ML20012C371
| ML20012C371 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/06/1990 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012C370 | List: |
| References | |
| 50-413-90-05, 50-413-90-5, 50-414-90-05, 50-414-90-5, NUDOCS 9003210134 | |
| Download: ML20012C371 (34) | |
Text
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ENCLOSURE 1 NOTICE OF VIOLATION Duke Power Company Docket No. 50-413 Catawba Unit 1 License No. NPF-35 During the Nuclear Regulatory Comission (NRC) inspection conducted on January 3.1990 through January 23, 1990, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions." 10 CFR Part 2. Appendix C. (1989), the violation is set forth below:
10 CFR 50. Appendix B. Criterion XIV. Inspection Test and Operating Status, as implemented by Duke Power Company Topical Report Quality Assurance Program. Duke-1-A. which incorporates in part. section 5.2.6 of ANSI N18.7-1976 ANS-3.2 requires that procedures be provided for control of equipment as necessary to maintain reactor safety and avoid unauthorized operation.
These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status.
Contrary to the above, procedures to maintain reactor safety and avoid unauthorized operation of the IB Containment Air Return Fan Power Lockout Breaker were inadequate in that the power lockout breaker was not controlled to preclude unauthorized operation.
As a result, the power lockout breaker was opened sometime during the period October 23, 1989, to January 3,1990, causing the IB Containment Air Return Fan to be inoperable with no indication of the condition available in the control room.
The fan remained inoperable for an indefinite period of time until it failed a required surveillance test on January 3.1990.
This is a Severity Level IV Violation and applies to Unit 1 only (SupplementI).
Pursuant to the provisions of 10 CFR 2.201. Duke Power Company is hereby required to submit a written statement of explanation to the Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington, DC 20555 with a copy to the Regional Administrator. Region II and a copy to the NRC Resident Inspector within thirty (30) days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the violation.
(2) the reason for the violation if admitted. (3) the corrective steps which have been taken and the results achieved. (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance 9003210134 900306 PDR ADOCK 05000413 g
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'. A Duke Power Company 2
Docket No. 50-413 Catawba Unit 1 License No. NPF-35 will-be achieved.
Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action-as may be proper should not be taken.
FOR THE NUCLEAR REGULATORY COMMISSION J
/
/-
/ btAQ/ neterWE tewart D. E Regional Administrator Dated at Atlanta, Georgia this 6th day of Mar.
1990 l
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LIST OF ATTENDEES U.S. Nuclear Regulatory Commission S. D. Ebneter.' Regional Administrator _ Region 11 l'
C.W.Hehl.DeputyDirector.DivisionofReactor_ Projects (DRP)
E. Merschoff. Deputy Director. Division of Reactor Safety-(DRS)
D. B. Matthews. Director, Project Directorate 11-3. NRR G. R. Jenkins. Director. Enforcement and Investigation Coordination Staff-
-(EICS):
- A. R. Herdt. Branch Chief. DRP'
- R. J. Goddard. Regional Counsel. Ril W. T. Orders. Senior Resident Inspector. Catawba K. Jabbour. Catawba Project Manager. NRR M. S. Lesser. Resident Inspector Catawba B. Uryc. Senior Enforcement Coordinator. EICS B. R. Bonser. Project Engineer. DRP J. Lieberman - Office of Enforcement Duke Power Company H. B. Tucker. Vice President.' Nuclear Production-
'T. B. Owen. Catawba Station Manager R. -N. Casler. Operations Superintendent. Catawba
-R. G.. Morgan Regulatory Compliance R. M. Glover. Catawba Compliance Manager J. E. Thomas. Design Engineering
-G.!B. Swindlehurst. Engineering Supervisor H. R._ Starling. Private Consultant for Duke Power Company I
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r ENCLOSURE 3 ENFORCEMENT CONFERENCE
SUMMARY
On February 22, 1990, representatives from Duke Power Company (DPC) met with the NRC in the Region II Office in Atlanta, Georgia to discuss ths inoperability of the IB Containment Air Return Fan (CARF) and the circumstances surrounding the opening of the power lockout breaker to the fan.
Following opening remarks by Stewart Ebneter, Region II Regional Administrator, DPC gave a presentation (Enclosure 4) on the issue.
DPC's presentation covered a description of the Containment Air Return Fan and Containment Pressure Control System, a sequence of events, three theories on the root cause, corrective actions, and a safety evaluation.
In summary, DPC made five major points:
There was no conclusive root cause identified; however, due to the evidence gathered, they felt strongly about " Theory C."
