ML113560359
| ML113560359 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/22/2011 |
| From: | Croteau R Division Reactor Projects II |
| To: | Morris J Duke Energy Carolinas |
| References | |
| Download: ML113560359 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 December 22, 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. 11-2-004]
Dear Mr. Morris:
By letter dated December 19, 2011, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Catawba Nuclear Station (CNS), Units 1 and 2, Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.11, Condition E and TS LCO 3.0.3 due to issues involving the Control Room Area Chilled Water System (CRACWS).
Your letter documented information previously discussed with the NRC in a telephone conference on December 15, 2011, at 4:30 p.m., (all times discussed in this letter refer to Eastern Standard Time). The principal NRC staff members who participated in the telephone conference are listed in the Enclosure. The staff determined that the information in your letter requesting the NOED was consistent with your oral request.
You stated that on December 15, 2011, at 7:39 a.m., both units were required by TS LCO 3.7.11 to enter into TS LCO 3.0.3. TS LCO 3.0.3 required both units be placed in Hot Standby (MODE 3) by 2:39 p.m., and MODE 4 by 8:39 p.m., on December 15, 2011. Units 1 and 2 entered MODE 3 on December 15, 2011, at 2:21 p.m., and 2:22 p.m., respectively. You requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, set out in Section 3.8 of the NRC Enforcement Policy, from entering MODE 4 and MODE 5 and be effective for a period of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This letter documents our telephone conversation on December 15, 2011, at 4:30 p.m.,
when we orally issued this NOED. We understand that the condition causing the need for this NOED was corrected allowing you to exit from TS LCO 3.7.11, Condition E, from TS LCO 3.0.3, and from this NOED on December 15, 2011, at 10:36 p.m.
On December 11, 2011, at 9:50 p.m., CRACWS Train A was declared inoperable for planned maintenance to replace a non-conforming pump shaft with a conforming material. At the time, Units 1 and 2 were at 100% power operation and TS LCO 3.7.11, Condition A was entered for one train of CRACWS inoperable which required the train be restored to operable within 30 days. During the fill and vent on December 13, 2011, a cooling water leak was identified.
Actions to tighten the fitting on December 14, 2011, reduced the leakage to 5 drops per minute.
At that time the decision was made to repair the leaking fitting. This maintenance evolution was
DEC 2 originally scheduled to be completed on December 15, 2011, at 7:00 p.m. On December 15, 2011, at 7:20 a.m., CRACWS Train B unexpectedly tripped and was declared inoperable at 7:39 a.m. TS LCO 3.7.11 Condition E was entered for both trains of CRACWS being inoperable which required immediate entry into TS LCO 3.0.3. TS LCO 3.0.3 required that both units be placed in MODE 3 within seven hours and MODE 4 within the following six hours. Both units were shutdown and placed in MODE 3. A NOED was requested from compliance with TS LCO 3.0.3 which required that both units be placed in MODE 4 within six hours.
The NRC determined that the requested NOED was necessary to reduce shutdown risk as a result of compliance with the license condition by avoiding system realignment that is inconsistent for plant conditions in that it does not provide an overall safety benefit (Part 9900, Section B.2.1, criterion 2). The NRCs basis for this discretion considered: (1) your commitment to brief each shift on procedure AP-39, Control Room High Temperature, (which provides actions for a loss of both trains of CRACWS) to maintain control room temperature, (2) the availability of the Standby Shutdown Facility (SSF) and Turbine Driven Auxiliary Feedwater (TDAWF) pump in MODE 3, (3) your commitment to defer non-essential maintenance activities for the duration of the enforcement discretion period, (4) 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, (5) that the noncompliance reduced shutdown risk by maintaining availability of the SSF and TDAFW pump, and (6) independent verification of some of these conditions and actions by our inspection staff.
The NRC staff based their decision to exercise enforcement discretion on a qualitative assessment of risk. Since CRACWS is not explicitly represented in any PRA model, a quantifiable risk assessment was not feasible. However, your mitigation actions for a loss of the CRACWS function, the availability of the SSF and TDAFW pump in MODE 3, and eliminating elective maintenance of all risk significant systems during the duration of the enforcement discretion reduced shutdown risk. Consequently, these actions provided reasonable assurance that the 5.0E-7 core damage frequency and 5.0E-8 large early release frequency guidance thresholds in Inspection Manual Part 9900 Technical Guidance were not exceeded.
