ML20236Q203
| ML20236Q203 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/09/1998 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-413-98-03, 50-413-98-3, 50-414-98-03, 50-414-98-3, EA-98-208, NUDOCS 9807200065 | |
| Download: ML20236Q203 (10) | |
Text
___-___________ ________________ - __ _____ _ _ _ _ __ _ _ _ _ _ _ _____ - -
e e
Duke Power
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Catawba Nwlear Station E
4800 Concord Road l
m e., c.,,
l York. SC 29745 Gary R. Peyerson (803) 831-4251 omCE Vice 1%sident (803) 831-3426 ux July 9, 1998 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
Subject:
Duke Energy Corporation Catawba Nuclear Station l
Dockets 50-413 and 50-414 Reply to Notice of Violation (NOV)
Inspection Report 50-413, 414/98-03 (EA 98-208)
I Pursuant to the provisions of 10 CFR 2.201, attached is Duke Energy Corporation's response to a Notice of Violation dated June 11, 1998.
Inspection Report 50-413, 414/98-03 i
(EA 98-208) identifies six violations.
A Level III l
problem, identifies 5 violations regarding the actions associated with the Auxiliary Building Ventilation System.
L A Level IV violation, identifies a failure to update the i
UFSAR to include a modification performed in 1996.
These l
violations were identified during an NRC inspection period between February 22, 1998 and April 11, 1998.
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Duke Energy Corporation acknowledges these violations.
I Section 3 in each response lists the only regulatory commitments associated with this response.
If there are any questions concerning this response, please contact M.
S. Purser at (803) 831-4015.
Sincerely, t
s' '
j G.
R.
Peterson l
Attachment
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Nuclear-Regulatory Commission July 9, 1998 Page'2 xc:
Mr.'Luis A.
Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission l
Atlanta Federal Center 61 Forsyth St.,
Suite 23T85 Atlanta, Georgia 30323 j
P.
S. Tam i
U.S.
Nuclear, Regulatory Commisston
' Office of Nuclear Reactor Regulation One White Flint North, Mail Stop 9H3 Washington, D.
C.
20555 D.
J.
Roberts Senior Resident Inspector Catawba Nuclear Station j
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Catawba Nuclear Station Reply to Notice of Violation Statement of Violation 50-413,414 (EA 98-208 A-E)
(01013,01023,01033,01043,01053)
During an NRC inspection' conducted on February 22, 1998, through. April 11', 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 3.7.7 Auxiliary Building Filtered Exhaust System, requires that two trains of the Auxiliary Building Filtered Exhaust (VA) system shall be' operable during Modes 1-4.
With one train of
.the VA system inoperable, the inoperable train shall be restored to operable status within 7 days or the reactor shall be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
l Technical Specification Surveillance Requirement j
4.7.7.b.3 states that each train of the VA system shall be demonstrated operable by verifying a system flow rate of 30,000 cubic feet per minute (cfm) +/- 10%
during system operation when tested in accordance with ANSI N510-1980.
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Contrary to the above, on March 16, 1998, the Unit 2 A-train VA system was inoperable in that the system flow rate was 26,129 cfm during surveillance testing in accordance with ANSI N510-1980; however, the licensee failed to implement the seven-day restoration actions of Technical Specification 3.7.7 until March 25, 1998.
As a result, Unit 2 remained in Mode 1 with the A-train i
VA system inoperable for nine days. (01013)
B.
10 CFR Part 50, Appendix B, Criterion XVI, as implemented by Duke Power Company Topical Quality l
l-Assurance Program (Duke-1-A), requires, in part, that measures be established to ensure that conditions adverse to quality, such as failures and nonconformances, are promptly identified and corrected.
I Technical Specification. Surveillance Requirements 4.7.7.b.3, 4.7.7.e, and 4.7.7.f address system testing i
requirements in accordance with American National I
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I Standards Institute (ANSI) Standard N510-1980.
Testing of Nuclear Air Cleaning Systems.
ANSI N510-1980,- Testing of Nuclear Air Cleaning Systems, states that testing of the air cleaning. system is an integral part of the licensee's Quality Assurance Program, and that surveillance tests are used to monitor the condition of associated-systems.
The ANSI standard'also provides that an airflow capacity test
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acceptance criterion shall be within +/- 10% of system design flow.
Contrary to the above, on February 9, 1998, during surveillance testing of the Unit 2 B-train VA system, the licensee identified a low airflow condition associated with the Unit 2 A-train VA system, but failed to promptly correct the low flow condition.
Consequently, on March 16, 1998, the Unit 2 A-train VA system failed to meet an airflow acceptance criterion of 30,000 cubic feet per minute'(cfm) +/- 10% during an 18-month surveillance test required by TS 4.7.7.
(01023).
C.
Technical Specification 6.8.1.a requires that written procedures'be. established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide-1.33, Revision 2. As referenced, this includes. administrative and surveillance procedures.
