IR 05000413/1999010: Difference between revisions

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{{Adams
{{Adams
| number = ML20206U416
| number = ML20210H194
| issue date = 05/10/1999
| issue date = 07/22/1999
| title = Insp Repts 50-413/99-10 & 50-414/99-10 on 990314-0424. Violation Being Considered for Escalated Enforcement Action Noted.Major Areas Inspected:Operations
| title = Discusses Insp Rept 50-413/99-10 & 50-414/99-10 on 990314- 0424 & Forwards Notice of Violation Re Failure to Comply with TS 3.7.13,when Misalignment of Two Electrical Breakers Rendered SSS Inoperable from 981216-29
| author name =  
| author name = Reyes L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name = Peterson G
| addressee affiliation =  
| addressee affiliation = DUKE POWER CO.
| docket = 05000413, 05000414
| docket = 05000413, 05000414
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-413-99-10, 50-414-99-10, NUDOCS 9905250204
| document report number = 50-413-99-10, 50-414-99-10, EA-99-094, NUDOCS 9908030299
| package number = ML20206U413
| package number = ML20210H199
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 7
| page count = 5
}}
}}


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I July 22,1999 EA 99-094 Duke Energy Corporation ATTN: Mr. G. . Site Vice President Catawba Nuclear Station 4800 Concord Road York, SC 29745 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-413/99-10 AND 50-414/99-10)


U.S. NUCLEAR REGULATORY COMMISSION
==Dear Mr. Peterson:==
This refers to a specialinspection conducted on March 14 through April 24,1999, at the Catawba Nuclear Station. The purpose of this inspection was to followup on an earlier configuration control problem that rendered the Standby Shutdown System (SSS) inoperable.


==REGION II==
The results of the inspection, including one apparent violation, were discussed with members of your staff at an exit meeting on May 3,1999, and formally transmitted to you by letter dated May 10,1999. An open, predecisional enforcement conference was conducted at the NRC
Docket Nos: 50-413, 50-414 License Nos: NPF-35, NPF-52
- Region ll office in Atlanta, Georgia, on July 12,1999, to discuss the apparent violation, the root cause, and your corrective actions. A list of conference attendees, copies of the Nuclear Regulatory Commission's (NRC) slides, and Duke Energy Corporation's (DEC) presentation materials are enclosed.
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Report Nos.: 50-413/99-10,50-414/99-10 Licensee: Duke Energy Corporation System: Catawba Nuclear Station, Units 1 and 2 Location: 422 South Church Street Charlotte, NC 28242 Dates: March 14 through April 24,1999 Inspectors: D. Roberts, Senior Resident inspector R. Franovich, Resident inspector Approved by: C. Ogle, Chief Reactor Projects Branch 1 Division of Reactor Projects
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Enclosure
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9905250204 990510 PDR ADOCK 05000413 G  PDR


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Based on the information developed during the inspection and the information you provided during the conference, we have determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report. The violation involved the failure to comply with Technical Specification (TS) 3.7.13, when the rnisalignment of two electrical breakers rendered the SSS inoperable from December 16 through 29,1998. On December 16,1998, in preparation for scheduled SSS maintenance, the two breakers were tagged and placed in the "off" (open) position. Upon completion of scheduled maintenance on December 18, plant personnel failed to return the two breakers to the normally "on" (closed)
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position. The misaligned breakers were discovered by DEC personnel on December 29,1998, while' conducting a plant procedure validation. Upon discovery of the open breakers, DEC personnel promptly positioned the breakers to their correct position to restore the SSS to operable status. TS 3.7.13 required that with the SSS inoperable, restore the inoperable equipment to operable status within seven days or be in at least hot standby within the next six hours and in at least hot shutdown within the following six hours; however, the SSS was inoperable for a total of 13 days and required actions were not taken to place the units in at least hot standby within the six hours and in at least hot shutdown within the following six hours. The root cause of the breaker misalignment was an oversight by DEC personnelin not referring to plant procedure OP/1/A/6350/001, Normal Power Checklist, to determine proper breaker
EXECUTIVE SUMMARY Catawba Nuclear Station, Units 1 and 2 NRC Inspection Report 50-413/99-10,50-414/99-10 This specialinspection focused on the integrated efforts of the Catawba Nuclear Station staff to evaluate, determine the root cause of, and correct a licensee-identified configuration control problem affecting the Standby Shutdown System from December 16 through 29,1998. The report covers the resident inspection period from March 14 to April 24,1999. [ Applicable template codes and the assessment for items inspected are provided below.)
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9908030299 990722 PDR


