IR 05000413/1997004

Documents Closure of Apparent Violation Described in Insp Repts 50-413/97-04 & 50-414/97-04 Conducted on 970106-23 & Completes NRC Action in Subj Matter

ML20134P472
Person / Time
Site:	Catawba
Issue date:	02/18/1997
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mccollum W DUKE POWER CO.
References
EA-97-036, EA-97-36, NUDOCS 9702250478
Download: ML20134P472 (6)

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O February 18, 1997

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EA 97-036 Duke Power Com]any ATTN: Mr. W. 1. McCollum Site Vice President Catawba Site

4800 Concord Road York. South Carolina 29745-9635 SUBJECT: EXERCISE OF ENFORCEMENT DISCRETION (NRC INSPECTION REPORT NOS. 50-413. 414/97-04)

This letter refers to an inspection conducted during the period January 6 through 23, 1997, at your Catawba Nuclear Station. During the inspection, the 1 NRC examined the facts and circumstances surrounding your identification of a design deficiency associated with the Unit 1 and 2 Auxihary Feedwater (AFW)

Syste On January 9, 1997, you submitted Licensee Event Report (LER)

, No. 50-413/96-012 following the determination that the AFW system was outside '

its design basis. Subsequently, on January 17, 1997. Revision 1 to the LER was submitted to provide additional information and corrective action Our review of this issue is discussed in detail in the subject inspection report

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transmitted to you by letter dated January 31, 199 Based on the information develo)ed during the inspection, the NRC has determined that a violation of 1RC requirements occurred. Specifically, from

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initial construction of Units 1 and 2 until December 11. 1996, measures were not established to correctly translate the design basis of the AFW system .

described in the Final Safety Analysis Report. Section 9.2.1 into specifications, drawings, and procedures for the Nuclear Service Water (NSW)

System (the assured water source for the AFW system) resulting in the

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requirements of Technical Specification (TS) 3.7.2.1 not being met for both units. Because the AFW systems' assured source lacked adequate train separation, a single, active failure of one of the two assured source suction valves (1/2RN-250 or 1/2RN-310) would render all three AFW pumps for the associated unit inoperable under certain condition Specifically, with all three AFW pumps running with high flow demand ar,a a loss of the normal suction sources (non-safety related), a single failure of one of the two assured source suction valves would cause the remaining train of the assured source to attempt to supply all three AFW pumps. This would result in inadequate net positive suction head to all three pumps, rendering them inoperabl In accordance with the " General Statement of Policy and Procedures for Enforcement Actions" (Enforcement Policy). NUREG-1600. this violation normally would be categorized as a Severity Level III violation. However, as discussed in Section VII.B.3 of the Enforcement Policy. the NRC may refrain from issuing a Notice of Violation (Notice) and proposing a civil Jenalty for a Severity Level III violation that involves a past problem, suc1 as an old engineerin design, or installation deficiency, provided that certain criteria are me OFFICIAL COPY

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d DPC -2-After review of this violation and consultation with the Director, Office of Enforcement the NRC has concluded that the criteria for enforcement

, discretion have been met. Therefore, to encourage licensee efforts to identify and correct subtle violations before degraded safety systems are called upon to function, no Notice is being issued in this case. The specific bases for this decision are: (1) you identified the violation during a

, licensee-initiated design review conducted in support of a modification:

(2) although voluntary self-initiated technical audits had beer 1 performed for both the AFW =and NSW systems, it was not unreasonable tha' these audits did not identify the deficiency earlier, and it is unlikely the deficiency would

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have been identified by routine surveillances or quality a surance audits:

(3) timely and appropriate modifications were completed to mstall check valves in locations to resolve the deficiency: (4) timely and effective corrective actions were implemented, and appropriate long-term corrective actions to review and identify any similar design deficiencies in the systems interfacing with the Standby Shutdown System were delineated; and (5) the design deficiency occurred at the time of plant construction and is not reasonably linked to present engineering performanc This letter serves to document the closure of the ap)arent violation (eel 50-413 and 50-414/97-04-01) described in the su) ject inspection re) ort and completes the NRC's action in this matter. No formal response to t1is letter is required. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Roo If you should have any questions regarding this letter, please contact Mr. Charles Casto. Chief Branch 1. Division of Reactor Projects, at 404-331-550 Sincer ly, ,

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Luis A. Reyes Regional Admin &s rator Docket Nos. 50-413, 50-414 License Nos. NPF-35, NPF-52 cc:

M. S. Kitlan Regulatory Compliance Manager Duke Power Company 4800 Concord Road York. SC 29745-9635 cc: (Cont'd on Page 3)

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cc (Cont'd): j Paul R. Newton Legal Department (PB05E)

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 Robert P. Gruber Executive Director Public Staff - NCUC P. O. Box 29520 Raleigh. NC 27626-0520 J. Michael McGarry, III. Es .

Winston and Strawn I 1400 L Street. NW Washington D. C. 20005 North Carolina MPA-1 ,

Suite 600 -

P. O. Box 29513 Raleigh. NC 27626-0513 l Max Batavia, Chief

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Bureau of Radi.ological Health S. C. Department of Health .

and Environmental Control 2600 Bull Street Columbia, SC 29201 Richard P. Wilson. Es Assistant Attorney General S. C. Attorney General's Office  ;

P. O. Box 11549 i Columbia. SC 29211 i

Michael Hirsch Federal Emergency Management Agency ,

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500 C Street. Sw. Room 840 '

Washington, D. C. 20472 cc: (Cont'd on Page 4)

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Membership Corporation P. O. Box 27306 Raleigh NC 27611 Karen E. Long Assistant Attorney General N. C. Department of Justice i P. O. Box 629  :

Raleigh. NC 27602  !

Saluda River Electric Cooperative. In ,

P. O. Box 929  !

Laurens. SC 29360 Peter R. Harden IV Account Sales Manager Power Systems Field Sales Westinghouse Electric Corporation P. O. Box 7288 C.larlotte. NC 28241 County Manager of York County York County Courthouse York. SC 29745 Piedmont Municipal Power Agency 121 Village Drive Greer. SC 29651 G. A. Copp Licensing - EC050 Duke Power Company P. O. Box 1006 Charlotte. NC 28201-1006 T. Richard Puryear Owners Group North Carolina Electric Membership Corporation 4800 Concord Road York. SC 29745 4 . - . . - - - .. _ .-.

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