ML20196A578

Discusses Notice of Enforcement Discretion for Duke Energy Corp Re Catawba Nuclear Station Unit 1 TSs 3.5.2 & 3.7.12

ML20196A578
Person / Time
Site:	Catawba
Issue date:	06/14/1999
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gordon Peterson DUKE POWER CO.
References
NUDOCS 9906220253
Download: ML20196A578 (5)

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, Jun'e 14, 1999 Duke Energy Corporation ATTN: V.r. G. R. Peterson

Site Vice President Catawba Nuclear Station 4800 Concord Road -

! York, SC 29745-9635'

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SUBJECT:

NOTICE OF ENFORCEMENT DISCRETlON FOR DUKE ENERGY t.

CORPORATION REGARDING CATAWBA NUCLEAR STATION UNIT 1

(NOED NO. 99-2-002)

Dear Mr. Peterson:

By letter dated June 10,1999, you requested that the Nuclear Regulatory C6mmission (NRC) exercise discretion not to enforce compliance with the actions required in Catawba Unit 1 - 1 Technical Specifications (TSs) 3.5.2 and 3.7.12. Your letter documented information previously discussed with the NRC in a telephone conference on June 10,1999, from approximately 7:30 p.m. until about 9:00 p.m. The principal NRC staff members participating in that telephone conference included Bruce Mallett, Director, Division of Reactor Safety; Charles Casto, Deputy Director, Division of Reactor Projects; Herb Berkow, Director, Project Directorate ll, Office of Nuclear Reactor Regulation and me. You stated that on June 11,1999, at 11:20 p.m., Catawba Unit 1 would not be in compliance with TS 3.5.2, Action Condition A, which required the return of the 18 centrifugal charging pump (CCP) to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. You also stated  :

that in order to accomplish the repairs necessary to retum the 1B CCP to an operable status you would not be able to comply with TS Limiting Condition for Operation 3.7.12, which govems-auxiliary building filtered ventilation exhaust system (ABFVES) operation. Specifically, you would not be able to comply with the requirement of TS Surveillance Requirement 3.7.1.2.4, which requires that one ABFVES train be capable of maintaining the emergency core cooling i system (ECCS) pump rooms at a negative pressure relative to adjacent areas. [The point that you were not able to satisfy TS Surveillance Requirement 3.7.1.2.4 and hence did not meet the {

requirements of two operable ABFVES was clarified during the telephone conference.] You . 9 i requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.C, of the

" General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement ..

Policy), NUREG-1600, and be effective for the period from 11:20 p.m., on June 11,1999, to  !

11:20 p.m., on June 15,1999. We understand that the condition causing the need for this  ;

NOED was subsequently corrected, resulting in your exit from the TSs and from this NOED on

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June 14,1999, at 4:00 a.m.

This condition was the result of the failure of the 1B CCP to provide charging flow at the desired rate. As a result, the pump was declared inoperable at 11:20 p.m. on June 8,1999, and TS , 3.5.2 was entered. Your Failure Investigation Process (FIP) Team concluded that based on

' observed conditions, the most likely cause of the problem was a failure of the 1B CCP itself.

You requested an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the expiration of the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of TS 3.5.2 to complete the repairs, operability tests, and retum the 1B CCP to service. You also requested the NRC exercise discretion in enforcing the requirements of TS 3.7.12 with respect to the ABFVES for the 1B CCP room during the time period the 1B CCP was out of service for repairs.

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j Duke Energy Corporation 2 You indicated that the exercise of discretion for TS 3.7.12 was needed to allow opening of an equipment access hatch and room doors to support repair of the 1B CCP. This was necessary, because while the hatch or the doors were open, the ABFVES would not be capable of .

establishing a negative pressure in 1B CCP room.

You stated that the following compensatory measures would be implemented:

.. The continued operability of CCP 1 A would be ensured for the period during which the request was applicable. Precautionary signs would be placed in the vicinity of CCP 1 A, diesel generator 1 A, and essential switchgear 1 ETA. The CCP 1 A breaker would be roped off as a protected area. Vibration levels associated with CCP 1A would be closely.

monitored while the NOED was in effect. Monitoring of parameters associated with CCP 1 A would be increased to twice per shift while the NOED was in effect, e Operations initiated action to review Standby Shutdown System (SSS) activation plans.

. No planned work on Train A or B ECCS components or their supporting systems would be undertaken while the NOED was in effect.

. During the period that the CCP 1B room pressure boundary was breached, appropriate compensatory measures would he established to quantify minor leakage in the room and to ensure that it remained within allowable limits.

. When the CCP 1B room door was secured open, a dedicated individual would be

. stationed at the door with instructions to close the door if a safety injection signal

occurred.'

