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05000414/FIN-2018003-0130 September 2018 23:59:59CatawbaSelf-revealingFailure to Follow Maintenance Procedure Results in Damage to the 2A EDG During TestingA Green self-revealed NCV of Technical Specification 5.4.1.a, Procedures, was identified for Catawbas failure to follow procedure TE-MN-ALL-0202, Transformer and Apparatus Testing, during maintenance on the 2A EDG. Specifically, the licensees failure to follow TE-MN-ALL-0202, resulted in damage to the voltage regulator circuit and the unexpected shutdown of the diesel during post maintenance testing (PMT) on June 11, 2018. The licensee entered this issue in the corrective action program (CAP) as Condition Report (CR) 2212222
05000413/FIN-2018010-0130 September 2018 23:59:59CatawbaNRC identifiedInadequate Engineering Analyses to Support Design Basis RequirementsThe team identified four examples of a Green non-cited violation of title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control. Specifically, Catawba failed to verify the electrical design of safety-related switch gear for the emergency core cooling system equipment and distribution systems (4160 volts-alternating-current (VAC), 600 VAC, and 125 volt-direct- current (VDC)): 1) Some circuit breakers had inadequate voltages that did not meet the minimum qualified requirements (90 VDC), 2) The design was not evaluated for the effects of electrical transients on control voltages that could affect the assumptions in the plant safety analyses for sequencing of loads and potentially affect the control fuses, 3) The effects of degraded voltages was not correlated to the component protection devices to prevent damage or unavailability of equipment during an event, and 4) Motor control centers and components located in the diesel control area were not qualified to perform their safety function during expected environmental transients.
05000413/FIN-2018010-0230 September 2018 23:59:59CatawbaNRC identifiedOperability of the VZ and RN Systems were not AssuredThe team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control for the failure to assure that applicable regulatory requirements for the safety-related service water pump house environmental controls were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to translate the IEEE 279-1971 design basis and requirements for the environmental controls.
05000413/FIN-2018002-0230 June 2018 23:59:59CatawbaNRC identifiedFailure to Promptly Identify and Correct a Condition Adverse to QualityThe inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality associated with low resistance readings for core exit thermocouples (CET) identified during testing on January 30, 2018. Specifically, the licensee failed to declare two CETs inoperable when resistance readings were outside of the acceptance criteria until April 9, 2018.
05000414/FIN-2018002-0330 June 2018 23:59:59CatawbaNRC identifiedNotice of Enforcement Discretion Granted from Technical Specifications Related to the Failure of the 2A EDG During Post-Maintenance TestAs required by Inspection Manual Chapter 0410 Section 06.03.c, an unresolved item is being opened associated with a Notice of Enforcement Discretion 18-2-001 related to approval to not comply with TS requirements associated with the failure of the 2A emergency diesel generator during post-maintenance testing on June 11, 2018. On the basis of the staffs evaluation of the licensees request, the NRC concluded that granting the NOED was consistent with the NRCs Enforcement Policy and had no adverse impact on public health and safety or the environment. Therefore, as communicated orally to the Duke staff on June 14, 2018, the NRC exercised enforcement discretion to not enforce compliance with TS LCO 3.8.1 Condition G requirements that Catawba Nuclear Station, Units 2, be in Mode 2 by 10:08 a.m. EDT on June 14, 2018. Unit 2, Mode 3 entry was extended by 48 hours, to allow completion of repair on the 2A emergency diesel generator. Planned Closure Action: Inspectors will review the licensees cause evaluation for this issue.Licensee Actions: Duke completed repairs to the 2A emergency diesel generator such that the condition causing the need for the NOED was corrected at 9:06 p.m. EDT on June 14, 2018. Corrective Action Reference: CR 2212222
05000414/FIN-2018002-0130 June 2018 23:59:59CatawbaSelf-revealingFailure to Identify and Correct CAQ Associated with Failure of the 2B Seal Water Injection Filter O-ringA self-revealed Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to promptly identify and correct a condition adverse to quality associated with the failure of 2B seal water injection filter (SWIF) O-ring on May 13, 2018. Specifically, the licensees failure to implement corrective actions for the first failure of the O-ring on 2B SWIF on March 12, 2018, led to a second failure of 2B SWIF O-ring on May 13, 2018.
