ML102220252

NOED 10-2-003

ML102220252
Person / Time
Site:	Catawba
Issue date:	08/09/2010
From:	Reyes L Region 2 Administrator
To:	Morris J Duke Energy Carolinas
References
Download: ML102220252 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 9, 2010 Mr. J. R. Morris Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745-9635

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR DUKE ENERGY CAROLINAS REGARDING CATAWBA NUCLEAR STATION [NOED NO. 10-2-003]

Dear Mr. Morris:

By letter dated August 2, 2010, you requested that the NRC exercise discretion to not enforce compliance with the following: (1) Technical Specification (TS) 3.8.1, Required Action B.4; (2)

TS 3.7.8, Required Action A.1; (3) TS 3.7.5, Required Action B.1; and (4) TS 3.6.6, Required Action A.1. Your letter documented information previously discussed with the NRC in a telephone conference on July 29, 2010, at 3:00 p.m. The principal NRC staff members who participated in that telephone conference are listed in the Enclosure. You stated that on July 30, 2010, at 2:00 a.m., the plant would not be in compliance with the TSs listed above which would require Unit 1 to be placed in Mode 3 by 8:00 a.m., on July 30, 2010, and in Mode 5 by 2:00 p.m.,

on July 31, 2010. You requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.C, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period from July 30, 2010, at 2:00 a.m., to July 31, 2010, at 2:00 a.m. This letter documents our telephone conversation on July 29, 2010, at 3:00 p.m., when we orally issued this NOED. We understand that the condition causing the need for this NOED was corrected by you, causing you to exit from the TSs and from this NOED on July 30, 2010, at 3:08 a.m.

In January 2010, Catawba observed that the exhaust cylinder temperature for the number 6 cylinder on the right bank (6R) of Diesel Generator (DG) 1A was reading approximately 300 degrees Fahrenheit lower than normal. Administrative processes were initiated to investigate and resolve the issue. Also, a review of the respective temperature data for the other 16 cylinders that had not exhibited changes showed this to be only an indication problem. On May 19, 2010, Problem Investigation Process (PIP) C-10-02963 was generated for Catawba. The purpose of this PIP was to ensure that the work request/order that had been previously initiated was performed in a timely manner to allow accurate trending of DG data, which is used to support engine reliability and operability. DG cylinder exhaust temperature data is used as one input to help determine the functionality of the fuel injection system. In response to this PIP, work order 01920283 was scheduled for the next planned DG work day on July 27, 2010. DG 1A was removed from service and declared inoperable at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on July 27, 2010, in support of the planned DG workdays activities.

DEC 2 While performing work to replace the DG 1A number 6R cylinder exhaust thermocouple, the end of the thermocouple was found severed. The total probe length was approximately 4 and approximately 3/8 in diameter. The Operations Shift Manager was notified of the as-found condition and PIP C-10-04459 was generated. Attempts to locate the thermocouple probe with a boroscope were not successful. Plant management convened a Unit Threat Team and plans were developed to remove the turbocharger to support locating the thermocouple probe. The broken piece was subsequently found in one piece (i.e., it had not broken into smaller pieces) in the stationary vane of the right bank turbocharger. There was no damage to the turbocharger.

To determine the cause of the thermocouple failure, the failed thermocouple and two other non-failed thermocouples from DG 1A were sent to Duke Energys metallurgical laboratory for analysis. The analysis showed that the cause of the thermocouple failure was mechanical fatigue due to high-cycle, low-amplitude, cyclic stresses typical of vibration. The other two thermocouples showed no signs of degradation.

The NRC determined that the requested NOED was necessary to avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks (Part 9900, Section B.2.1, criterion 1.a). The NRCs basis for this discretion considered: (1) all related B train equipment was operable; (2) that Duke deferred non-essential surveillances and other elective maintenance activities in the switchyard where human error could contribute to the likelihood of a Loss of Offsite Power; (3) that Duke deferred non-essential surveillances and other elective maintenance activities on risk-significant equipment including DG 1B, the turbine-driven auxiliary feed water pump, and the standby shutdown system; (4) that Duke personnel communicated with the System Operations Center once per shift regarding the unit status and the need to maintain grid stability during the period of enforcement discretion; (5) that Dukes calculated Incremental Conditional Core Damage Probability and Incremental Conditional Large Early Release Probability values did not exceed the threshold guidance provided in Inspection Manual Part 9900 Technical Guidance and were consistent with values calculated by NRC regional analysts; (6) that the cause and proposed path to resolve the situation were understood such that there was a high likelihood that planned actions to resolve the situation could be completed within the proposed NOED time frame; (7) that the noncompliance would not be of potential detriment to the public health and safety; and (8) independent verification of some of these conditions and actions by our inspection staff.

