ML20248B779
| ML20248B779 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/26/1998 |
| From: | Berkow H NRC (Affiliation Not Assigned) |
| To: | Gordon Peterson DUKE POWER CO. |
| References | |
| TAC-MA1921, TAC-MA1922, NUDOCS 9806010378 | |
| Download: ML20248B779 (5) | |
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UNITED STATES s
- NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 30866-0001
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May 26, 1998 Mr. Gary R. Peterson Site Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745-9635
SUBJECT:
CATAWBA NUCLEAR STATION - NOTICE OF ENFORCEMENT DISCRETION (NO. 98-6-007) (TAC NOS. MA1921 AND MA1922)
)
Dear Mr. Peterson:
By letter dated May 22,1998, you requested that the NRC exercise discretion not to enforce compliance with the actions required by Catawba Nuclear Station, Units 1 and 2, Technical i
Specification (TS) Section 4.4.3.3 related to the performance, every 18 months, of a j
surveillance to demonstrate that the pressurizer heaters can be manually transferred from the normal to the emergency power supply. That letter documented information previously discussed with the staff in a telephone conversation on May 22,1998, at 8:45 a.m. (NRR Projects, NRR Division of Engineering, and Region ll personnel were present). You stated that, because the units would not be in compliance with TS 4.4.3.3, entry into TS 4.0.3 (regarding failure to perform a surveillance requirement) was made at 12:50 p.m. on May 21,1998. TS 4.0.3 requires that the subject surveillance be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and TS 3.4.3.b requires Units 1 and 2 be in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, if the surveillance cannot be completed to demonstrate operability of the pressurizer.
You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercising discretion for an operating facility, set forth in Section Vil.c, l
of the " General Statement of Policy and Procedures for NRC Enforcement Actions" l
(Enforcement Policy), NUREG-1600, and that the NOED be effective for the period until the 1
issuance of a related TS amendment.
Your staff determined that testing currently performed to satisfy TS 4.4.3.3 does not comply l
with the TS. This omission in the surveillance program has been present since the incorporation of this Three Mile Island action item into the TS, and was initially identified on October 31,1996, and documented in a problem investigation process (PIP) report. On November 6,1996, a second PIP was initiated to address how TS 4.4.3.3 was being satisfied i
by the use of overlapping procedures (see below), concluding that TS 4.4.3.3 was satisfied. On May 14,1998, as the result of a surveillance procedure working group's efforts, a third PIP was generated concluding that compliance with TS 4.4.3.3 was not being met because the present l
design of the Catawba power system will not allow the pressurizer heaters to be manually 1
transferred from the normal to the emergency source without physically manipulating individual l
supply breakers to allow a dead-bus transfer. TS 4.4.3.3, as currently written, does not reflect the plant design. A hot-bus transfer could only be accomplished by defeating interlocks and g g manipulating individual supply breakers. Testing at power using either of these methods could l
subject the units to an undesirable transient. The method Catawba has used to satisfy
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9806010378 980526 g- ( O l
PDR ADOCK 05000413 l
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G. R. Pstarson May 26, 1998 the subject requirement involves overlapping procedures PT/1(2)/A/4200/09 and
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PT/1(2)/A/4600/16. Both of these tests were performed during the last refueling outages of the
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units. One procedure verifies the emergency power supply to the load center, which supplies the pressurizer heatets, and the other verifies that the pressurizer heaters' breaker control logic is energized without actually energizing the heaters. The heaters are verified to be energized i
during both unit startup and also quarterly in accordsnca with TS 4.4.3.2.
i On the basis of the preceding information, the staff has determined that the current method of
- testing to satisfy TS 4.4.3.3 is acceptable because the underlying purpose of the requirement is to verify that the pressurizer heaters have the capability of being powered from the emergency bus irrespective of the method (manual or automatic). There are no negative safety consequences by following Catawba's current procedures, and, thus, no compensatory measures have been proposed by you.
The staff has reviewed your request and justification for the issuance of the NOED and agrees that it satisfies criterion 1(a) of the staff's guidance, and that failure to implement TS Section I
4.4.3.3 surveillance should not result in the forced shutdown of Units 1 and 2. The staff concludes that the issue does not create any concems regarding the capability of any structures, systems, or components to perform their intended safety functions. This review was performed by Om Chopra of the Engineering Division.
On the basis of the staff's evaluation of your request, the staff has conclu'ded that an NOED is
- warranted because the staff is clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Therefore, it is the staff's intention to exercise discretion not to enforce compliance with TS Section 4.4.3.3 for the period from 12:50 p.m on May 21,1998, untilissuance of a related amendment to revise the subject TS, which was requested by your letter dated May 22,'1998. This letter affirms our telephone conversation at 9:35 a.m. on May 22,1998, when the staff verbally issued this NOED.