You committed to submit a permanent license amendment to address operability requirements of CRACWS following NRC approval of TSTF-426, Revise or Add Actions to preclude entry into LCO 3.0.3, NRC approval of WCAP-16125, Rev. 1, Justification for Risk Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown, and submittal by the Technical Specification Task Force of the corresponding Traveler applicable to Westinghouse plants (currently under development) and subsequent NRC approval of this Traveler.
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 staff guidance and has no adverse impact on public health and safety or the environment. Therefore, as we communicated to you at 6:00 p.m., on December 15, 2011, we exercised discretion to not enforce compliance with TS LCO 3.0.3 for the period from 8:39 p.m., on December 15 until 8:39 a.m., on December 16, 2011.
However, we understand you only used approximately two hours of the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requested.
DEC 3 As stated in the Enforcement Policy, action may 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,
/Dan Rich RA for/
Richard P. Croteau, Director Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52 cc w/encl: (See page 4)
___ML113560359____ G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:ORA RII:DRA NRR:DORL SIGNATURE Via email Via email DWR /RA for/ Via email Via email SDW /RA for/ Via telecom NAME CRapp JBartley RCroteau WJones JMunday DChung AHowe DATE 12/21/2011 12/21/2011 12/22/2011 12/21/2011 12/21/2011 12/21/2011 12/21/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE NRR:DORL RII: DORL RII:DRP RII:DRP SIGNATURE Via email Via email NAME JStang GKulesa DATE 12/21/2011 12/22/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO DEC 4 cc w/encl: David A. Cummings George T. Hamrick Associate General Counsel Station Manager Duke Energy Corporation Catawba Nuclear Station Electronic Mail Distribution Duke Energy Carolinas, LLC Electronic Mail Distribution Beth J. Horsley Wholesale Customer Relations Tanya M. Hamilton Duke Energy Corporation Engineering Manager Electronic Mail Distribution Catawba Nuclear Station Duke Energy Carolinas, LLC Sandra Threatt, Manager Electronic Mail Distribution Nuclear Response and Emergency Environmental Surveillance Steven B. Putnam Bureau of Land and Waste Management Safety Assurance Manager Department of Health and Environmental Catawba Nuclear Station Control Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution Division of Radiological Health Randy D. Hart TN Dept. of Environment & Conservation Regulatory Compliance Manager 401 Church Street Duke Energy Carolinas, LLC Nashville, TN 37243-1532 Electronic Mail Distribution David A. Repka David A. Baxter Winston Strawn LLP Vice President, Nuclear Engineering Electronic Mail Distribution General Office Duke Energy Carolinas, LLC County Manager of York County Electronic Mail Distribution York County Courthouse P. O. Box 66 M. Christopher Nolan York, SC 29745-0066 Fleet Safety Assurance Manager Duke Energy Carolinas, LLC Piedmont Municipal Power Agency Electronic Mail Distribution Electronic Mail Distribution Charles J. Thomas Vanessa Quinn Fleet Licensing Manager Federal Emergency Management Agency Duke Energy Carolinas, LLC Radiological Emergency Preparedness Electronic Mail Distribution Program 1800 S. Bell Street Luellen B. Jones Arlington, VA 20598-3025 Fleet Licensing Engineer Duke Energy Carolinas, LLC Electronic Mail Distribution Lara S. Nichols Vice President-Legal Duke Energy Corporation Electronic Mail Distribution
DEC 5 Letter to J. R. Morris from Richard P. Croteau dated December 22, 2011
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR CATAWBA NUCLEAR STATION [NOED NO. 11-2-004]
Distribution w/encl:
C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC A. Adams, NRR RidsNrrPMCatawba Resource
List of Participants Joel Munday, Acting Regional Administrator, RII Rick Croteau, Director, Division of Reactor Projects (DRP), RII William Jones, Deputy Director, DRP, RII Jonathan Bartley, Chief, Reactor Projects Branch 1 (RPB1), DRP, RII George Hutto, Catawba Senior Resident Inspector, RPB1, DRP, RII Ronald Cureton, Catawba Resident Inspector, RPB1, DRP, RII Allen Howe, Deputy Director, Division of Operator Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)
John Stang, Oconee Project Manager, Plant Licensing Branch II-2, (LPL2-2) DORL, NRR Gloria Kulesa, Chief, LPL2-1, DORL, NRR Donald Chung, Reliability and Risk Analyst, Division of Risk Assessment, NRR Sheldon Stuchell, Senior Project Manager, Licensing Processes Branch, DPR, NRR Enclosure