ML20236J742
| ML20236J742 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/11/1998 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Gordon Peterson DUKE POWER CO. |
| Shared Package | |
| ML20236J744 | List: |
| References | |
| 50-413-98-03, 50-413-98-3, 50-414-98-03, 50-414-98-3, EA-98-208, NUDOCS 9807080333 | |
| Download: ML20236J742 (5) | |
See also: IR 05000413/1998003
Text
- - - - - - - -
,
= - - - - - - - - - - - -
- _ _ - - _ - - -
.
,
4
.
..
-
(
. - .
-
June 11 L1998 :
r
-
EA 98 208-
Duke Energy Cor
ATTN: Mr. G.- R.poration.
-
Peterson
Site Vice President
e Catawba Nuclear Station
'4800 Concord Road:
York, South Carolina'.29745-
l?
.' SUBJECT:
u
(NRC INTEGRATED INSPECTION REPORT 50 413/98-03 AND 50 414/98 03)
Dear Mr..Peterson:
^
.This refers-to the inspectioniconducted on February 22, 1998, through.
l
.Aprilill,1998,'atyourCatawbaNuclearStation. The inspection included a
review of surveillance testing of the Unit 2 auxiliary building filtered
. exhaust (VA): system. The results of the-inspection were discussed with.
members ~'of your' staff at the exit meeting conducted on April 21, 1998,.and
formally transmitted to you by letter dated April 30, 1998. -An.open,
- predecisional enforcement' conference was conducted in the Region II office on
May 14, :1998,' with you and members of your staff to discuss the apparent
Jviolations, the root causes, and corrective actions-to preclude recurrence.
A list'of conference attendees, copies of the Nuclear. Regulatory Commission's
-
4
'(NRC) slides, and presentation material _ provided by Duke Energy Corporation-
- (DEC) are enclosed.
'
j
F
. Based on the information developed during the inspection and the information
,
you providad during the conference,>the NRC has determined that violations of
regulatory r uirements occurred. The violations:are cited in the enclosed
< Notice of Vio ation,(Notice),:and the circumstances surrounding them are
' described in detaillin.the subject inspection report.
I
The violations involve:' (IT failure to implement the seven-day restoration
- actions of TS 3.7.7-following a failure to satisfy Technical Specification
'(TS) surveillance requirement 4.7.7.b.3 for the Unit 2 "A" train VA. system:
j
. (2)-failure.to take prompt corrective action in accordance with 10 CFR 50,
i
Appendix B, Criterion XVI, associated with a low flow condition on the
1
Unit 2."A" train.VA system: (3) failure.to follow procedures for. system
operability determinations following surveillance testing of the Unit 2
~'A train'VA system: (4) failure to verify, as required by
)rocedure, that all'
activities described by Hinor Modification CNCE 7901 had )een implemented in
'
,
Lthe field _ before closing the ~ modification: and (5) failure to ensure that-
1
l adequate prerequisites for surveillance testing of the VA system were
established as' required by 10 CFR.50, Appendix B, Criterion XI.
i
l
9907090333 990611
'9
M
PDR-
,
' ADOCK 05000413-
hj
9-
FDR
.
-
-
-
-
-
-
--
-
-__
_-
__&
.
. _
-- __ __
_
- -_
__ _ ____ _ ____ _ ___
.
2
L
The violations can be attributed to the following root causes. DEC failed to
thoroughly examine potential degradation of the VA system _ when a low flow
condition was identified on the "A" train of the VA system in
February 1998. .In March 1998, during a required surveillance test of the
.VA system, the "A" train failed to meet the TS acceptance criteria: however.
established procedures for determining TS operability were not followed. When
the failure-to meet the TS acceptance criteria was identified and discussed
L
with DEC management, DEC management failed to promptly declare the system
l
-inoperable.
In addition, inadequacies in the surveillance procedure
'
. description of the required initial test conditions contributed to engineering
L
decisions which delayed restoration of the system to an operable status.
