ML20217G555

Notice of Violation from Insp on 980111-0221.Violation Noted:Licensee Failed to Perform Written Safety Evaluation for Closing Valves 1CA-6 & 2CA-6

ML20217G555
Person / Time
Site:	Catawba
Issue date:	03/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20217G543	List: ML20217G540 ML20217G555 ML20217G566
References
50-413-98-01, 50-413-98-1, 50-414-98-01, 50-414-98-1, EA-98-134, NUDOCS 9804020415
Download: ML20217G555 (4)

Text

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NOTICE OF VIOLATION Duke Energy Corporation Docket Nos. 50-413. 50-414 Catawba Nuclear Station License Nos. NPF-35. NPF-52 EA 98-134 During an NRC inspection conducted from January 11, 1998 - February 21. 1998, violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedures for NRC Enforcement Actions,"

NUREG-1600, the violations are listed below:

A. . Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained for applicable procedures in Appendix A to Regulatory Guide 1.33. Quality Assurance Program Requirements (Operation). Revision 2. 1978. As referenced, this includes procedures for unit startup operation, and shutdown as well as administrative procedures governing procedure use and adherence.

Procedure OP/2/A/6100/02. Controlling Procedure for Unit Shutdown, approved November 25, 1996, Step 2.31 directed the control room operator to close the discharge isolation valves associated with the four cold leg accumulators (CLA).

Procedure OP/1/A/6200/009. Cold Leg Accumulator Operation Revision 61.

Step 2.3.3. directed the control room operator to close valve 1NI-118A, safety injection pump 1A cold leg injection isolation valve, prior to starting the associated A-train safety injection pump to fill the cold leg accumulators.

Operations Management Procedure (OMP) 1-4 Use of Procedures. Revision 59 Section 8.1.N. stated "unless specified by a procedure, an automatic signal shall att be defeated from performing its intended function."

Section 8.4.E of OMP 1-4 further stated that a decision not to perform a step in a procedure must be documented in the procedure. Section 9.6 of OMP 1-4 also stated that, whenever an abnormal [ operating] procedure (AP) is used, a Procedure Evaluation Form shall be completed and forwarded along with the completed procedure to the Operations Support Manager to provide feedback to ensure that APs are kept current and usable.

Operating Procedure OP/2/A/6450/020. Containment Chilled Water System, Revision 32 Step 2.2.1 required that, when swapping to a third chiller unit, operators stop one of the operating chiller units.

Enclosure 1 9804020415 980323 PDR ADOCK 05000413 G PDR

NOV 2 Contrary to the above, procedures were not implemented as written as evidenced by the following examples:

1. On December 16, 1996, the CLA isolation valves were not closed during a Unit 2 shutdown to Mode 5 as directed by OP/2/A/6100/02.

As a result, all four CLAs discharged into the reactor coolant system (RCS) when RCS pressure reached the discharge pressure setpoint during system cooldown to Mode 5.

2. On December 29, 1997, during performance of OP/1A/6200/009 to fill Unit 1 CLAs, the operator at the controls inadvertently missed Step 2.3.3 and failed to close valve 1NI-118A. As a result, the A-train safety injection pump injected water into the RCS.

3. On December 29, 1997, during performance of Abnorinal Procedure AP/1/A/5500/05. Reactor Trip or Inadvertent Safety Injection Below P-10, Revision 16. Unit 1 control room operators defeated an automatic main feedwater isolation when reactor trip breakers were opened to induce a manual reactor trip. Control room operators also failed to document a decision not to perform Step 29.a. which directed them to manually initiate feedwater isolation, by marking the step N/A and providing the initials of an approving SRO. along with a description of the reason for the deviation. Control room operators also failed to provide feedback regarding the inap3ropriateness of feedwater isolation after a trip from Mode 4 in tie Procedure Evaluation Form.

4. On February 3,1998. Unit 2 operators failed to stop one of the operating chiller units before starting a third chiller unit, as required by step 2.2.1 of OP/2/A/6450/020. This resulted in tripping the two operating chillers and causing chiller system temperature to increase from 42 degrees to the alarm setpoint of 60 degrees Fahrenheit.

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

B. 10 CFR 50.59 states that the licensee may make changes to the facility as described in the safety analysis report, or make changes in the procedures as described in the safety analysis report without prior Commission approval unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question. The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these char:ges constitute changes in the facility as described in the safety analysis report (or the procedures as described therein). The records must include a written safety evaluation which provides the bases for the determination that the change does not involve a unreviewed safety question.

NOV- 3 Updated Final Safety Analysis Report Section 10.4.9 Auxiliary Feedwater System (CA), subsection 10.4.9.2, which described the suction sources for the CA system, stated that "all of the preferred sources of condensate quality water are normally aligned to the CA pump suctions,"

It further stated 'to maintain steam generator water chemistry, especially for such fast recovery events-as [ station] blackout loss of

' normal feedwater, or main steam system malfunction, the CA pumps should be normally aligned to condensate quality water. All necessary means to prevent inadvertent injection of out-of-chemistry nuclear service water to the steam generators must be employed. Such detection and transfer controls are automatic since CA system flow must be established within one minute from the initiating event."

Contrary to the above, from May 15, 1997, to February 21, 1998, the

' licensee failed to perform a written safety evaluation for closing valves ICA-6 and 2CA-6, the suction valves from the Unit 1 and 2

- auxiliary feedwater condensate storage tanks. This isolated the auxiliary feedwater condensate storage tanks from the auxiliary feedwater pump suctions. These valves were closed as a compensatory measure in response to concerns related to air entrainment into the auxiliary feedwater system. The auxiliary feedwater condensate storage

~ tanks are described in the Updated Final Safety Analysis Report as normally aligned to the auxiliary feedwater pump suctions.

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

Pursuant to the provisions of 10 CFR 2.201. Duke Energy Company is hereby required to submit a written statement or explanation to the 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 Resident Inspector at the Catawba facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the 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,-1f the correspondence adequately 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 is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

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NOV '4 Because your response will be placed in the NRC Public Document Room

.(PDR), to the extent possible. it should not include any personal privacy. 3roprietary, or safeguards information so that it can be placed.

in the PD1 without redaction. If personal privacy or proprietary

-information is necessary to provide an acce) table response, then please

provide a bracketed copy'of your response tlat identifies the informa-tion that should be protected and a redacted copy of your response that?

deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for.your claim of withholding.(e.g., explain why the disclosure of information will create

^ an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards

.information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia

.this 23rd day of March, 1998 i

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