Duke's corrective actions address all three root cause theories.
The safety significance of the fan inoperability was low.
The incident was licensee identified, promptly reported and non-recurring.
Operability of the CARF was assured prior to return to service.
Hal Tucker, Vice President, Nuclear Production Department closed Duke's presentation with his comments.
He stated that he found two things disturbing about this issue;- they could not identify with certainty the cause of the fan inoperability and that there are people in the plant whose conduct iridicates a lack of regard for the plant.
However, no evidence had been found to indicate that the breaker was intentionally opened.
He stated that Duke will continue to try to identify these individuals.
The NRC closed the meeting by stating that Duke's presentation had served to enhance. Region II's understanding of this issue and their corrective actions.
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i ENCLOSURE 4 9
i DUKE POWER COMPANY 1
CATAWBA NUCLEAR STATION 7
ENFORCEMENT CONFERENCE CONTA N AIR RETURN FAN (CARF) BREAEER FOUND OPEN FEBRUARY 22, 1990 Iratroductiosa.
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B.
Oesora 4
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Thansee Systems Descriptions Sequennom Of Everste T.
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Oesers Root Caussee Ttneory A maad B R.
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Camler Theory C T.
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Oeseera,
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Shar'11 rig Corrective Actioram T.
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Oesora Thi ete Sa +
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AIR RETURN FAN
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AIR RETURN SUBSYSTEM RETURN AIR TO THE LOWER COMPARTMENT FOLLOWING THEINITIAL BLOWDOWN FROM AN HELB.
L CONTAINMENT PR ESSUR E CONTROL SYSTEM l
PROTECT CONTAINMENT FROM NEGATIVE PRESSURE BY PREVENTING INADVERTENT OR EXCESSIVE
. OPERATION OF CONTAINMENT PRESSURE REDUCING l
SYSTEMS & EQUIP 51ENT.
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CATAWBA NUCLEAR STATION SYSTEM DESCRIPTION Containment Air Return Fan (CARF) and Containment Pressure Control System CPCS l
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+ 60.0 UPPER RANE OF CONTANENT PRESSLRE GAUES-
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5.0 LPPER RANT OF CPCS GAUGE 3.0 Sp SIGNAL GENERATED "Hi-Hi' CONTAll*ENT PRESSLEE PSIG O.55 O.45 ON INCREASING PRESSLRE WITH CONCLARENT Sp (3.0 PSIG) SIGNAL CARF STARTS O.35 0.25 ON DECREASING PRESSURE, CARF STOPS O.15 0.05 O.O l
l-5.0 LOWER RANGE OF CPCS GAUGE i
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SIMPLIFIED SCHEMATIC FOR
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The Design Has a Shortcoming From an Operat
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- Inadvertent Opening of the CPCS Breaker will Co Ei the Design for The Control Room Indication j';
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- Design Documentation Does Not Alert Station to
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for Compromise ofIndication i
Breakers Now Locked - Design Evaluation O ngoing 6
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i DUKE POWEll COMPANY CATAWRA NUCLEAR STATION ENFVRNMENT CONFERENCE FEBRUARY 22, 1990 J
Sequence of Events i
10/23/09 CARF-1B operated succlessfully during Quarterly PT 11/16/89 SSPS A Train tes. ting (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) 11/17/89 CPCS A Train testing (1) hours) 12/11/89 A Train Air Returu Fan testing (3) hours) 12/15/89 CPCS A Train testing (1) hours) 01/02/90 D/G A Train testing (4 houro) r 01/03/90 CARF-1B felled to start during testing. Work Request 7353PRF (2X) was written to investigate.
Breaker on 1EXN iound cpen by 1AE i
MES and IAR reviewed breaker pooltion and confirmed the breaker was definitely open, not tripped. This was also verified by OPS.
Af ter extensive review, the breaker was closed and the test i
ccupleted.
A review plan was developed by OPS to determine if the l
breaker had been opened improperly through the nEl process. This work was ccupleted at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on 01/04/90.
i Station Manager was called by OPS and t.ied in the Coupliance Manager to revi w pregress.
After extensive review, Station Manager caH ed D(sign to re-visit the probability of the breaker tripping due to a failure and passing thrcmgh the trip position and saoving to the cpen position. This of fort was exhausted with no change of earlier understanding.
01/04/90 OV8 called Station Manager at hame tc infore hisa of a second breaker found open on Unit 2, 577' elevation, Conte,inraent Floor and Equipment Susp Punp.