05000413/FIN-2018001-0131 March 2018 23:59:59CatawbaNRC identifiedFailure to Ensure that Conditions Adverse toQuality Managed Outside of the Corrective Action Program are CorrectedThe inspectors identified a Green non-cited violation (NCV)of Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to adequately establish measures to correct conditions adverse to quality (CAQ). Specifically, the licensee failed to establish controls to ensure that CAQs managed outside of the corrective action program (CAP) are corrected
05000413/FIN-2017004-0231 December 2017 23:59:59CatawbaNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for a Change to Engineering Safety Features Actuation Periodic Test.The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to perform a written safety evaluation prior to implementing a change to licensee procedure PT/1/A/4200/009 Engineering Safety Features Actuation periodic test (ESFAS). This procedure was last used during refueling outage 22 (November 2015) and resulted in a missed surveillance for TS surveillance requirements (SR) 3 3.8.1.11 and 3.8.1.19. The licensee took corrective actions to revise the ESFAS procedure and complete repairs of the 1A auxiliary shutdown panel supply unit (ASPSU) to allow complete testing of the ESFAS logic circuitry during the next refueling outage in accordance with SR 3.0.3 (November 2018). The licensee entered this issue into the CAP as CR 2124814.The failure to perform a 10 CFR 50.59 safety evaluation for a change to procedure PT/1/A/4200/009, Engineering Safety Features Actuation periodic test (ESFAS) was a performance deficiency. This performance deficiency was determined to be more than minor because there was a reasonable likelihood that the change would have required Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process because they are considered to be violations that could potentially impede or impact the regulatory process. However, when possible, the underlying technical issue is evaluated under the SDP to determine the significance of the violation. The performance deficiency impacted the mitigating systems cornerstone. The inspectors determined the issue to be of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time and did not represent an actual loss of function of one or more non-tech spec trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. In accordance with Section 6.1.d the NRC Enforcement Policy, issued November 1, 2016, a traditional enforcement violation of 10 CFR 50.59 that results in conditions evaluated as having very low safety significance (i.e., Green) by the SDP is considered to be a SL IV violation. There was no cross-cutting aspect associated with this violation because cross-cutting aspects are not assigned to traditional enforcement violations.
05000413/FIN-2017004-0131 December 2017 23:59:59CatawbaNRC identifiedInadequate Testing of Fuel Pool Ventilation Radiation MonitorsAn NRC identified Green non-cited violation (NCV) of Technical Specification (TS)5.4.1, Procedures, was identified for the licensees failure to establish and maintain a procedure for testing the Units 1 and 2 process and area radiation monitoring system. Specifically, the channel operational test procedures IP/1(2)/B/3314/036 Q, 1(2) EMF35, 1(2) EMF36, 1(2) EMF42, and, EMF50L Channel Operational Test, did not adequately test the trip functions for fuel pool ventilation radiation monitor EMF-42 on Units 1 and 2. As a result, the licensee declared the Units 1 and 2 EMF-42 radiation monitors non-functional and initiated corrective actions to revise the procedure. The licensee entered this issue into the corrective action program (CAP) as Condition Report (CR) 2168190.The failure to establish adequate procedural guidance to test the trip functions of EMF-42 on Units 1 and 2 was a performance deficiency. The performance deficiency was more than minor because it was associated with the plant facilities/equipment and instrumentation attribute (reliability of process radiation monitors) of the radiation safety cornerstone (public radiation safety) and adversely affected the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian use. The inspectors determined the finding to be of very low safety significance because it was associated with the effluent program; however, it was not a substantial failure to implement the effluents program and it did not result in a public dose greater than an Appendix I criterion or 10 CFR 20.1301(e). The finding was associated with a cross-cutting aspect in the change management component of the human performance area because the licensee failed to effectively use a systematic process for evaluating and implementing a change to the testing procedure for EMF-42 in 2015, so that nuclear safety remains the overriding priority. (H.3)
05000413/FIN-2017004-0331 December 2017 23:59:59CatawbaNRC identifiedFailure to Follow Administrative ProceduresThe NRC identified a Green NCV of TS 5.4.1, Procedures. Specifically, the licensee failed to follow procedure AD-HU-ALL-004, Preparation and Work Instruction Use and Adherence. As a result, the licensee: (1) replaced a pressurizer heater breaker with an incorrect breaker, (2) performed a temporary modification incorrectly, and (3) did not perform an operational test procedure step as written. As corrective actions, the licensee: (1) replaced and tested satisfactorily breaker 1PHP1C-F01B with the correct model and entered this issue into their CAP as CR 2157978, (2) replaced 1NW-61B with the original design piping installed and entered this issue into CAP as CR 2161153, and (3) concluded there were no adverse effects to the diesel generator (DG) caused by this unloaded operation and entered this issue into the CAP as CR 21666032. The failure to follow procedure AD-HU-ALL-0004 was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure adherence attribute of the mitigating systems cornerstone, and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, failing to follow AD-HU-ALL-0004 could result in undetected degradation of plant equipment to perform its intended safety functions. The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency confirmed to result in a loss of operability or functionality, did not represent a loss of system safety function, did not result in a loss of safety system function for a single train for greater than TS allowed outage time and did not result in a loss of safety function of one or more non-TS trains of equipment designated as risk significant for greater than 24 hours. The finding had a cross-cutting aspect of procedure adherence in the area of human performance, because the licensee failed to follow procedure AD-HU-ALL-0004 during implementation of plant maintenance, engineering changes and testing. (H.8)