However, as stated in the Enforcement Policy, action will normally 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, Original signed by:
i Herbert N. Berkow, Director Project Directorate ll-2 Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414 Distribution BBoger OGC Docket File JZwolinski ACRS cc: See next page PUBLIC.
JLiebermani OChopra PDll-2 RF SCollins/FMiraglia HThompson COgle, Ril e-mail BSheron LPlisco, Ril NRCWEB NOED j
DOCUMENT NAME: G:\\ CATAWBA \\CATA1921.LTR
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To receive a copy of this document, indicate in the box: "E" = Copy "N" = No copy
- See previous concurrence OFFICE PDll-2/P_lp ]
PDil-2/LA l DE/D l
Ril l
PD/f-2Dl NAME PTamWfnl LBerry*
GLainas*
COgle HiserkW DATE S'/26/98 5 /26 /98 5 / 26 /98 If2(/98 6 /#/98 OFFICIAL RECORD COPY C--conurred 67 p/ reg f'(T 1
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G. R. Peterson the subject requirement involves overlapping procedures PT/1(2)/A/4200/09 and PT/1(2)/A/4600/16. Both of these tests were performed during the last refueling outages of the units. One procedure verifies the emergency power supply to the load center, which supplies the pressurizer heaters, and the other verifies that the pressurizer heaters' breaker control logic is energized without actually. energizing the heaters. The heaters are verifed to be energized during both unit startup and also quarterly in accordance with TS 4.4.3.2.
On the basis of the preceding information, the staff has determined that the current method of testing to satisfy TS 4.4.3.3 is acceptable because the underlying purpose of the requirement is to verify that the pressurizer heaters have the capability of being powered from the emergency bus irrespective of the method (manual or automatic). There are no negative safety consequences by following Catawba's current procedures, and, thus, no compensatory measures have been proposed by you.
The staff has reviewed your request and justification for the issuance of the NOED and agrees that it satisfies criterion 1(a) of the staffs guidance, and that failure to implement TS Section 4.4.3.3 surveillance shouid not result in the forced shutdown of Units 1 and 2. The staff concludes that the issue does not create any concems regarding the capability of any structures, systems, or components to perform their intended safety functions. This review was performed by Om Chopra of the Engineering Division.
On the basis of the staffs evaluation of your request, the staff has concluded that an NOED is warranted because the staff is clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Therefore, it is the staff's intention to exercise discretion not to enforce compliance with TS Section 4.4.3.3 for the period from 12:50 p.m on May 22,1998, until issuance of a related amendment to revise the subject TS, which was requested by your letter dated May 22,1998. This letter affirms our telephone conversation at 9:35 a.m. on May 22,1998, when the staff verbally issued this NOED.
However, as stated in the Enforcement Policy, action will normally 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, f
I-e rt N. Berkow, Director 3roject Directorate 11-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414 cc: See next page
.s Catawba Nuclear Station ec:
Mr. M. S. Kitlan North Carolina Electric Membership Regulatory Compliance Manager Corporation Duke Energy Corporation P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident inspector Mr. Paul R. Newton U.S. Nuclear Regulatory Commission
. Legal Department (PB05E) 4830 Concord Road Duke Energy Corporation York, South Carolina 29745 422 South Church Street Charlotte, North Carolina 28242 Regional Administrator, Region 11 U. S. Nuclear Regulatory Commission J. Michael McGarry, Ill, Esquire Atlanta Federal Center Winston and Strawn 61 Forsyth Street, S.W., Suite 23T85 1400 L Street, NW Atlanta, Georgia 30303 Washington, DC 20005 Max Batavia, Chief North Carolina Municipal Power Bureau of Radiological Health Agency Number 1 South Carolina Department of 1427 Meadowwood Boulevard Health and Environmental Control P. O. Box 29513 2600 Bull Street Raleigh, North Carolina 27626 Columbia, South Carolina 29201 Mr. Peter R. Harden, IV L. A. Keller Account Sales Manager Manager-Nuclear Regulatory Westinghouse Electric Corporation Licensing Power Systems Field Sales Duke Energy Corporatiori P. O. Box 7288 526 South Church Street Charlotte, North Carolina 28241 Charlotte, North Carolina 28242-0001 County Manager of York County Saluda River Electric York County Courthouse P. O. Box 929 York, South Carolina 29745 Laurens, South Carolina 29360 l
Piedmont Municipal Power Agency Ms. Karen E. Long 121 Village Drive Assistant Attorney General l
Greer, South Carolina 29651 North Carolina Department of Justice P. O. Box 629 i
Raleigh, North Carolina 27602 l
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Elaine Wathen, Lead REP Planner Division of Emergency Management l
116 West Jones Street Raleigh, North Carolina 27603-1335
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Catawba Nuclear Station cc:
Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 i
Richard M. Fry, Director Division of Radiation Protection l
North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 l
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