Station Manager called Security to discuss the thresheld of entering Catawba's Saboteur Plan. We agreed that at that time we should not go into that plan based on the pattern of events and the non-safety function of Unit 2's equi; ment.
We agreed to increase survelliance in the Auxiliary Building.
4 e
i OUKE POWER COMPANY CATAWRA NUCLEAR STATION l
ENFORCEMENT CONFERP.NCE FEBRUARY 22, 1990 gequence_Of Events i
01/04/90 Station Manager called OPS and agreed that OPS Management
)
should join Security in the review at the plant.
(Station l
Manager could not go due to an intestinal virus.)
becision was also hade that all safety-related breakers in the Emergency Switchgear Rooms would be inspected for tampering.
Ser.ior NRC Resident was called and made aware of the j
situntion and he concurred with actions taken.
2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />, Security and OPS reported that kH.wMing was found above both breakera which had been opened. Pictures were taken and materials saved for forensic review. This indicated that actions other than sabotage had potentially caused the opening of the breakers and we ended our search j
for the night.
01/5/90 Station Manager discussed the pictures at morning meeting and asked supervision to account for their personnel during the period between 0700 and 1900 on 01/04/90. Shared pictures, info and disbelief 01/08/90 Requested investigation help frono Keith Shannon, Manager, Corporate Security.
01/09/90 Steve Canaler, Investigator, arrived on site. Took collection of evidence to Forensic Analytical Services and Testing, Inc.
01/11/90 Pinger prints were collected at breaker locations.
e 01/15/90 Print expert examined prints. Eliminated Security / Operations personnel involved in discovery / collection. Found three (3) suspect prints.
01/17/90 Met with Legal and Human Resource representatives.
Reference options of polygraph, finger print collection and interviewing. Interview option selected.
Identified all personnel in RCA on 01/04/90. Sent Dose Cards to Raleigh, North Carolina to examine finger prints.
01/22/90 Questions developed and meetings with Supervisors.
Currently evaluating responses for follow up.
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l INVESTIGATION TO DETERMINE ROOT CALSE e
THEORY "A" - Breaker was intentionally or unintentionally tagged open for maintenance i
THEORY "B" - Breaker was opened as part of a procedure, test or by mistake THEORY "C" - Breakers were opened by persons climbing to access cable trays
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1 Breaker was intentionally or unintentionally tagged open for maintenance Investigation revealed (September '89 through January '90 period)
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- Breaker was not intentionally tagged
- No breaker on the entire motor control center was tagged
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- Breaker for the CARF was not tagged l
- Breaker for both.CARFs on Unit 2 were not tagged I
This breaker is never the breaker tagged to perform i
any work
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No work request on this component or the opposite train, other unit's components were issued or signed on i
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THEORY "B" Breaker was operated as part of a procedure, test or by mistake Investigation revealed (September '89 through January '90 period)
- Breaker is located in a remote corner of the room i
- No procedure or test was conducted that would have had an employee operate any component or breaker j
in this area l
- Performance test for this component requires cycling l
the fan's damper breaker
- Lockout breaker is not mentioned or used in the l
test l
- Signoffs and interviews confirm proper breaker l
was cycled l
- Damper breaker is not located in this area of the plant
- Opposite train and wrong unit scenarios were investigated - same conclusions were reached
- Same column line, wrong elevation scenarios were investigated - same conclusions were reached a
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DUER IN COMPANY CATAWBA NEM* LEAR STATION ENFORCEMENT CONFummuar**
CONTAIENEENT RIR RETURN FAN (CARP) BREAEER FOsman opsg FKumDARY 22, 1990 CORRECTIVE ACTI M i
Immmediate i
I CARF 1B hreaker fanated mand reclomand; l
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IAE/ OPS Periodic Tomt terumsp l eted j
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Submascnnessat Fourad h=nint i rag =hreven 1ENIN mand 2NEN 5.
Security Evaluated +==pr==tas
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O p e r a t i r ws==
evaaluante may poterstini issolat4 -=
Issasuend operastne Updsstem oma lockoust 7.
Oswratir===
breaanserm arad teroung snes4 t / ser u n g oc _ a==-
L isaasuess SPR vritten S.
Operanti anas l
Revimos of teso (2) hromaanseras in asserinas y PT 9.
Operatir=s=
developend 10.
Sancurity
- Haradoes caratrol Sa=ame ch for h=rism
- 11. E-Maec Additiornal astapemrvimices; othenr groupas
- 12. E-Munc evaluatend = 1 =mr=
L eben'ti ran 1ENEM mastri 2MEM " N Ur-r. m SAFETT l
- 13. Projecta RELETED" i
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- 14. Statiora Ngurt.