Operations
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AD3CK 05000413      i G  pop    -
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An apparent violation of previous Technical Specification 3.7.13 [now Selected Licensee Commitment item 16.7-9 (Standby Shutdown System)] was identified concerning two mispositioned electrical circuit breakers that rendered the Standby Shutdown System inoperable from December 16 through 29,1998. This issue affected both Catawba unit (Section 02.1; [1 A - eel])
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Upon discovery of the mispositioned breakers, licensee personnel promptly restored the Standby Shutdown System to operable status and made appropriate notifications to the NRC in the time period required. (Section O2.1; [1 A, 5A - POS])
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The licensee's procedures for operating the Standby Shutdown System during certain flood, power, fire, and security events were adequate to maintain equipment protection and perform their intended functions. Only minor enhancements were neede Licensee personnel interviewed were knowledgeable of these procedures and how to implement them. (Section O3.1; [1C,38 - POS))
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The licensee's root cause evaluation provided in Licensee Event Report (LER) i 50-413/98-19 sufficiently developed human performance issues that resulted in the j mispositioned Standby Shutdown System breakers. The licensee adequately addressed possible contributing factors in its corrective action program. (Section 08.1; [5B - POS])
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.c Report Details Summary of Plant Status During the period of this event (December 16 through 29,1998) both units were at approximately 100 percent reactor powe . Operations 02 Operational Status of Facilities and Equipment O2.1 Standby Shutdown SystemlSSS) Inocerable Due to Personnel Error Durina Eauipment Restoration Process Inspection Scope (71707)
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The inspectors reviewed the circumstances associated with LER 50413/98-19 (previously discussed in inspection Report 50-413,414/98-12), in which the SSS was determined to be inoperable for nearly two weeks because two circuit breakers in a SSS motor control center were misaligned. The inspectors discussed this issue with plant personnel, reviewed SSS operating and test procedures, reviewed the restoration procedure associated with SSS maintenance activities on December 16,1998, and reviewed the licensee's immediate corrective actions for restoring system operabilit Observations and Findinas On December 29,1998, the licensee discovered that two breakers associated with the SSS were open when they should have been closed. The breakers were F02C, Motor Control Center 1EMXS Attemate Supply, and R03D, Motor Control Center 2EMXS Alternate Supply. With the two breakers open, the SSS was inoperable for Units 1 and 2. The licensee determined that the two breakers had been in the incorrect position for 13 days, which exceeded the allowed outage time of seven days before action to initiate a unit shutdown to Mode 3 (hot standby) was required within the following six hour SSS Backaround information The SSS is a non-safety-related system that is used to cope with certain flood, power, fire, and security events in order to achieve and maintain hot standby condition for one or both units. The SSS is utilized for certain events that may result in the loss of normal reactor coolant pump (RCP) seal injection. This involves a time-critical task to provide sealinjection with the associated unit's standby makeup pump (which can be powered from 1SLXG using the SSS diesel) within 10 minutes in order to maintain RCP seal integrity. Some of the SSS loads are supplied from 1(2)EMXS, which is normally aligned to the A train 4160 volt alternating current (VAC) vital electrical bus. Procedure OP/0/B/6100/013, Standby Shutdown System Operations, Revision 41, directs operators to open breaker 1(2) F01 A associated with 1(2)EMXA, which is powered from 1(2) ETA (the A train 4160 VAC vital bus), and close breaker 1(2)F03A associated with 1SLXG, the auxiliary power supply, during postulated events. If power to 1SLXG is lost, the SSS diesel engine will be manually started to power the SSS loads, assuming the required breaker alignment is in place. The standby makeup pump suction and discharge isolation valves are powered from 1(2)EMXS. These valves are normally closed and would not be capable of opening and providing RCP sealinjection with breakers F02C and R03D open since they are in series with breaker 1(2)F03A, respectivel .,
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I DEC    2 L
position after the completion of maintenance, and in not specifying the correct position on system restoration procedures.
 
