ML20141K661

Errata to NOV from Insp on 960324-0504.Violation Noted: Licensee Failed to Accomplish Activities Affecting Quality IAW Procedures as Evidenced by Listed Info

ML20141K661
Person / Time
Site:	Catawba
Issue date:	05/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141K638	List: ML20141K636 ML20141K661
References
50-413-96-05, 50-413-96-5, 50-414-96-05, 50-414-96-5, EA-97-179, NUDOCS 9705290279
Download: ML20141K661 (3)

Text

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NOTICE OF VIOLATION Duke Power Company Docket Nos. 50 413 and 414  :

Catawba Units 1 & 2 License Nos. NPF 35 and NPF-52 l EA 97 179 ,

During an NRC inspection conducted from March 24 through May 4, 1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures, and  ;

shall be accomplished in accordance with these instructions or procedures.

Procedure NSD 203, Operability Revision 4, effective January 1,1996, '

specifies the requirements for determining the operability status of a structure, system, or component. Paragraph 203.7.4 of NSD 203, in part, requires a 10 CFR 50.59 unreviewed safety question (USQ) evaluation if the operability evaluation concludes the system, structure, or component (SSC) is operable, but degraded. Operable, but degraded is defined in NSD 203 as situation which existed where a SSC relies on a temporary change to a design limit or design basis in order to remain operable.

Paragraph 203.9.2 of NSD 203 requires a calculation to be initiated per procedure EDH 101 to define, analyze, and document any change to a i safety related SSC which changes the design basis or design basis documents.

Duke Power Nuclear Station Directive (NSD) 209,10 CFR 50.59 Evaluation, Revision 3, effective October 1,1995, specifies the requirements for performance of reviews of changes to the facility or facility procedures to assure compliance with 10 CFR 50.59. Section 209.10.2 of NSD 209 specifies the screening process required to be performed to determine if a facility or procedure change constitutes an unreviewed safety question r (USQ) which in part requires negative answers to the following questions:

Does the activity change the facility as described in the SAR?

- Could the activity adversely affect any system, structure, or component that is necessary in accordance with the SAR?

NSD 209 defines the SAR as the set of documents used to support ,

issuance of a plant operating license. These documents include, but are not limited to, the Facility Operating License, the NRC Safety Evaluation Report, the FSAR, the Technical Specifications, and other licensing documents.

i Enclosure 2 c

9705290279 970516 PDR ADOCK 05000413 G PDR

Notice of Violation 2 Paragraph 3.10.1 of Specification No. CNS-1206.00 04 0001, Design Specification for Nuclear Safety Related (OA Condition 1) and QA l

Condition 4 Component Supports, Revision 4, dated March 1, 1995,

requires concrete expansion anchors to be designed with a minimum safety l factor of 4.0.

Section 101.4.3 of Engineering Directives Manual EDH 101.

Engineering Calculations / Analyses, Revision 4, dated March 30, l 1995, requires certification of design calculations prior to <

release of calculation results.

Contrary to the above the licensee failed to accomplish activities )

affecting quality in accordance with procedures as evidenced by l the following: )

1. The evaluations performed to determine if changing the operating temperature of the auxiliary feedwater piping  ;

involved an unreviewed safety question (50.59 screening) was i inadequate in that the negative responses to the NSD 209 )

questions were incorrect for addressing the February 21, l 1996, change to Enclosure 4.12 of procedure OP/1/A/6250/02, Auxiliary Feedwater System. Increasing the allowable I auxiliary feedwater piping temperature to 250 F changed the design of the auxiliary feedwater system. The reduction of the concrete expansion safety factor, from four to two, to permit operability of the auxiliary feedwater piping at a temperature of 250* F decreased the margin of safety and had a potentially adverse effect on the design of the auxiliary feedwater piping. NRC IE Bulletin 79 02, a licensing document, requires a minimum safety factor of four for concrete expansion anchors.

2. Engineering calculations were released prior to completion l of the design certification process required by procedure EDM 101, in that on February 21, 1996, a change to Enclosure 4.12 of Procedure OP/1/A/6250/02 was made with uncertified  ;

calculations. In changing Procedure OP/1/A/6250/02, for  !

raising the acceptable Auxiliary Feedwater suction i temperature, approved February 21, 1996, engineering calculations supporting this change were not approved until on, or after, March 5, 1996. These calculations formed the bases for approval of the procedure change.

This is a Severity Level IV violation (Supplement I). )

Pursuant to the provisions of 10 CFR 2.201, Duke Power Com)any is hereby required to submit a written statement or explanation to tie U.S. Nuclear Regulatory Commission ATTN: Document Control Desk, Washington, D.C. 20555  !

, with a copy to the Regional Administrator, Region II, and a copy to the NRC l Resident Inspector at the facility that is the subject of this Notice, within Enclosure 2 ]

Notice of Violation 3 30 days of the date of the letter transmitting this Notice of Violation  !

(Notice). This reply should be clearly marked " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the i violation, or, if contested, the basis for disputing the violation (2) the i corrective steps that have been taken and the results achieved. (3) the  :

corrective steps that will be taken to avoid further violations, and (4) the '

date when full compliance will be. achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately i addresses the required response. If an adequate reply is not received within '

the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or  :

why such other action as may be proper should not be taken. Where good cause l is shown, consideration will be given to extending the response time. ]

Because your res)onse will be placed in the NRC Public Document Room (PDR), to the extent possi)le, it should not include any personal privacy, 3roprietary, or safeguards information so that it can be placed in the PDR wit 1out redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Georgia ,

this 16th day of May 1997 1 l

j Enclosure 2 i