Diascuamasiassas with asupemrviarioen Invaartigantican = rani intervieseen
- 15. Statiora Ngus t.
Evaaluated effect on Ooones arsd McGuire;
- 16. Demmign Eng.
notified Ocormee arad Moeni.ro i r===
- 17. Desigra Erag.
- Evaaluetend m--ihles r=======
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of the CARF 1B b r eantr e r
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DUEE POWER L W &WY CAT & WHA MRAER STATICBE l
FJEFORCEBMGPF CONFEREIDCE COEFTAN AIR RETURN FAB (CARF) BREREER FOsmann opsgg FEBRUARY 22, 1990 l
CORRECTIVE ACTIONS Planzanammet Additir===1 labeling /programr-for 1 = h = 2.
1.
Operatinnam/
pesairstorm-ences massint====nemos 2.
Pro-)ectas/
Evaluates SPR for remni satiosa of karmetrar,
Deasigra Reag.
lasmuse A periodic inaspenctices of rsah'l e 3.
E-90sec/
Statican ptspart.
treym; Stasticus will r e v i emes tknas ressultas 4.
Operations Trainirag oss possume lockout broenkerm l
l Continue. issveastigasthwaro S.
Statior 98 gest.
Eve 3umte ttsee enamend for protectiosi l
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Stantiora Peguurt.
of certain elem-trical brounkerw 1
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I SAFETY EVALUATION DELAYED ACTUATION OF VX FANS
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e DESIGN FUNCTION OF VX FANS
-e FSAR CONTAINMENT RESPONSE 1
e W ANALYSIS OF LOCA CONTAINMENT RESPONSE WITHOUT VX FANS e
EQ EVALUATION i
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e DESIGN FUNCTION OF VX FANS e
ACTUATE 10 MINUTES AFTER A HIGH-ENERGY LINE BREAK INSIDE CONTAINMENT e
PROVIDE FORCED CIRCULATION OF STEAM / AIR FROM UPPER CONTAINMENT TO LOWER CONTAINMENT - THIS FORCES THE STEAM / AIR THROUGH THE ICE CONDENSER e
THE MAIN FUNCTION OF THE VX FANS IS TO COOL LOWER CONTAINMENT - THERE ARE NO SPRAYS IN LOWER CONTAINMENT e
THE IMPACT OF THE SITUATION OF CONCERN IS A DELAY IN VX FAN ACTUATION FROM 10 MINUTES TO EITHER 50 OR 85 MINUTES (FOR THE PERIODS OF TIME ilHERE BOTH WERE OUT OF EERVICE)
- 50 MINUTES IS BASED ON RESTORir;G THE "A" TRAIN FAN FROM f
A TEST CONFIGURATION
- 85 MINUTES IS BASED ON RESTORING THE "B" TRAIN FAN BY DIAGNOSING THE OPEN BREAKER AND CLOSING IT
- STATION EP REQUIRES VERIFYING FAN ACTUATION F0LLOWING AN S SIGNAL (3 PSIG) p
- A FAILURE OF BOTH TRAINS OF A SAFETY SYSTEM WOULD BE RECOGNIZED AS A HIGH PRIORITY CONCERN
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FSAR CONTAINMENT RESPONSE l
i LD.CA (FIGURES 1 & 2) e RAPID PRESSURIZATION FOLLOWING PIPE RUPTURE e
SPRAYS ACTUATE IMMEDIATELY AT 3 PSIG e
VX FANS ACTUATE AT 10 MINUTES i
e SWITCH SAFETY INJECTION AND SPRAYS TO SUMP RECIRCULATION MODE e
ALIGN RHR CONTAINMENT SPRAYS AT 50 MINUTES e
ICE MELT 00T AT li191 SECONDS e
PEAK PRESSURE lit.0 PSIG AT 7308 SECONDS e
PEAK TEMPERATURE BOUNDED BY STEAM LINE BREAK STEAM LINE BREAK (FIGURE 3) l e
PEAK TEMPERATURE OCCURS PRIOR TO 10 MINUTE VX FAN ACTUATION e
MASS AND ENERGY RELEASE DECREASING AT 10 MINUTES - ALL l-FEEDWATER ISOLATED e
PEAK PRESSURE BOUNDED BY LOCA I
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i FIGURE 1 CONTAINMENT PRESSURE VS. TIME CATAk'BA FSAR 1
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a FIGURE 2 CATAWBA FSAR L WER COMPARTMENT TEMPERATURE VS TIME j
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FIGURE 3-CATAWBA FSAR - STEAM LINE BREAK 40 l'