c Although the SSS is not considered a safety-related system, its design basis is to provide an alternate means for achieving and maintaining a hot standby condition for 72 hours during ;
certain events, including station blackout (SBO) events. During a postulated SBO, the SSS I provides e_lectrical power via a dedicated diesel generator to the standby makeup pump.and its suction and discharge valves (one pump and two valves for each unit), such that the ptimp can provide seal coolinD flow to the reactor coolant pumps (RCPl. The facility design requires restoration.of RCP seal cooling flow in the event of an SBO within ten minutes to prevent seal damage and loss of sealintegrity. However, with the two breakem in the incorrect position, the ability of the SSS to provide electrical power to open the standby makeup pump suction and discharge valves in a timely manner to provide RCP seal cooling flow within ten minutes could not be ensured. Although this condition did not result in any actual safety consequences, the ,
potential existed for this condition to cause a loss of RCP sealintegrity, had an actual SBO l
occurred.


To ensure that the time-critical task of providing RCP seal injection can be performed within 10 minutes, the licensee has procedurally minimized the number of breakers that need to be manipulated (only F01 A and F03A) to transfer power to 1SLXG. With no procedural steps provided to verify that the third breaker (F02C for Unit 1 and R03D for Unit 2) was closed, the ability to provide reactor coolant pump seal injection within 10 l minutes could not be ensure Personnel Error Durino Eouioment Restoration Procedure Devetooment The licensee determined that breakers F02C and R03D had been left in the open position following preventive maintenance on December 16,1998. The normally closed breakers were tagged and placed in the OFF (open) position in support of the maintenance. Following completion of the maintenance activities, the tags were removed from the breakers, but the breakers were left in the OFF position in accordance with the system restoration procedure, Tag-Out 08-2811. The system restoration procedure incorrectly specified that the breakers be restored in the open position. The licensee determined that a senior reactor operator (SRO) who generated the restoration procedure assumed that, since the breaker was associated with an alternate power supply, then the normal position of the breaker was OFF. This SRO failed to reference applicable procedures to verify the normal breaker position. A second SRO reviewed and approved the tag-out procedure and missed the error. The misaligned breakers were identified and questioned by another operator on December 29,1998, who was performing an unrelated procedure validation walk-throug Operation Management Procedure (OMP) 2-18, Tagout Removal and Restoration Procedure, Revision 50, Step 6.2, Restoration / Partial Restore Record Sheet, item AA, states that equipment is to be normally returned to the position specified by a governing operating procedure checklist, the body of a goveming procedure, or as specified by the approving SRO based on plant conditions. The i.ispectors determined that the governing operating checklists for the two SSS breakers were not reviewed when the operators determined the required restored positions. Discussions with licensee personnel and review of assot nd Problem Investigation Process report (PIP)
A violation that causes a system designed to prevent or mitigate serious safety events to be unable to perform its intended safety function is generally characterized as a Severity Level ll violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions"(Enforcement Policy), NUREG-1600. During the enforcement conference, you  ,
O-C98-4935, revealed that othen possible contributing factors included the fact that the restoration procedure did not reference OP/1/A/6350/001, Normal Power Checklist, which specifies the normal operating positions of the breakers; and station drawings did not accurately depict the breakers' normal operating positions. The inspectors concluded that these contributors did not cause the human performance error when the clearance restoration procedure was being developed and approved by the SROs in support of the December 16,1998, maintenance activities. These items were, however, properly included in the licensee's corrective action progra Root Cause Determination The licensee determined that the root cause for this event was inadequate work practices. Operations personnel failed to follow the established practice of reviewing OP/1/A/6350/001, Normal Power Checklist, to determine the correct normal (restored)
presented the results of your bounding risk analysis, assuming RCP pump seal damage after
position of breakers F02C and R03D. Based on the breakers' labels, operations personnel wrongly assumed that the normal position of the breakers was open. The inspectors concluded that the licensee's root cause determination, as well as its development of possible contributing factors in the corrective action program, was
        '
ten minutes. Your analysis concluded that the increase in core damage frequency was small and below the accident precursor threshold of 1E-6 per year. Based on your analysis, we ,
determined that this violation would not be properly characterized at Severity Level 11 However, l we have determined that this violation represents a significant failure to comply with the Action Statement of a TS Limiting Condition for Operation where the appropriate action was not taken within the required time. Therefore, this violation has been characterized in accordance with the Enforcement Policy as a Severity Level lli violation.