05000414/FIN-2017011-0130 September 2017 23:59:59CatawbaNRC identifiedFailure to Adequately Establish and Adjust Preventive Maintenance for Emergency Diesel Generator Excitation System Diodes.To Be Determined (TBD): The inspectors identified an AV of Technical Specification 5.4.1.a, Procedures, for the licensees failure to adequately develop and adjust the preventive maintenance strategy for the emergency diesel generator (EDG) excitation system in accordance with AD-EG-ALL-1202, "Preventive Maintenance and Surveillance Testing Administration." The inspectors also identified an associated AV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B, Criterion XVI, Corrective Actions, for the failure to correct a condition adverse to quality associated with elevated operating temperatures of EDG excitation system diodes. This resulted in the failure of an EDG excitation system diode and overcurrent trip of the 2A emergency diesel output breaker during a surveillance test performed on April 11, 2017. The licensee entered this condition into their corrective action program as Condition Report 2116069. The 2A EDG was returned to service on April 14, 2017 follo wing replacement of the excitation system diodes. The failure to adequately develop and adjust preventive maintenance activities in accordance with AD-EG-ALL-1202, thus allowing a condition adverse to quality to remain uncorrected, was a performance deficiency. This performance deficiency was more than minor because it affected the mitigating systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems and components that respond to initiating events to preclude undesirable consequences (i.e. core damage). Spec ifically, failure to adjust the preventive maintenance activities for the EDG excitation sy stem by incorporating operating experience, corrective maintenance history, and structures, systems, and components (SSC) performance history led to the failure of diode CR4 in the EDG excitation system and caused the 2A EDG output breaker to trip open on April 11, 2017. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, the inspectors determined that the issue affected the mitigating systems cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, the inspectors determined that the issue required a detailed risk evaluation because the finding represents an actual loss of function of a single train for greater than its technical specification allowed outage time. This finding has a cross-cutting aspect of oper ating experience in the area of problem identification and resolution, because the organiza tion did not systematically and effectively evaluate relevant internal and external operating experience in a timely manner. Specifically, Condition Report 1566561 doc umented industry operating experience regarding EDG excitation system diodes failing at an increased rate and that operating experience was not effectively implemented and institutionalized through changes to station processes, procedures, and equipment. This issue is indicative of current performance because the station did not take effective corrective actions to address the degradation of the EDG excitation system
05000413/FIN-2017002-0130 June 2017 23:59:59CatawbaNRC identified10 CFR 50.59 Evaluation of a Change to an Engineered Safety Features Actuation (ESFAS) Test ProcedureThe inspectors selected the six operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the attachment. Unit 1, Following the 1A DG periodic test on April 18, 2017, a 10 drop per minute lube oil leak from the 1A engine driven lube oil pump was identified, CR 2117628 Unit 2, DG-2A Power-driven Potentiometer pre-position circuit, CR 2116554 Unit 2, Acoustic monitors for the pressurizer safety valves, CR 2125238 Unit 1, Faint abnormal odor on 1 DG control panel A, CR 2132262Unit 1, 1A EDG kilowatts spiked from 900 kw to 7000 kw when jumper was placed in circuit for testing, CR 2118549 Unit 2, Questions on auxiliary shutdown panel supply unit, CR 2124814 b. Findings(Opened) Unresolved item (URI): 10 CFR 50.59 Evaluation of a Change to an Engineered Safety Features Actuation (ESFAS) Test ProcedureIntroduction: The inspectors identified a URI associated with the implementation of a procedure change to the Unit 1 auxiliary shutdown panel (ASP) room air conditioning system. Additional information is needed to determine if a performance deficiency exists.Description: In November 2015, the licensee changed procedure PT/1/A/4200/009, Engineering Safety Features Actuation periodic test (ESFAS), to allow testing of the 1A ASP room air conditioning unit while it was unavailable. A URI was identified because the change verified the ESFAS Sequenced On light was lit, where the previous version of the procedure confirmed the air conditioning unit was running. The licensee did not perform a 50.59 evaluation, and the inspectors determined the change may affect the intent of the surveillance requirement.The licensee has initiated a 50.59 evaluation to determine the impact of the change relative to ESFAS testing requirements. The inspectors will review the completed evaluation to determine if a performance deficiency exists. The licensee documented this issue and background information in their corrective action program as CR 2124814. (URI 05000413/2017002-01, 10 CFR 50.59 Evaluation of a Change to an Engineered Safety Features Actuation (ESFAS) Test Procedure).