Nuclear System Directive (NSD) 203, Operability, Revision 10, Appendix A.
203.
Operability Policy for Previously Identified Items, defines the licensee's policy governing failed TS surveillance tests as follows: "Upon initial discovery of a failed surveillance, the affected system, subsystem, train, l
component or device shall be declared inoperable and the applicable TS action statement entered."
Nuclear System Directive (NSD) 203, Operability, Revision 10, Section 203.9.1. General Requirements, states that notification to Operations (Operations Shift Manager) shall be accomplished by completion of Appendix E, Operability Notification Form, as described by this directive.
Surveillance procedure PT/0/A/4450/01C, Auxiliary Building Filtered Exhaust Filter Train Performance Test, approved May 5, 1986, Step 12.2.1.4.2, applies to surveillance tests of the auxiliary building filtered exhaust (VA) system whereby acceptance criteria have
l not been met and states, " Notify the Shift Supervisor, Performance Engineer and the Licensing Engineer, and
'have the system (equipment) declared inoperable in accordance with its LCO in Tech. Specs."
Contrary to the above, administrative and surveillance procedures were not implemented as evidenced by the following examples:
1.
On March 16, 1998, the Unit 2 A-train VA system was not declared inoperable following a surveillance test during which system performance failed to meet TS surveillance acceptance criteria; and L
2.
On March 16, 1998, a formal, documented operability notification was not provided to the Operations Shift Manager following the March 16, 1998, VA system surveillance test failur. ( 1033)
D.
Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2. As referenced, this p
includes general procedures for the control of modification work.
1 Catawba Nuclear Station Modification Manual, Revision 15, Section 5.6.2, states, that prior to returning the I
Minor Modification
(. M) Work Orders to the Operational M
Control Group for Return-To-Service, the Implementation Accountable or MM Originator shall verify that all activities as described by the MM have been implemented in the field or a Variation Notice written to revise the MM's scope accordingly.
Contrary to the above, the licensee failed to verify that all activities described by Minor Modification i
CNCE-7901 (Resolution of System VA Filtered Exhaust Low Air Flow Concerns) had been implemented in the field before closing the modification on December 23, 1996.
l As a result, three flow straighteners in the Unit 2 A-train auxiliary building filtered exhaust (VA) system j
that should have been removed by CNCE-7901 were left i
installed until removed on March 25, 1998. (01043)
E.
10 CFR Part 50 Appendix B, Criterion XI, Test Control, as implemented by Duke Power Company Topical Quality Assurance Program (Duke-1-A), states that a test program shall be established to ensure that all testing
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j required to demonstrate that structures, systems and components will perform satisfactorily in service.
' Test procedures shall include provisions for assuring, in part, that all prerequisites for the given test have l
been met.
L As referenced in Technical Specification 4.7.7, American National Standards Institute (ANSI) Standard N510-1980, Section 4.2, Test Procedures, states that test procedures shall identify, among other things, the arrangement or clearances that have to be made prior to the test and the prerequisites that have to be met.
Contrary to the above, surveillance test procedure PT/0/A/4450/01C, Auxiliary Building Filtered Exhaust Filter Train Performance Test, approved May 5,
- 1986, did not establish a prerequisite controlling system configuration (pertaining to the status or position of various interfacing systems and components) for performance of the test.
As a result, a consistent, repeatable test methodology had not been. established to ensure that system performance trends were reliable
+
indicators of flow degradation. (01053)
These violations represent a Severity Level III problem (Supplement I).
Response to Violation EA 98-208 A-E (01013,01023,01033,01043,01053)
Duke Energy Corporation acknowledges the five violations.
The violations, root causes and corrective actions were discussed with the NRC at a Predecisional Enforcement Conference in Atlanta on May 14, 1998, and a summary of this discussion was docketed in a Notice of Violation from the NRC to Duke Energy Corporation dated June 11, 1998.
This violation response will summarize the information presented and update corrective actions.
- 1. Reason for Violation These violations can be attributed to the following root causes.
Duke failed'to thoroughly examine potential degradation of the Auxiliary Building Ventilation (VA)
System when a low flow condition was identified in February 1998.
In March 1998, during a required surveillance test, the "A" train failed to meet the Technical Specification (TS). acceptance criteria, however, the established procedures for determining TS operability were not followed.
A discussion of the low flow condition was held, resulting l
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in a failure to promptly declare the system inoperable.
Additionally, inadequacies in the surveillance procedure's
" description of the initial test alignment contributed to decisions which delayed restoration of the system to operable status.
Specifically, Duke determined the system to be operable because it was believed the initial test to be invalid. It was not promptly identified that the initia' test alignment was not adequately specified in the surveillance test.
The modification that was to correct the low flow condition on VA "A" train was signed off as complete without thorough verification.
Corrective actions to later complete the modification were not timely.
- 2. Corrective Actions Taken and Results Achieved l
Immediate corrective actions included removing the flow straighteners in the VA ductwork, originally identified in the modification CE-7901.