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I in accordance with the Enforcement Policy, a base civil penalty in the amount of S55,000 is considered for a Severity Level lli violation. Because your facility has been the subject of an ;
escalated enforcement action within the last two years', we considered whether credit was warranted for Identification and Corrective Actipn in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit for identification is warranted because the violation was identified by DEC personnel while conducting a plant procedure validation. Credit also is warranted for Corrective Acjt on because of your immediate corrective action to restore the SSS to operable status and because of long-term corrective actions to preclude recurrence. These corrective actions included: discussions with plant operators to reinforce plant requirements to refer to procedures to determine breaker restoration positions and to maintain independence between plant personnelin the removal and restoration process; placement of permanent waming labels on the two breakers; and other corrective
- actions that were discussed at the co,nference.


comprehensive. Several short- and long-term corrective actions were specified to restore operability and prevent recurrence. These included specifying, in the equipment data base and locally at the breakers, that having them in the OFF (open) position would render the SSS inoperable. Other actions were taken to address the human performance issue Safety Sianificance
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The SSS is not considered safety-related. However, the SSS provides an alternate and independent means for maintaining the plant in a safe shutdown (for the SSS this is Hot .
[
Standby [ Mode 3]) condition following certain loss of power, flooding, fire, and security events that result in the loss of normal RCP seal injection. These events are not ,
I A Severity Level 111 problem was issued on June 11,1998, for violations associated with the Unit 2 auxiliary building filtered exhaust system.
assumed to be concurrent with a design basis accident. Safe shutdown is achieved when: (1) the reactor is prevented from achieving criticality; and (2) adequate heat sink is provided to ensure reactor coolant system pressure and temperature design and safety limits are not exceeded. Upon a loss of normal RCP sealinjection, the SSS is placed in service and the associated unit's standby makeup pump is started to provide seal injection. This is to be accomplished within 10 minutes to ensure that significant RCP seal damage and a resultant small break loss of coolant accident do not occu With breakers F02C and R03D in the wrong positions and not referenced in the SSS operating procedure, the SSS's ability to perform its intended safety function of maintaining RCP seal integrity could not be ensure Reculatory Sianificance The inspectors concluded that the SSS was inoperable from December 16 through 29, 1998, without appropriate actions being taken to restore operability within seven days or perform a plant shutdown within the following six hours as required by Technical Specifications (TS). [As of January 16,1999, following the licensee's conversion to improved TS, this requirement was transferred to the Selected Licensee Commitments (SLC) document (item 16.7-9), considered Chapter 16 of the Catawba Updated Final Safety Analysis Report.) The licensee's failure to restore SSS operabiity or perform a plant shutdown within allowed outage times is considered an apparent violation of previous TS 3.7.13. This is identified as apparent violation (eel) 50-413,414/99-10-01:
 
Standby Shutdown System Inoperable in Excess of TS Limits Due to Mispositioned Circuit Breaker c. Conclusions An apparent violation of previous Technical Specification 3.7.13 [now Selected Licensee Commitment item 16.7-9 (Standby Shutdown System)) was identified concerning two mispositioned electrical circuit breakers that rendered the Standby Shutdown System inoperable from December 16 through 29,1998. This issue affected both Catawba unit Upon discovery of the mispositioned breakers, licensee personnel promptly restored the Standby Shutdown System to operable status and made appropriate notifications to the NRC in the time period require j J
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DEC    3
 
Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized by the Director, Office of Enforcement, not to propose a civil penalty in this t
case. However, significant violations in the future could result in a civil penalty.
 