05000413/FIN-2017007-0131 March 2017 23:59:59CatawbaNRC identifiedFailure to Translate Design Requirements into Operating Procedures for NW SystemGreen: The NRC identified a non-cited violation of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the limiting high pressure design requirement of the containment valve injection water (NW) system surge chamber into station proc edures. Specifically, the licensee failed to translate the NW surge chamber high pressure design limit of 85 psig from calculation CNC-1223.19-00-0004, NW system setpoint ca lculation, Rev. 7, into procedure OP/1/A/6200/019, Containment Valve Injection Water System, Rev. 36, to ensure the NW system could perform its intended safety function during a design basis accident. The licensee entered this issue into their corrective action program as action request 02096392, reviewed the issue for current and past operability, and issued an operations guide to limit the NW surge chamber pressures to 80 psig. The performance deficiency was determined to be more than minor because it adversely affected the design control attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to translate the 85 psig NW surge chamber pressure limit into procedures resulted in exceeding the NW surge chamber high pressure limit, which could result in an inability of the safety re lated nuclear service water system to provide makeup water to the NW surge chamber and result in entrainment of nitrogen gas in the surge chamber outlet. The team determined the finding to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containmen t, containment isolation system, and heat removal components, and the finding did not involve an actual reduction in function of hydrogen igniters in the reactor containment. This finding was assigned a cross-cutting aspect of Evaluation in the Problem Identification and Resolution Area because the finding was indicative of present licensee performance, and the licensee did not thoroughly evaluate the issue identified in ARs 01912139 and 01912453 after the revision to the calculation was completed to ensure that the correct high pressure NW surge chamber design requirement would have been translated into procedures (P.2)
05000413/FIN-2016004-0131 December 2016 23:59:59CatawbaSelf-revealingFailure to Follow Lockout Relay Testing ProcedureA self-revealing Green non cited violation (NCV) of Technical Specification (TS) 5.4.1, Procedures, was identified for the licensees failure to follow procedure IP/2/A/4971/086, 2ETA 4160V Switchgear Lockout Relays, during relay testing, resulting in inadvertently tripping the A control room area chilled water system (CRACWS) compressor. Specifically, not following the procedure resulted in tripping the A CRACWS compressor and entering TS 3.7.11, Control Room Area Chilled Water System (CRACWS). As corrective actions, the licensee started the B CRACWS chiller, completed the testing on the A CRACWS chiller and returned it to operable. The licensee entered this issue as condition report (CR) 2062216. The inspectors determined the failure to follow procedure IP/2/A/4971/086 was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure adherence attribute of the mitigating systems cornerstone, and it adversely impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, not following the procedure resulted in the unplanned inoperability of the A train of CRACWS. Using IMC 0609, Significance Determination Process, Phase 1 screening worksheet of the SDP, this finding was determined to be of very low safety significance because it was not a design or qualification deficiency confirmed to result in a loss of operability or functionality, did not represent a loss of system safety function, did not result in a loss of safety system function for a single train for greater than TS allowed outage time, did not result in a loss of safety function of one or more non-TS trains of equipment designated as risk significant for greater than 24 hours, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect of procedure adherence in the area of human performance because the licensee failed to follow procedure IP/2/A/4971/086 during lockout relay testing. (H.8)
05000413/FIN-2016003-0130 September 2016 23:59:59CatawbaLicensee-identifiedLicensee-Identified ViolationThe licensee identified a non-compliance with Operating License Condition 2.C.(5), for Units 1 and 2, for the failure to protect one of the redundant trains of equipment needed to achieve post-fire SSD from fire damage. Specifically, the licensee failed to use one of the means described in Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1, Item C.5.b.2 to ensure that one of the redundant trains of equipment necessary to achieve and maintain hot shutdown conditions was protected from fire damage. Description: On June 2, 2014, the licensee submitted LER 413/2014-002-00 with Revision 01 submitted on December 1, 2014, which documented discovery of cable routing issues and postulated fire-induced circuit failures that could prevent operation or cause maloperation of equipment required to achieve SSD in the event of a fire. This condition was identified during the licensees transition to National Fire Protection Association Standard 805 (NFPA 805). During the transition to NFPA 805, the licensee identified multiple instances of cables for equipment required to achieve SSD not meeting the separation requirements of the current licensing basis. The