On the basis of the staff's evaluation of your request, we have concluded that granting this NOED is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on public health and safety or the environment. Therefore, it is our intention to exercise discretion to not enforce compliance with the TSs listed above for the period from July 30, 2010, at 2:00 a.m., to July 31, 2010, at 2:00 a.m. You have determined that a follow up license amendment is not necessary.

DEC 3 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 non-compliance for which this NOED was necessary.

Sincerely,

/Victor McCree RA for/

Luis A. Reyes Regional Administrator Docket No.: 50-413 License No.: NPF-35

Enclosure:

As stated cc w/encl: (See page 4)

_________________________ G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:RDS RII:DRS RII:ORA RII:ORA SIGNATURE EJS /RA/ JTM /RA for/ RHB /RA/ KMK /RA for/ VMM /RA/ VMM /RA for/

NAME EStamm LWert RBernhardt CChristensen VMcCree LReyes DATE 08/09/2010 08/09/2010 08/09/2010 08/09/2010 08/09/2010 08/09/2010 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO DEC 4 cc w/encl: W. Lee Cox, III Randy D. Hart Section Chief Regulatory Compliance Manager Radiation Protection Section Duke Energy Carolinas, LLC N.C. Department of Environmental Electronic Mail Distribution Commerce & Natural Resources Electronic Mail Distribution R. L. Gill, Jr.

Manager Vanessa Quinn Nuclear Regulatory Issues & Industry Affairs Federal Emergency Management Agency Duke Energy Carolinas, LLC 500 C Street, SW Electronic Mail Distribution Room 840 Washington, DC 20472 Dhiaa M. Jamil Group Executive and Chief Nuclear Officer Steve Weatherman, Operations Analyst Duke Energy Carolinas, LLC North Carolina Electric Membership Electronic Mail Distribution Corporation Electronic Mail Distribution Kathryn B. Nolan Senior Counsel County Manager of York County Duke Energy Corporation York County Courthouse 526 South Church Street-EC07H P. O. Box 66 Charlotte, NC 28202 York, SC 29745-0066 Lara Nichols Piedmont Municipal Power Agency Associate General Counsel Electronic Mail Distribution Duke Energy Corporation Electronic Mail Distribution Peggy Force Assistant Attorney General David A. Repka State of North Carolina Winston Strawn LLP P.O. Box 629 Electronic Mail Distribution Raleigh, NC 27602 North Carolina MPA-1 Suite 600 P.O. Box 29513 Raleigh, NC 27525-0513 Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Mark Yeager Division of Radioactive Waste Mgmt.

S.C. Department of Health and Environmental Control Electronic Mail Distribution

Letter to J. R. Morris from Luis A. Reyes dated August 9, 2010

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR DUKE ENERGY CAROLINAS REGARDING CATAWBA NUCLEAR STATION [NOED NO. 10-2-003]

Distribution w/encl:

C. Evans, RII OE Mail RIDSNRRDIRS PUBLIC A. Adams, NRR RidsNrrPMCatawba Resource

List of Participants NRC Region II Victor McCree, Deputy Regional Administrator for Operations, Region II (RII)

Kriss Kennedy, Director, Division of Reactor Safety (DRS), RII Joel Munday, Deputy Director, Division of Reactor Projects (DRP), RII Chris Christensen, Deputy Director, DRS, RII Jonathan Bartley, Chief, Reactor Projects Branch 1, DRP, RII Randy Musser, Chief, Reactor Projects Branch 4, DRP, RII Rudolph Bernhard, Senior Risk Analyst, DRS, RII John Hanna, Senior Risk Analyst, DRS, RII Mike Runyan, Senior Risk Analyst, DRS, RIV Scott Sparks, Senior Enforcement Specialist, RII NRC Headquarters Robert Nelson, Deputy Director, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)

Jon Thompson, Project Manager, Plant Licensing Branch II-1 (LPL2-1), DORL, NRR Karen Cotton, Project Manager, LPL2-1, DORL, NRR Roy Mathew, Acting Chief, Electrical Engineering Branch (EEEB), Division of Engineering (DE)

Matthew McConnell, Senior Electrical Engineer, EEEB, DE Matthew Kromer, Engineer, EEEB, DE Sheldon Stuchell, Senior Project Manager, Licensing Process Branch, Division of Policy and Rulemaking, NRR Sam Miranda, Senior Reactor Systems Engineer, Reactor Systems Branch, Division of Safety Systems (DSS), NRR Steve Jones, Senior Reactor Systems Engineer, Balance of Plant Branch, DSS, NRR Antonios Zoulis, Risk and Reliability Analyst, PRA Operational Support Branch, Division of Risk Assessment, NRR Robert Wolfgang, Component Perf. and Testing Branch, Division of Component Integrity, NRR Enclosure