The NRC has concluded that information regarding the reason for the violation and the corrective actions taken and planned to correct the violation and prevent recurrence is already ;
adequately addressed on the docket in NRC Inspection Report No. 50-413,414/99-10, Licensee
  - Event Report 50-413/98-019 dated January 28,1999, and in the materials you presented at the .
conference. Therefore, you are not required to respond to this letter unless the description .
~
therein does not accurately reflect your corrective actions or your position. In that case, or if you I choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
 
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be placed in the Public Document Room (PDR) To the extent possible, your response should not include 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.


03 Operations Procedures and Documentation O3.1 SSS Operatina Procedures and Plant Staff Knowledae - General Comments (71707)
Sincerely, Original signed by LAR Luis A. Reyes  i Regional Administrator  j i
The inspectors reviewed procedures associated with the operation of the SSS for loss of nuclear service water, loss of component cooling water, and station blackout events (i.e., events resulting in loss of normal RCP seal injection), and interviewed operations and security personnel responsible for implementation. One minor discrepancy was identified in OP/0/B/6100/013, Standby Shutdown System Operations, Revision 4 Procedural steps goveming the transfer to the SSS referenced a wrong structural
        .
  ' column identification number in describing a critical terminal box location. This item was communicated to station personnel for correctio Otherwise, the licensee's procedures for operating the SSS during certain flood, power,
Enclosures: 1. Notice of Violation 2. Conference Attendees    I 3. Material Presented by NRC    ;
. fire, and security events were adequate to maintain equipment protection and perform their intended functions. Licensee personnel interviewed were knowledgeable of these procedures and how to implement the Miscellaneous Operations issues (40500, 92901)
4. Material Presented by DEC    '
- 08.1 - (Closed) LER 50-413/98-19-00: Standby Shutdown System inoperable in Excess of Technical Specification Allowed Outage Time due to Mispositioned Breakers Caused by Personnel Error The licensee's root cause evaluation provided in this LER sufficiently developed human -
Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 l
performance issues that resulted in the mispositioned breakers. The licensee adequately addressed possible contributing factors in its corrective action progra Based on the inspectors' review of the subject event, as described in Sections 02 and
cc w/encis'. (see page 4)      l
' 03 of this inspection report, this LER is close V. Management Meetmgs X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on May 3,1999. The licensee acknowledged the findings presented. No proprietary information was identife .
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Distribution w/encis:
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WTravers, EDO FMiraglia, DEDR MKnapp, DEDE
, DDambly, OGC l
EJulian, SECY 8 Keeling, CA Enforcement Coordinators Rl, Rlli, RIV JLieberman, OE GCaputo, O!
WBeecher, OPA HBell, OlG CEvans, Ril SSparks, Ril MSatorius, OEDO LPlisco, Ril BMallett, Ril COgle, Ril HBerkow, NRR PTam, NRR DNelson, OE RCarroll, Ril VOrdaz, NRR OE:EA File (BSummers, OE)(2 letterhead)
PUBLIC NRC Resident inspector U.S. Nuclear Regulator Commission 4830 Concord Road York, SC 29745 s N
  / u. -9.?Np
 
SENDTdPUBLICDOCUMENTR00M7 YES  / ll OFFICE Mll:EICS Rll:DRP RII:DRS Ril:0RA RII:0g /
Signature $' g gf NW , g NAME SSPARKS LISCO BMALLETT CEVANS ! JOHN DATE "I/72/99 N / \L~ /99 M $ /99 w 5 /99 '7/ A/99 / /99 COPYt VES NO \ES NO '
YYESI NO 6ESl NO YE/NO ) YES NO OFFICIAL RECORD COPY DOCUMENT NAM 64*f:\ENf 0RCE\99 CASES \99094 CAT.DIR\F NAt@PD
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[ DEC-  4 cc w/encis:  Peggy Force G. D. Gilbert  Assistant Attorney General Regulatory Compliance Manager N. C. Department of Justice Duke Energy Corporation  P. Box 629 4800 Concord Road  Raleigh, NC 27602 York, SC 29745-9635 Saluda River Electric Lisa Vaughn  Cooperative, Inc. ff
,
Legal Department (PB05E) P. O. Box 929 Duke Energy Corporation Laurens, SC 129360 422 South Church Street Charlotte, NC 28242  County Manager of York County York County Courthouse  -
Anne Cottingham . York, SC 29745 Winston and Strawn 1400 L Street, NW  Piedmont Municipal Power Agency Washington, D. C. 20005 121 Village Drive Greer, SC 29651 North Carolina MPA-1 Suite 600  L. A. Keller, Manager P. O. Box 29513  Nuclear Regulatory Licensing Raleigh, NC 27626-0513  Duke Energy Corporation -
526 S. Church Street Virgil R. Autry, Director Charlotte, NC 28201-0006 Div. of Radioactive Waste Mgmt.
 