licensee determined that this condition existed for 22 fire areas (FAs) across both units. The licensee characterized these issues as variance(s) from deterministic requirements (VFDRs). The conditions identified in the LER are related to VFDRs that met the following criteria: 1) VFDRs that required a plant modification to meet the fire risk criteria of NFPA 805, or 2) VFDRs where a potential concern existed with respect to NRC Information Notice (IN) 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire, dated February 28, 1992. The licensee determined that the deficiencies existed because of latent design deficiencies in the cable routing and circuit design. This LER was applicable to Units 1 and 2. Upon discovery, the licensee entered this issue into their corrective action program as PIP C-1401427, and implemented compensatory actions in the form of fire watches and/or control of transient combustible material for the affected FAs. Analysis. Failure to protect one redundant train of cables and equipment necessary to achieve post-fire SSD from fire damage was a performance deficiency. This finding was more than minor because it was associated with the reactor safety mitigating system cornerstone attribute of protection against external events (i.e., fire). Specifically, failure to protect safe shutdown cables and equipment from fire damage negatively affected the reactor safety mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this issue relates to fire protection and this noncompliance was identified as a part of the sites transition to NFPA 805, this issue is being dispositioned in accordance with Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) of the NRC Enforcement Policy. In order to verify that this non-compliance was not associated with a finding of high safety significance (Red), inspectors reviewed qualitative and quantitative risk analyses performed by the licensee. These risk evaluations took ignition source and target information from the licensees fire probabilistic risk assessment to demonstrate that the significance of the non-compliances were less-than-Red (i.e. CDF less than 1E-4/year). Inspectors determined that cables associated with some of the VFDRs were not located in the zone of influence (ZOI) of any credible ignition source. For cables that were located in the ZOI of a credible ignition source, inspectors were able to perform a calculation to determine the change in conditional core damage probability (CCDP), based on the postulated fire-affected equipment not being available. Based on these screenings, inspectors determined that the significance of this non-compliance was lessthan-Red. A bounding risk assessment performed by a regional Senior Risk Analyst (SRA) reviewed the licensee and inspector risk evaluations and confirmed the CDF risk increase due to this condition was less than 1E-4, and therefore less than RED. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Enforcement. Operating License Condition 2.C.(5), for Units 1 and 2, requires that the licensee implement and maintain in effect all provisions of the approved FPP as described in the UFSAR, as amended, for the facility and as approved in the SER through Supplement 5. BTP CMEB 9.5-1, which incorporated the guidance of Appendix A to BTP ASB 9.5-1 and the technical requirements of Appendix R to 10 CFR 50, established the regulatory and licensing requirements for the FPP at Catawba Nuclear Station (CNS). The CNS FPP was reviewed against and approved for conformance with BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.b.1, requires that fire protection features be provided that are capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot standby conditions from either the control room or emergency control station(s) is free from fire damage. BTP CMEB 9.5- 1, Item C.5.b.2 requires one redundant train to be protected from fire damage by one of the following specified methods: (a) separation of cables and equipment by a fire barrier having a 3-hour rating, (b) separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and with fire detectors and an automatic fire suppression system in the fire area, or (c) enclosure of cables and equipment in a fire barrier having a 1-hour rating and with fire detectors and an automatic fire suppression system in the fire area. Contrary to the above, the licensee failed to use one of the means described in BTP CMEB 9.5-1, Item C.5.b.2 to ensure that one of the redundant trains of equipment necessary to achieve and maintain hot shutdown conditions was protected from fire damage. Specifically, on April 2, 2014, the licensee identified the failure to protect equipment in accordance with the current licensing basis. The licensee determined that fire damage could prevent operation of, or cause maloperation of, components that were required to achieve and maintain SSD. This condition has existed since initial plant startup for Units 1 and 2. The licensee entered this issue into the corrective action program (PIP C-14-1427) and implemented compensatory measures in the form of fire watches and/or control of transient combustible material for the affected FAs. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, it was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, it was not likely to have been previously identified by routine licensee efforts, it was not willful, and it was not associated with a finding of high safety significance (Red).
