ML20134P472

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)

See also: IR 05000413/1997004

Text

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February 18, 1997

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EA 97-036

Duke Power Com]any

ATTN: Mr. W. 1. McCollum

Site Vice President

Catawba Site

1

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)

System. 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 actions. 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, 1997.

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

,

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 conditions. 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 inoperable.

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 engineering.

design, or installation deficiency, provided that certain criteria are met.

OFFICIAL COPY

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9702250478 970218

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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 performance.

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

Room.

If you should have any questions regarding this letter, please contact

Mr. Charles Casto. Chief Branch 1. Division of Reactor Projects, at

404-331-5506.

1

Sincer ly, ,

.

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. Esq. .

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

!

Bureau of Radi.ological Health

S. C. Department of Health .

and Environmental Control

2600 Bull Street

Columbia, SC 29201

Richard P. Wilson. Esq.

Assistant Attorney General

S. C. Attorney General's Office  ;

P. O. Box 11549 i

Columbia. SC 29211

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Michael Hirsch

Federal Emergency Management Agency ,

,

500 C Street. Sw. Room 840 '

Washington, D. C. 20472

cc: (Cont'd on Page 4)

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North Carolina Electric '

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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. Inc. ,

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

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