S. C. Department of Health    j Steven P. Shaver and Environmental Control Senior Sales Engineer 2600 Bull Street  Westinghouse Electric Company Columbia, SC 29201 5929 Carnegie Boulevard, Suite 500 Charlotte, NC 28209 Richard P. Wilson, Esq.


PARTIAL LIST OF PERSONS CONTACTED Licensee R. Beagles, Safety Assurance Manager M. Boyle, Radiation Protection Manager S. Bradshaw, Safety Assurance Manager G. Gilbert, Regulatory Compliance Manager  *
Assistant Attorney General S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Michael Hirsch ~
R. Glover, Operations Superintendent P. Herran, Engineering Manager R. Jones, Station Manager G. Peterson, Catawba Site Vice-President F. Smith, Chemistry Manager R. Parker, Maintenance Manager INSPECTION PROCEDURES USED IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems IP 71707: Plant Operations IP 92901: Followup - Operations ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-413,414/99-10-01 eel Standby Shutdown System inoperable in Excess of TS Liro;ts Due to Mispositioned Circuit Breakers (Secuon O2.1)
Federal Emergency Management Agency 500 C Street, SW, Room 840
Qloped 50-413/98-19-00 LER Standby Shutdown System inoperable in Excess of Technical Specification Allowed Outage Time due to Mispositioned Breakers Caused by Personnel Error (Section 08.1)
. Washington, D. C. 20472 North Carolina Electric
LIST OF ACRONYMS USED CFR - - Code of Federal Regulations eel -
'
Escalated Enforcement item (Apparent Violation)
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LER -
Membership Corporation P. O. Box 27306 Raleigh, NC 27611    ,
Licensee Event Report NRC -
w
Nuclear Regulatory Commission PIP - Problem Investigation Process RCP -
[
Reactor Coolant Pump SLC -
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Selected Licensee Commitments SRO -
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Senior Reactor Operator SSS -
Standby Shutdown System TS- -
Technical Specification      ,
VAC - Volts Attemating Current
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Latest revision as of 03:47, 4 December 2021

Discusses Insp Rept 50-413/99-10 & 50-414/99-10 on 990314- 0424 & Forwards Notice of Violation Re Failure to Comply with TS 3.7.13,when Misalignment of Two Electrical Breakers Rendered SSS Inoperable from 981216-29
ML20210H194
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 07/22/1999
From: Reyes L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Gordon Peterson
DUKE POWER CO.
Shared Package
ML20210H199 List:
References
50-413-99-10, 50-414-99-10, EA-99-094, NUDOCS 9908030299
Download: ML20210H194 (5)


Text

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I July 22,1999 EA 99-094 Duke Energy Corporation ATTN: Mr. G. . Site Vice President Catawba Nuclear Station 4800 Concord Road York, SC 29745 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-413/99-10 AND 50-414/99-10)

Dear Mr. Peterson:

This refers to a specialinspection conducted on March 14 through April 24,1999, at the Catawba Nuclear Station. The purpose of this inspection was to followup on an earlier configuration control problem that rendered the Standby Shutdown System (SSS) inoperable.