05000413/FIN-2016002-0230 June 2016 23:59:59CatawbaNRC identifiedFailure to Implement Effective Corrective Actions to Prevent Diesel Generator Connecting Rod Bearing RotationsAn NRC identified Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to implement effective corrective actions to prevent repetition of a significant condition adverse to quality regarding connecting rod bearing rotations on the 1A diesel generator (DG). Specifically, the number 6 connecting rod was found rotated approximately 190 degrees following a 24 hour diesel run. The licensee replaced the rotated bearing and implemented modifications on all four Catawba DGs to minimized voiding in the engine driven lube oil pump suction piping. The licensee entered this issue into their corrective action program as CR 2021799. The licensees failure to identify a lubricating oil design discrepancy during the root cause investigation for 1A and 1B DG bearing rotations in 2014 was a PD. The PD was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that that respond to initiating events to prevent undesirable consequences. Specifically, the rotation of the 1A DG number 6 bearing resulted in approximately 60 hours of unavailability to replace the bearing. The finding was determined to be of very low safety significance, Green, based on the Phase 1 screening criteria found in IMC 609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, as the finding did not represent a loss of a system and/or function, and did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time. This finding had a cross-cutting aspect of evaluation, as described in the problem identification and resolution cross-cutting area because the licensee failed to fully evaluate diesel lube oil system discrepancies that contributed to DG connecting rod bearing rotations during the root cause investigation of previous bearing rotation events in 2014. (P.2)
05000413/FIN-2016002-0130 June 2016 23:59:59CatawbaSelf-revealingFailure to Adequately Implement RHR Operating ProcedureA self-revealing Green NCV of Technical Specifications (TS) 5.4.1.a, Procedures, was identified for the licensees failure to adequately implement a procedure for the operation of the Unit 1 residual heat removal (RHR) system. As a result, the breaker for the 1B RHR pump loop suction valve was left open, which resulted in the 1B train of emergency core cooling system (ECCS) being inoperable for greater than its TS allowed outage time. The licensee took immediate corrective actions to close the breaker and restore operability of the 1B train ECCS. The licensee entered this issue into their corrective action program as condition report (CR) 2014866. The licensees failure to adequately implement RHR system operating procedure, OP/1A/6200/004, Shutdown and Alignment for Standby Readiness, prior to plant startup was a performance deficiency (PD). The PD was determined to be more than minor because it was associated with the configuration control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the performance deficiency resulted in the breaker for the 1B RHR pump loop suction valve being left open and the1B train of ECCS being inoperable for greater than its TS allowed outage time. The inspectors evaluated the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Section B and determined the finding to be of very low safety significance (Green) because the finding did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time because 1ND37A (redundant decay heat removal (ND) 1B pump suction from reactor coolant (NC) Loop C) was still be able to provide the required permissive signal to open 1ND136B (ND supply to safety injection (NI) pump 1B). The performance deficiency had a cross-cutting aspect of teamwork in the area of human performance because operations did not communicate and coordinate activities associated with the RHR system to ensure nuclear safety is maintained. (H.4)
05000413/FIN-2016201-0131 March 2016 23:59:59CatawbaNRC identifiedSecurity
05000413/FIN-2015004-0131 December 2015 23:59:59CatawbaSelf-revealingFailure to Adequately Implement In-service Test Procedure for the Unit 1 Standby Makeup PumpA Green self-revealing non-cited violation of Technical Specification (TS) 5.4.1, Procedures, was identified for the licensees failure to adequately implement their inservice test procedure for the Unit 1 standby makeup pump (SMP). Operators performed procedure steps out of sequence which resulted in the pumps discharge relief valve lifting, requiring valve replacement. The licensee entered this issue into their corrective action program as nuclear condition report (NCR) 1954266. The performance deficiency was considered to be more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the SMP was unavailable to perform its safety function during unplanned testing and maintenance. The internal events risk contribution was determined by the inspectors to be 3E-7 and thus required a senior reactor analyst to review for external events and large early release frequency (LERF) to ensure the finding was below the Green/White threshold. The external events contribution was determined to be 5E-7 and thus the total risk was 8E-7 and core damage frequency (CDF) was determined to be the limiting metric. Consequently the finding was determined to be of very low safety significance (Green). This finding had a cross-cutting aspect of avoid complacency, as described in the human performance cross-cutting area, because the operators failed to implement appropriate error reduction tools such as formal three-way communications while performing the SMP surveillance procedure. (H.12)