DEC management and staff determined that the system .vas operable because they
believed the initial test conditions were inadequate, but did not promptly
identify that appropriate initial test conditions were not specified in the
surveillance test.
' Although the. actual safety consequence associated with these violations was
minimal, the failure of management to ensure adherence to TS requirements for
!
' operability and testing of equipment is a significant regulatory concern.
In
particular, the NRC 1s concerned that management decisions with regard to the
'
operability of the VA system were non conservative and resulted in failure to
meet the TS restoration requirements. The failure of multiple barriers
involving TS adherence, surveillance testing procedures, administrative
,
L
procedures, and management oversight is a significant regulatory concern.
Therefore, these violations have been classified in the aggregate in
!
accordance with the " General Statement of Policy and Procedures for NRC
,'
'
' Enforcement Actions" (Enforcement Policy), NUREG 1600, as a Severity Level III
-
problem.
,
l
l
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $55,000 is considered for a Severity Level III problem.
Because your.
facility has not been the subject of escalated enforcement action within the
l
,last two years or two inspections, the NRC considered whether credit was
'
warranted for Corrective Action in accordance with the civil penalty
assessment process described in Section VI.B.2 of the Enforcement Policy.
!
Your corrective actions were preapt and comprehensive and included the return
i
of the VA system to operable status: the establishment of a surveillance test
'
working group: review and revision, as needed, of heating / ventilation and air
conditioning (HVAC) procedures: clarification of management expectations
regarding TS requirements; review of other HVAC modifications for closecut
. issues and expansion to this review to modifications other than
,
L
HVAC modifications; and reinforcement of modification requirements with
L
engineering personnel. Based.on these actions, the NRC concluded that credit
is warranted for Corrective Action.
'
Therefore. to encourage prompt and comprehensive correction of violations and
in recognition of the absence of previous escalated enforcement I have been
authorized,_ after consultation with the Director Office of Enforcement, not
to propose a civil penalty in this case. However, significant violations in
-the future could result in a civil penalty.
j
y<
.
J
_ _ _ _ _
_ _ _ _ _
- . _ - - -
)
3
!
In addition, as discussed at the conference, NRC Integrated Inspection
Report 50 413,414/98 03 also identified an a) parent violation for failure to
,
u)date the. Final Safety Analysis Re) ort (FSAR) following 1996 modifications to
'
tie..VA system. This modification clanged routine operation of. the VA system
from the alignment described in the FSAR, i.e., flow bypassing the HEPA and
carbon filters, to operation in the filtered mode. As described in the
Notice, this violation has been characterized at Severity Level IV.
During the predecisional enforcement conference, you indicated that the
March 23, 1998, date used in the second paragraph on page 14 of Inspection
Report 50 413.414/98 03 was in error.
You clarified that the correct date
,
l
when DEC engineering personnel began to question the basis of the conclusion
,
that the VA system was inoperable was March 24, 1998. The NRC accepts this
1
clarification, and this letter serves to correct the record in this regard.
j
,
You.are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
i
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter, its enclosures, and any response will be placed in the NRC Public
Document Room (PDR). To the extent possible, your response should not include
'
i
any personal privacy, proprietary, or safeguards information so that it can be
placed in the PDR without redaction.
If you have any questions regarding this letter, please contact Loren Plisco,
Director,. Division of Reactor Projects, at (404) 562 4501.
Sincerely,
ORIGINAL SIGNED BY JRJ
l
l
Luis A. Reyes
Regional Administrator
Docket Nos. 50 413, 50 414
License Nos. NPF 35, NPF 52
- Enclosures:
1.
,
2.
List of Conference Attendees
1
3.
NRC Presentation Material
4.
DEC Presentation Material
,
I
l
L_-
- _ - - - _ - _ - _ _ - _ _ - _ - - - - - - - - - - - - - - - _ -
-
.-
- - - - - - - - - - - -
- - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - -
_-
_ _ _ _ - _ - _ _ - _ - _ -
_- - -__- _ -
, .