The results of the inspection, including one apparent violation, were discussed with members of your staff at an exit meeting on May 3,1999, and formally transmitted to you by letter dated May 10,1999. An open, predecisional enforcement conference was conducted at the NRC

- Region ll office in Atlanta, Georgia, on July 12,1999, to discuss the apparent violation, the root cause, and your corrective actions. A list of conference attendees, copies of the Nuclear Regulatory Commission's (NRC) slides, and Duke Energy Corporation's (DEC) presentation materials are enclosed.

Based on the information developed during the inspection and the information you provided during the conference, we have determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report. The violation involved the failure to comply with Technical Specification (TS) 3.7.13, when the rnisalignment of two electrical breakers rendered the SSS inoperable from December 16 through 29,1998. On December 16,1998, in preparation for scheduled SSS maintenance, the two breakers were tagged and placed in the "off" (open) position. Upon completion of scheduled maintenance on December 18, plant personnel failed to return the two breakers to the normally "on" (closed)

position. The misaligned breakers were discovered by DEC personnel on December 29,1998, while' conducting a plant procedure validation. Upon discovery of the open breakers, DEC personnel promptly positioned the breakers to their correct position to restore the SSS to operable status. TS 3.7.13 required that with the SSS inoperable, restore the inoperable equipment to operable status within seven days or be in at least hot standby within the next six hours and in at least hot shutdown within the following six hours; however, the SSS was inoperable for a total of 13 days and required actions were not taken to place the units in at least hot standby within the six hours and in at least hot shutdown within the following six hours. The root cause of the breaker misalignment was an oversight by DEC personnelin not referring to plant procedure OP/1/A/6350/001, Normal Power Checklist, to determine proper breaker

\

9908030299 990722 PDR

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AD3CK 05000413 i G pop -

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I DEC 2 L

position after the completion of maintenance, and in not specifying the correct position on system restoration procedures.

c Although the SSS is not considered a safety-related system, its design basis is to provide an alternate means for achieving and maintaining a hot standby condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during ;

certain events, including station blackout (SBO) events. During a postulated SBO, the SSS I provides e_lectrical power via a dedicated diesel generator to the standby makeup pump.and its suction and discharge valves (one pump and two valves for each unit), such that the ptimp can provide seal coolinD flow to the reactor coolant pumps (RCPl. The facility design requires restoration.of RCP seal cooling flow in the event of an SBO within ten minutes to prevent seal damage and loss of sealintegrity. However, with the two breakem in the incorrect position, the ability of the SSS to provide electrical power to open the standby makeup pump suction and discharge valves in a timely manner to provide RCP seal cooling flow within ten minutes could not be ensured. Although this condition did not result in any actual safety consequences, the ,

potential existed for this condition to cause a loss of RCP sealintegrity, had an actual SBO l

occurred.

A violation that causes a system designed to prevent or mitigate serious safety events to be unable to perform its intended safety function is generally characterized as a Severity Level ll violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions"(Enforcement Policy), NUREG-1600. During the enforcement conference, you ,

presented the results of your bounding risk analysis, assuming RCP pump seal damage after

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ten minutes. Your analysis concluded that the increase in core damage frequency was small and below the accident precursor threshold of 1E-6 per year. Based on your analysis, we ,

determined that this violation would not be properly characterized at Severity Level 11 However, l we have determined that this violation represents a significant failure to comply with the Action Statement of a TS Limiting Condition for Operation where the appropriate action was not taken within the required time. Therefore, this violation has been characterized in accordance with the Enforcement Policy as a Severity Level lli violation.

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I in accordance with the Enforcement Policy, a base civil penalty in the amount of S55,000 is considered for a Severity Level lli violation. Because your facility has been the subject of an ;

escalated enforcement action within the last two years', we considered whether credit was warranted for Identification and Corrective Actipn in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit for identification is warranted because the violation was identified by DEC personnel while conducting a plant procedure validation. Credit also is warranted for Corrective Acjt on because of your immediate corrective action to restore the SSS to operable status and because of long-term corrective actions to preclude recurrence. These corrective actions included: discussions with plant operators to reinforce plant requirements to refer to procedures to determine breaker restoration positions and to maintain independence between plant personnelin the removal and restoration process; placement of permanent waming labels on the two breakers; and other corrective

- actions that were discussed at the co,nference.