05000414/FIN-2015003-0130 September 2015 23:59:59CatawbaNRC identifiedFailure to Promptly Replace a Frequently Operated Sliding LinkAn NRC identified non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to promptly implement corrective actions to replace a frequently operated sliding link associated with the 2A train auxiliary feedwater (CA) control circuitry. As a result, the sliding link failed prior to replacement which affected the function to automatically swap from the normal source to the assured source (nuclear service water) on low suction pressure to the 2A motor driven CA pump. The licensee replaced the failed sliding link and entered the issue into their corrective action program. The inspectors determined that the licensees failure to promptly implement corrective actions for a previously identified vulnerability with frequently operated sliding link E-12 was a performance deficiency (PD). The PD was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failed sliding link resulted in the inoperability of the 2A train of CA. The finding was determined to be of very low safety significance because of the multiple sources of water available to the CA pump before the assured source was needed, and the short duration that the steam generator injection lines valves were closed. This finding had a cross-cutting aspect of resolution (P.3), as described in the problem identification and resolution cross-cutting area as the licensee failed to replace sliding link E-12 in a timely manner commensurate with its safety significance.
05000413/FIN-2015012-0130 June 2015 23:59:59CatawbaNRC identifiedFailure to Analyze the Spurious Operation of Control Room Area Ventilation Valves and the Adverse Impact on Control Room HabitabilityThe NRC identified an NCV of the Unit 1 and 2 Catawba Nuclear Station (CNS) Facility Operating License, Condition 2.C.5, for the failure to analyze the spurious operation of two motor operated valves (MOVs) in the control room area ventilation system (CRAVS) and the adverse impact on control room habitability. The licensee entered the issue in its correction action program as action request (AR) 01930126 and a continuous fire watch was already in place due to deficiencies identified during the sites ongoing NFPA 805 licensing activities. The failure to analyze the spurious operation of two MOVs in the CRAVS and the adverse impact on control room habitability was a performance deficiency (PD). The performance deficiency was more than minor because it was associated with the protection against external events (i.e. Fire) attribute of the Initiating Events Cornerstone and it adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the finding could be reasonably viewed as a precursor to a significant event based on smoke migration into the control room that could challenge control room habitability and lead to an evacuation of the control room. This PD was the result of degraded defense-in-depth features that limit the effects of a fire to one fire area. The finding was screened as Green because the reactors would be able to reach and maintain safe shutdown utilizing the standby shutdown facility. No cross cutting aspect was assigned because the finding was not indicative of current licensee performance.
05000413/FIN-2015012-0230 June 2015 23:59:59CatawbaNRC identifiedFire Protection Program Change did not meet CNS License Condition Requirement 2.C.5 for Units 1 and 2The NRC identified a non-cited Severity Level IV violation of the Unit 1 and 2 CNS Facility Operating License, Condition 2.C.5, for the failure to implement and maintain in effect all provisions of the approved fire protection program (FPP). Specifically, the licensee made a change to the approved FPP which involved the de-rating of a credited three hour fire barrier between the control room and the cable spreading room(s) to only a pressure and smoke barrier. The licensee entered the issue in its corrective action program as AR 01932211 and it was added to existing fire watches for the area. The failure to comply with the CNS Operating License Condition 2.C.5 for a change to the approved FPP involving the de-rating of a credited three hour fire barrier between the control room and the cable spreading room(s) was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of protection against external events (i.e. Fire.) The performance deficiency negatively affected the cornerstone objective in that the change to the FPP had the potential to adversely affect the availability of the control room to achieve and maintain stable plant conditions due to the increased likelihood of control room abandonment in the event of a fire in the cable spreading rooms. The licensees failure to submit the FPP change to the NRC was determined to impede the regulatory process because the FPP change required NRC review and approval prior to implementation. The finding was screened as Green because based upon inspection of the affected barriers, the inspectors determined that the barriers would provide a 1-hour or greater fire endurance rating. This violation was determined to be a Severity Level IV violation because the associated finding was evaluated by the SDP as having very low safety significance (i.e., Green finding). No cross cutting aspect was assigned because the finding was not indicative of current licensee performance.