L
4
.-
[-
~ cc w/encls:
'
M. S. Kitlan
North Carolina Electric
Regulatory Compliance Manager
Membership Corporation
Duke Energy Corporation
P
0. Box 27306
4800 Concord Road
=Raleigh. NC 27611
,'
'
York, SC- 29745 9635
Assistant Attorney General
Paul R. Newton
N. C. Department of Justice
y
Legal Department .(PB05E)
P. O. Box 629
'
Duke Energy Cor3 oration
.Raleigh, NC 27602
422 South Churct Street
' Charlotte NC 28242-0001
Saluda River Electric
.
Cooperative, Inc.
. Executive Director.
P. O. Box 929
. Public Staff - NCUC
Laurens, SC 29360
'P. O. Box 29520
-
-
_
Raleigh, NC -27626 0520
Peter R.-Harden IV
,
-
L
.
. Energy Systems Sales-
Account Sales Manager
J. Michael McGarry, III, Esq.
Winston and Strawn-
. westinghouse Electric Corporation
W
1400 L. Street, NW
P. 0. Box 7288
l
y
Washington, D. C.
20005
Charlotte, NC 28241-7288
County Manager of York County
Suite 600
York County Courthouse
P.'O. Box 29513
York, SC 29745
- Raleigh, NC- 27626 0513
Piedmont Municipal Power Agency
i
Chief:
121 Village Drive
. Bureau of Radiological Healtn
Greer,-SC 29651
,
S. C, Department of Health-
and environmental Control
G. A. Coppi
2600 Jull Street
Licensing --EC050
Columbia. SC 29201
Duke Energy Corporation
-
l
P. 0. Box 1006
'
Assistant Attorney General
Charlotte. NC 28201 1006
'
S. C. Attorney General's Office
P. O. Box 11549-
Columbia, SC 29211
Federal Emergency Management Agency
500 C Street,.SW, Room 840-
Washington,~D. C.
20472
..
l
l-
l
L_- _ _
_
i
-
.
--
_ _ - - _ -
-____ _ - __ _ ________ ____
!
DEC-
5
Distribution w/encls: 3
-LJCallan,-ED0
.HThompson, DEDR
1
.
!
AThadani, DEDE
,o
LChandler, DGC
~JGoldberg. 0GC-
EJulian, SECY- -
~BKeeling, CA
..
'
..
Enforcement' Coordinators
l-
-t-
RI, RIII.-RIV
LJLieberman, OE-
-
WBeecher,:OPA-
..
- "
GCaputo. 01.-
-
'
<
.TMartin, AE00 .
i
,
J
.HBell, OIG-
L
,CEvans, RII
KClark,.RII~
JJaudon RII
e BMallett, RII-
,
LPlisco, RII
CCasto, RII
C0gle. RII
' RCarroll, RII-
MTschiltz, OED0
ABoland, RII'
.PTam,.NRR. .
'
-JLusher, OE-
l0E:EA File (BSummers,~0E)(2 letterhead).
,
PUBLIC-
[
NRC'Res1' dent Inspector-
U.S.. Nuclear Regulatory Commission
-4830 Concord Road
L
. York, SC 29745
N
ft
/ F
sf.rJFMuCDoca , m r
Es
0FFICE
Ril:DRS f
RII:DjtP ' a
kII;EICS
R11:05
Ril:0RA
SW"
'
y
NAME
JJaud n
1
ABoland
CEvans
J
son
i
-(ATE h 8 /M
h/
4-
h /@ /M
b'
h/ @/M
/ /N
COPU [YES
ES[W)
Q ' ND
ES ND
(IS')
W'
. OFFICIAL SEC W (XFY FILE : N:\\19EFEN.ENF\\9820BCAT.DIR\\FINALRV. CAT
E
>
'
E.
. . .
..
-
--
-
-_ -- - ---__o