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I A Severity Level 111 problem was issued on June 11,1998, for violations associated with the Unit 2 auxiliary building filtered exhaust system.

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DEC 3

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized by the Director, Office of Enforcement, not to propose a civil penalty in this t

case. However, significant violations in the future could result in a civil penalty.

The NRC has concluded that information regarding the reason for the violation and the corrective actions taken and planned to correct the violation and prevent recurrence is already ;

adequately addressed on the docket in NRC Inspection Report No. 50-413,414/99-10, Licensee

- Event Report 50-413/98-019 dated January 28,1999, and in the materials you presented at the .

conference. Therefore, you are not required to respond to this letter unless the description .

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therein does not accurately reflect your corrective actions or your position. In that case, or if you I choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be placed in the Public Document Room (PDR) To the extent possible, your response should not include 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 LAR Luis A. Reyes i Regional Administrator j i

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Enclosures: 1. Notice of Violation 2. Conference Attendees I 3. Material Presented by NRC  ;

4. Material Presented by DEC '

Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 l

cc w/encis'. (see page 4) l

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Distribution w/encis:

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WTravers, EDO FMiraglia, DEDR MKnapp, DEDE

, DDambly, OGC l

EJulian, SECY 8 Keeling, CA Enforcement Coordinators Rl, Rlli, RIV JLieberman, OE GCaputo, O!

WBeecher, OPA HBell, OlG CEvans, Ril SSparks, Ril MSatorius, OEDO LPlisco, Ril BMallett, Ril COgle, Ril HBerkow, NRR PTam, NRR DNelson, OE RCarroll, Ril VOrdaz, NRR OE:EA File (BSummers, OE)(2 letterhead)

PUBLIC NRC Resident inspector U.S. Nuclear Regulator Commission 4830 Concord Road York, SC 29745 s N

/ u. -9.?Np

SENDTdPUBLICDOCUMENTR00M7 YES / ll OFFICE Mll:EICS Rll:DRP RII:DRS Ril:0RA RII:0g /

Signature $' g gf NW , g NAME SSPARKS LISCO BMALLETT CEVANS ! JOHN DATE "I/72/99 N / \L~ /99 M $ /99 w 5 /99 '7/ A/99 / /99 COPYt VES NO \ES NO '

YYESI NO 6ESl NO YE/NO ) YES NO OFFICIAL RECORD COPY DOCUMENT NAM 64*f:\ENf 0RCE\99 CASES \99094 CAT.DIR\F NAt@PD

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[ DEC- 4 cc w/encis: Peggy Force G. D. Gilbert Assistant Attorney General Regulatory Compliance Manager N. C. Department of Justice Duke Energy Corporation P. Box 629 4800 Concord Road Raleigh, NC 27602 York, SC 29745-9635 Saluda River Electric Lisa Vaughn Cooperative, Inc. ff

,

Legal Department (PB05E) P. O. Box 929 Duke Energy Corporation Laurens, SC 129360 422 South Church Street Charlotte, NC 28242 County Manager of York County York County Courthouse -

Anne Cottingham . York, SC 29745 Winston and Strawn 1400 L Street, NW Piedmont Municipal Power Agency Washington, D. C. 20005 121 Village Drive Greer, SC 29651 North Carolina MPA-1 Suite 600 L. A. Keller, Manager P. O. Box 29513 Nuclear Regulatory Licensing Raleigh, NC 27626-0513 Duke Energy Corporation -

526 S. Church Street Virgil R. Autry, Director Charlotte, NC 28201-0006 Div. of Radioactive Waste Mgmt.

S. C. Department of Health j Steven P. Shaver and Environmental Control Senior Sales Engineer 2600 Bull Street Westinghouse Electric Company Columbia, SC 29201 5929 Carnegie Boulevard, Suite 500 Charlotte, NC 28209 Richard P. Wilson, Esq.

Assistant Attorney General S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Michael Hirsch ~

Federal Emergency Management Agency 500 C Street, SW, Room 840

. Washington, D. C. 20472 North Carolina Electric

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Membership Corporation P. O. Box 27306 Raleigh, NC 27611 ,

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