During the telephone conversation of June 10,1999, we requested and you agreed to ensure the following conditions, in addition to those you had already identifuxt:

• The 1B room equipment access hatch would only be removed for a period of approximately 8 to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

• Following completion of 1B CCP rotating assembly replacement, testing would be performed with a single point pump curve flow verification. In addition, a full flow test of the 1B CCP will be conducted during the first outage opportunity which allows full flow testing.

Both of these conditions were documented in your letter of June 10,1999.

You provided as your safety rationale for issuing the NOED that the results of your probabilistic safety assessment indicated that the extension request would increase core damage frequency and the Large Early Release Frequency (LERF) by very small amounts. Regarding the breaching of the 1B CCP room pressure boundary, you stated that the dose analysis results would not be adversely affected and dose rates would remain within the values established by

. regulations.

- We consider that your compensatory measures and probabilistic safety assessment are appropriate to support this request. In addition, verification of your monitoring of the 1A CCP vibration levels, as well as your review of the SSS activation plan, were accomplished by the resident inspectors. These items support a conclusion that enforcement discretion should be l

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7 Duke Energy Corporation 3

. granted to avoid an undesirable transient as a result of forcing compliance with the TS; thereby minimizing the potential safety consequences and operational risks. ' 1 On the basis of the staff's evaluation of your request, we have concluded that an NOED is warranted because we are satisfied that this action involves minimal or no safety impact; is consistent with the enforcement policy and staff guidance; and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.5.2, for the period from 11:20 p.m. on June 11,1999, to 3:00 a.m. on June 15,1999.

. In addition, we will exercise discretion not to enforce compliance with TS 3.7.12 for the period

'from 9:19 p.m. on June 10,1999, to 3:00 a.m. on June 15,1999. [Given that the the 1B CCP

- was returned to service at 3:00 a.m. on June 14,1999, the NOED ended prior to the originally granted expiration.] Further, a condition to granting this enforcement discretion was that if you determined that the root cause of the event was other than a failure of the 1B CCP, or if a new problem was identified during repairs or testing that would also require that the 1B CCP be i declared inoperable, the enforcement discretion would be terminated, after which you would be required to immediately comply with TSs 3.5.2 and 3.7.12. This exercise of enforcement -!

discretion was verbally granted on June 10, .1999, at 9:19 p.m.; this letter documents the  ;

granting of that enforcement discretion; 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, I I

i (Orig'inal signed by Jon R. Johnson)

Luis A. Reyes Regional Administrator cc: Regulatory Compliance Manager i Duke Energy Corporation 4800 Concord Road

-York, SC 29745-9635 Lisa Vaughn Legal Department (PBOSE)

Duke Energy Corporation '

422 South Church Street i Charlotte, NC 28242- ,

t i Anne Cottingham Winston and Strawn  ;

- 1400 L Street,' NW . '

Washington, D. C. 20005 '

cc: .

(Cont'd on Page 4)

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-. j Duke Energy Corporation 4 1

cc: (Continued) )

North Carolina MPA-1 Suite 600 .

P. O. Box 29513 Raleigh, NC 27626 0513 Virgil R. Autry, Director Div. of Radioactive Waste Mgmt.

S. C. Department of Health and Environmental Control i

' 2600 Bull Street )

Columbia, SC 29201

, Richard P. Wilson, Esq.

' Assistant Attorney General i S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Elaine Chan 4 Federal Emergency Management Agency 500 C Street, SW, Room 840 Washington, D. C. 20472 North Carolina Electric .

Membership Corporation P. O. Box 27306 Raleigh, NC 27611 Peggy Force Assistant Attorney General N. C. Department of Justice P. Box 629 Raleigh, NC 27602 County Manager of York County York County Courthouse

- York, SC 29745 Piedmont Municipal Power Agency ,

121 Village Drive '

Greer, SC 29651 Manager. (EC050) l Nuclear Regulatory Licensing j Duke Energy Corporation 1 526 S. Church Street Charlotte, NC 28201-0006 Distribution: (See page 5)

P Duke Energy Corporation 5 Distribution: L. Plisco, Ril B. Mallett, Ril P. Tam, NRR M. Satorius, NRR B. Sheron, NRR J. Zwolinski, NRR J. Lieberman, OE M. Gamberoni, NRR R. Emch, NRR H. Berkow, NRR P. Tam, NRR 3 K. Landis, Ril R. Carroll, Ril C. Payne, Ril A. Boland, Ril PUBLIC NRC Resident inspector U.S. Nuclear Regulator Commission 4830 Concord Road York, SC 29745 E-Mail Distribution: NOED NRCWEB l

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