The system was then retested and returned to operable status.
All Operations, Engineering, and Safety Assurance employees were trained to reinforce Management expectations regarding i
TS requirements as they relate to operability.
A self assessment of Operability Evaluations has been completed.
The review identified weaknesses in the luations and additional training has been scheduled as e_
described in Section 3 of this response.
In the interim, management review and sign off on Operability Evaluations is required.
A surveillance test working group was established to review surveillance program requirements for systems governed by Technical Specifications.
Priorities were set based on safety significance.
A preliminary review identified issues which have been entered into the Corrective Action Program for tracking and resolution.
A complete review was performed of the heating / ventilation and air conditioning (HVAC) procedures.
Deficiencies have been identified and entered into the Corrective Action Program for tracking and resolution.
Modification Manual requirements were reinforced with
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Engineering.
Other HVAC modifications were reviewed for closeout issues.
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- 3. Corrective Actions to be Taken to Avoid Future Violations
'HVAC' Procedures will be revised'as needed to meet the standards currently _ expected at the site for mechanical system procedures.
Training is scheduled for groups in the Engineering Support Training Program in August 1998 to refresh knowledge of Operability and cover changes to Nuclear Station Directive (NSD) 203, Operability, and to communicate lessons learned from'recent NRC inspections and self-assessments.
A follow-up self assessment will be performed on Operability Evaluations to determine the effectiveness of the corrective actions.
A'second surveillance test working group has been established and will review surveillance program requirements for the Improved Technical Specifications
.(ITS).
The modification review will be expanded beyond the scope of ventilation modifications for closecut issues.
Discrepancies will be entered into the' Corrective Action Program.
- 4. Date of Full Compliance Duke Energy is in full compliance.
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Statement of Violation 50-413,414 (EA 98-208 F) (02014)
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[F.
'10'CFR Part 50.71(e)' states that each person licensed to operate a nuclear power reactor shall periodically l
update the-Final Safety Analysis Report (FSAR) to ensure that'the information included in the FSAR contains the latest material developed.
The updated FSAR shall.be revised to include the effects of, in part, all changes made in the facility as described in o
the FSAR.
Contrary to the above, as of April 9, 1998, the licensee failed.toJensure that changes made during 1996 modifications CNCE-61117 and CNCE-61118 to the auxiliary building filtered exhaust (VA) system to routinely operate the VA system in the filtered mode were reflected in revisions to the applicable sections (7. 6.12.1 and 7. 3.1.1.1) of the updated FSAR. (02014)
This is-a Severity Level'IV violation (Supplement I).
Response to Violation EA 98-208 F (02014)
Duke acknowledges the violation. The modifications, CE-61117
.and CE-61118'were implemented at the plant and not incorporated into the-UFSAR.
Duke is currently undergoing a reverification of the UFSAR, as documented in a letter from Duke Energy to the NRC. Document Control Desk, Plans for Assuring the Accuracy and Completeness-of the UFSAR, dated June 16, 1997.
Although this issue was NRC identified, Duke believes that the discrepancy would have been identified by
.the reverification team under the defined scope, j
thoroughness and schedule of the initiative.
The chapters have been prioritized, and the review of the two chapters affected by the modifications are in progress.
- 1. Reason for Violation Modifications CE-61117 and CE-61118 were implemented in 1996 at Catawba' Nuclear Station to document that the Auxiliary Building Filtered Exhaust System would be routinely operated in the filtered mode.
The changes were submitted to the i
Regulatory Compliance group at Catawba for inclusion in the
.UFSAR and the 10CFR50.59 Annual Report.
The changes were incorporated in the 10CFR 50.59 report but not the UFSAR.
l During 1996, the update process was not as effective for tracking and monitoring changes to the UFSAR.
A Tracking Tool to document pending UFSAR changes has been implemented
l since early'1997 and the UFSAR and 10CFR50.59 reports
,rece1ve more thorough engineering oversight.
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- 2. Corrective Actions Taken and Results Achieved The changes to the.UFSAR resulting from modifications CE-i 61117 and CE-61118 have been immediately incorporated into the UFSAR Program Tracking Tool for pending changes.
A review of other HVAC modifications has been performed to l
insure any UFSAR changes were included.
A UFSAR Reverification Group has been established at Catawba l
since early 1997.
UFSAR chapters have been prioritized based on safety significance and both chapters affected by this modification are in progress.
Prior to this violation, Duke noted that using different individuals to maintain the 10CFR 50.59 Annual Report and the UFSAR Revision introduced the opportunities-for errors and missed information.
Currently, one individual is responsible for maintaining records for both data bases.
Relevant information comes to one person and is handled one time.
Improvements have already been noted.
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- 3. Corrective Actions to be Taken to Avoid Future Violations L
The changes to the UFSAR per modifications CE-61117 and CE-l 61118 will be incorporated in the next UFSAR update.
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- 4. Date of Full Compliance Duke. Energy is in full compliance.
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