ML20134P472
| ML20134P472 | |
| Person / Time | |
|---|---|
| Site: | Catawba |
| Issue date: | 02/18/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mccollum W DUKE POWER CO. |
| References | |
| EA-97-036, EA-97-36, NUDOCS 9702250478 | |
| Download: ML20134P472 (6) | |
See also: IR 05000413/1997004
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February 18, 1997
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EA 97-036
Duke Power Com]any
ATTN:
Mr. W.
1. McCollum
Site Vice President
Catawba Site
1
4800 Concord Road
York. South Carolina 29745-9635
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION
(NRC INSPECTION REPORT NOS. 50-413. 414/97-04)
This letter refers to an inspection conducted during the period January 6
through 23, 1997, at your Catawba Nuclear Station.
During the inspection, the
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NRC examined the facts and circumstances surrounding your identification of a
design deficiency associated with the Unit 1 and 2 Auxihary Feedwater (AFW)
System.
On January 9, 1997, you submitted Licensee Event Report (LER)
No. 50-413/96-012 following the determination that the AFW system was outside
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its design basis.
Subsequently, on January 17, 1997. Revision 1 to the LER
was submitted to provide additional information and corrective actions.
Our
review of this issue is discussed in detail in the subject inspection report
transmitted to you by letter dated January 31, 1997.
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Based on the information develo)ed during the inspection, the NRC has
determined that a violation of 1RC requirements occurred.
Specifically, from
initial construction of Units 1 and 2 until December 11. 1996, measures were
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not established to correctly translate the design basis of the AFW system
.
described in the Final Safety Analysis Report. Section 9.2.1 into
specifications, drawings, and procedures for the Nuclear Service Water (NSW)
System (the assured water source for the AFW system) resulting in the
requirements of Technical Specification (TS) 3.7.2.1 not being met for both
,
units.
Because the AFW systems' assured source lacked adequate train
separation, a single, active failure of one of the two assured source suction
valves (1/2RN-250 or 1/2RN-310) would render all three AFW pumps for the
associated unit inoperable under certain conditions.
Specifically, with all
three AFW pumps running with high flow demand ar,a a loss of the normal suction
sources (non-safety related), a single failure of one of the two assured
source suction valves would cause the remaining train of the assured source to
attempt to supply all three AFW pumps. This would result in inadequate net
positive suction head to all three pumps, rendering them inoperable.
In accordance with the " General Statement of Policy and Procedures for
Enforcement Actions" (Enforcement Policy). NUREG-1600. this violation normally
would be categorized as a Severity Level III violation.
However, as discussed
in Section VII.B.3 of the Enforcement Policy. the NRC may refrain from issuing
a Notice of Violation (Notice) and proposing a civil Jenalty for a Severity
Level III violation that involves a past problem, suc1 as an old engineering.
design, or installation deficiency, provided that certain criteria are met.
OFFICIAL COPY
.nno.3
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9702250478 970218
ADOCK 05000413
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After review of this violation and consultation with the Director, Office of
Enforcement the NRC has concluded that the criteria for enforcement
discretion have been met. Therefore, to encourage licensee efforts to
,
identify and correct subtle violations before degraded safety systems are
called upon to function, no Notice is being issued in this case. The specific
bases for this decision are: (1) you identified the violation during a
licensee-initiated design review conducted in support of a modification:
,
(2) although voluntary self-initiated technical audits had beer 1 performed for
both the AFW =and NSW systems, it was not unreasonable tha' these audits did
not identify the deficiency earlier, and it is unlikely the deficiency would
have been identified by routine surveillances or quality a surance audits:
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(3) timely and appropriate modifications were completed to mstall check
valves in locations to resolve the deficiency: (4) timely and effective
corrective actions were implemented, and appropriate long-term corrective
actions to review and identify any similar design deficiencies in the systems
interfacing with the Standby Shutdown System were delineated; and (5) the
design deficiency occurred at the time of plant construction and is not
reasonably linked to present engineering performance.
This letter serves to document the closure of the ap)arent violation
(eel 50-413 and 50-414/97-04-01) described in the su) ject inspection re) ort
and completes the NRC's action in this matter. No formal response to t1is
letter is required.
In accordance with 10 CFR 2.790 of the NRC's " Rules of
Practice," a copy of this letter will be placed in the NRC Public Document
Room.
If you should have any questions regarding this letter, please contact
Mr. Charles Casto. Chief Branch 1. Division of Reactor Projects, at
404-331-5506.
Sincer ly,
,
.
Luis A. Reyes
Regional Admin &s rator
Docket Nos. 50-413, 50-414
cc:
M. S. Kitlan
Regulatory Compliance Manager
Duke Power Company
4800 Concord Road
York. SC 29745-9635
cc:
(Cont'd on Page 3)
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cc (Cont'd):
j
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Paul R. Newton
Legal Department (PB05E)
Duke Power Company
422 South Church Street
Charlotte, NC 28242-0001
Robert P. Gruber
Executive Director
Public Staff - NCUC
P. O. Box 29520
Raleigh. NC 27626-0520
J. Michael McGarry, III. Esq.
.
Winston and Strawn
1400 L Street. NW
D. C.
20005
North Carolina MPA-1
Suite 600
,
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P. O. Box 29513
Raleigh. NC 27626-0513
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Max Batavia, Chief
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Bureau of Radi.ological Health
S. C. Department of Health
and Environmental Control
.
2600 Bull Street
Columbia, SC 29201
Richard P. Wilson. Esq.
Assistant Attorney General
S. C. Attorney General's Office
P. O. Box 11549
i
Columbia. SC 29211
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Michael Hirsch
Federal Emergency Management Agency
,
500 C Street. Sw. Room 840
,
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Washington, D. C.
20472
cc:
(Cont'd on Page 4)
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cc (Cont'd):
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North Carolina Electric
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Membership Corporation
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P. O. Box 27306
Raleigh NC 27611
Karen E. Long
Assistant Attorney General
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N. C. Department of Justice
P. O. Box 629
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Raleigh. NC 27602
Saluda River Electric
Cooperative. Inc.
,
P. O. Box 929
Laurens. SC 29360
Peter R. Harden IV
Account Sales Manager
Power Systems Field Sales
Westinghouse Electric Corporation
P. O. Box 7288
C.larlotte. NC 28241
County Manager of York County
York County Courthouse
York. SC 29745
Piedmont Municipal Power Agency
121 Village Drive
Greer. SC 29651
G. A. Copp
Licensing - EC050
Duke Power Company
P. O. Box 1006
Charlotte. NC 28201-1006
T. Richard Puryear
Owners Group
North Carolina Electric
Membership Corporation
4800 Concord Road
York. SC
29745
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