Nichols Associate General Counsel Duke Energy Corporation Electronic Mail Distribution David A. Repka Winston Strawn LLP Electronic Mail Distribution North Carolina MPA-1 Suite 600 P.O. Box 29513 Raleigh, NC 27525-0513 Piedmont Municipal Power Agency Electronic Mail Distribution Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Mark Yeager Division of Radioactive Waste Mgmt.
S.C. Department of Health and Environmental Control Electronic Mail Distribution W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Vanessa Quinn Federal Emergency Management Agency Radiological Emergency Preparedness Program 1800 S. Bell Street Arlington, VA 20598-3025 Steve Weatherman, Operations Analyst North Carolina Electric Membership Corporation Electronic Mail Distribution County Manager of York County York County Courthouse P. O. Box 66 York, SC 29745-0066 Peggy Force Assistant Attorney General State of North Carolina P.O. Box 629 Raleigh, NC 27602 David A. Baxter Vice President, Nuclear Engineering Duke Energy Carolinas, LLC Electronic Mail Distribution
DEC 4
Letter to J. R. Morris from Richard P. Croteau dated March 3, 2011
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR CATAWBA NUCLEAR STATION [NOED NO. 11-2-002]
Distribution w/encl:
C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMCatawba Resource
Enclosure List of Participants NRC REGION II ATTENDEES Rick Croteau, Director, Division of Reactor Projects (DRP), Region II (RII)
Jonathan Bartley, Chief, Reactor Projects Branch 1 (RPB1), DRP, RII John Hanna, Senior Risk Analyst, Engineering Branch 2 (EB2), Division of Reactor Safety (DRS), RII Andy Hutto, Catawba Senior Resident Inspector, RPB1, DRP, RII NRC HQ ATTENDEES Joseph Gitter, Director, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)
John Stang, Acting Branch Chief, LPL2-1, DORL, NRR Jon Thompson, McGuire NRC Project Manager, LPL2-1, DORL, NRR Jeff Mitman, Senior Reliability and Risk Analyst, PRA Operational Support Branch, Division of Risk Assessment, NRR Margaret Stambaugh, Reliability and Risk Analyst, PRA Operational Support Branch, Division of Risk Assessment, NRR Roy Matthew, Acting Branch Chief, Electrical Engineering Branch (EEEB), Division of Engineering (DE), NRR Matt McConnell, Senior Electrical Engineer, EEEB, DE, NRR Ken Miller, Electrical Engineer, EEEB, DE, NRR Prem Sahay, Electrical Engineer, EEEB, DE, NRR Sheldon Stuchell, Senior Project Manager, Licensing Processes Branch, Division of Policy and Rulemaking, NRR