LOWER COMPARTHENT
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N&lNSTREAM ISOLATION V ALVE F ALLURE PEAK TEMPERATURE: 3M.8*F Eg_ 200 I
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PEAK CONTAINMENT SUPERHEAT DURATION TRANSIENT e CATAWBA Pd) CLEAR Figure '6. 2.1-16
- .8^a W ANALYSIS OF LOCA CONTAINMENT RESPONSE WITHOUT VX FANS 1
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REALISTIC BOUNDARY CONDITIONS WERE ASSUMED e
ASSUMED VX FANS UNAVAILABLE e
RESULTS (FIGURES 4 & 5) SHOW THAT THE PEAK CONTAINMENT PRESSURE STILL OCCURS AFTER ICE MELT 00T AND IS LESS THAN THE DESIGN PRESSURE
- ICE MELTOUT AT ~150 MINUTES
- PEAK PRESSURE AT 213 MINU1ES a
NO NEGATIVE IMPACT ON CONTAINMENT PRESSURE RESPONSE e
CONTAINMENT TEMPERATURE RESPONSE BOUNDED BY STEAM LINE BREAK CONCLUSION:
N0 IMPACT ON LOCA IF THE VX FANS DELAY INCREASES FROM 10 TO 50 OR 85 MINUTES
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c EQ EVALUATION e
SINCE VX FANS COOL LOWER CONTAINMENT POST-ACCIDENT, A DELAY IN THE RATE THAT LOWER CONTAINMENT COOLS DOWN WILL RESULT e
THE CURRENT LOWER CONTAINMENT TEMPERATURE PROFILE FOR EQ EVALUATION IS THAT RESULTING FROM THE STEAM LINE BREAK (SHORT TERM) AND LOCA (LONG TERM) e WITH A VX FAN DELAY OF 50 OR 85 MINUTES, THE EQ TEMPERATURE PROFILE CAN BE CONSERVATIVELY ESTIMATED AS (FIGURE 6):
JJ11E IEEERATURE l
0 - 10 MIN CURRENT PROFILE (SLB) 0 10 - 50 MIN 320 F (SLB) 0 50 - 85 MIN 230 F (LOCA)
>SS MIN CURRENT PROFILE (LOCA) e EQUIPMENT IN LOWER CONTAINMENT WAS EVALUATED BASED ON THIS TEMPERATURE PROFILE CONCLUSION:
NO UNACCEPTABLE IMPACT ON ANY EQUIPMENT IF THE VX FAN DELAY INCREASES FROM 10 TO 50 OR 85 MINUTES l
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DUKE IWER COMPANY CATAWBA NGCTKAR STATION ENFORCENEBFT CONFERENCE COBrTA N AIR RETURN FAN (CARF) BREAEER FOUBE) O P EED FEBRUARY 22, 1990
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i SUpWERRY 1.
No conclussive root causse "Thann= y C"
hoe circummertential evidonom 2.
Corrective acticasst addresses el_1 three tisemorinas fl.
Safety asignificance testas lose
= = = = 11osansonne 16enas tifind, prostptly
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Then inci h t reporteed and nors-recurring 5.
Operability of then CARF sesmas measured prior to returra to spearviosa i
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4 DUKE POWER CCBEPANY C&T&b8BA 300 CLEAR STATICEI KMFORCERGEEFT CONFEREBBCE CougTA N AIR RETURN FAN (CARF) BREAKER FOUIED OPHER F atsten U A R Y 22, 1990 crruEm IssauEst 1.
Lamott of Coratrol Rom Issdioetirwmm Corrective actin =an diascummed prurvionnelyJ L o cta n d tar e eds e r e, OPS t r = 4 =*4=== esad nur=n=tanes,
.i SPR writtees 2.
Switetspensaal a a 3 ixag Carrective actiosse dissonemanal prervicuatly ;
r.=%1as
-,en w, programmans for oorst-1 eraumd massinaturasence i
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3.
Protecticas of P1=nt Equips.amart Corrective actinnan discu M previousslyy Stations Wr=====t to ovaluate ttne tseest fcar protections of c>wn.-* = 4 ** hreamlae ras froma dessuego or Enedvenetent operming 4.
Cable Trey Bandas Corrective actinnan di ancusassed pruovio===1y; Revieste to ben penrforismed stad Stastiora t
to evaluate roastaltas for tsan=====ey actican i
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