05000413/FIN-2015301-0130 June 2015 23:59:59CatawbaLicensee-identifiedLicensee-Identified ViolationThe following Severity Level IV violation was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation. Following the facilitys administration of the initial written examination on May 28, 2015, the licensee identified that an earlier version of the examination was inadvertently provided to the RO applicants. The licensee immediately informed the NRC. The earlier version of the examination did not include the changes that were made to resolve NRC comments provided during the preexamination review of the written examination. This earlier version of the examination had not been approved by the NRC for administration to the license applicants. 10 CRF 55.49, Integrity of examinations and tests states, in part, that facility licensees shall not engage in any activity that compromises the integrity of any test or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to the above, on May 28, 2015, the licensee administered an unapproved RO written examination, an activity that compromised the integrity of the written examination. The RO applicants did not get the benefit of the question enhancements that occurred during the examination review. The SRO applicants experienced a higher quality exam than that of the RO applicants. This is neither equitable nor consistent. The unapproved version of the exam was subsequently reviewed by the NRC and was determined to be valid. See enclosure 3 to this report to review the analysis of the administered written exam for validity of the exam. A violation of 10 CFR 55.49 is a violation that potentially impacts the regulatory process, because the examination results are used by the NRC to make licensing decisions. An improperly administered examination has the potential to provide inaccurate information to the NRC regarding the competence of the applicants. There were no actual or potential safety consequences. This violation is being treated as a Severity Level IV non-cited violation consistent with Section 2.3.2.a. of the NRC Enforcement Policy. The violation was entered into the licensees corrective action program as Nuclear Condition report 01931989.
05000413/FIN-2014005-0131 December 2014 23:59:59CatawbaLicensee-identifiedLicensee-Identified ViolationUnit 1 and 2 Facility Operating Licenses, Condition 2.C.5, Fire Protection Program, required that the licensee shall implement and maintain in effect all provisions of th approved fire protection program as described in Section 9.5.1 of the UFSAR as amended and approved in the safety evaluation report through Supplement 5. Safety Evaluation Report Section 9.5.1.8, Fire Protection for Specific Station Areas, stated in part, that each DG is located in a different fire area separated by a threehour fire rated wall and that all cable and piping penetrations through the fire rated barriers are fitted with a three-hour fire rated penetration seal. 14 Contrary to the above, from October 2008 until November 2014, provisions of the approved fire protection program were not maintained in effect for the DG area. Penetration Firestop 306W102, separating 2A and 2B DG rooms, was determined to be non-functional due to inadequate filler material. This represented a degradation of the separation requirements for a three-hour fire barrier. The licensee initiated PIP C-14-10350 to address and correct this issue. This finding screened as Green according to Inspection Manual Chapter 0609, Appendix F, Fire Confinement (Task 1.4.3) due to the presence of a fully functional automatic suppression system on either side of the fire barrier.
05000413/FIN-2014004-0230 September 2014 23:59:59CatawbaNRC identifiedFailure to adequately implement a prompt determination of operability for diesel generator lube oil temperatureA NRC-identified non-cited violation (NCV) was identified for the licensees failure to adequately implement their administrative procedure for operability/functionality assessments as applied to the evaluation of Unit 1 diesel connecting rod bearing rotations. The inspectors determined that the licensees failure to implement the requirements of NSD 203 was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective to ensure availability of systems that respond to initiating events in that stagnant DG lube oil temperature could have decreased below the operability limit that was subsequently established by the licensee. The finding was determined to be of very low safety significance (Green) in that it does not represent an actual loss of safety function of a single train for greater than its TS allowed outage time. This finding had a cross-cutting aspect of evaluation (P.2), as described in the Problem Identification and Resolution cross-cutting area as the licensee failed to adequately evaluate the DG lube oil standby temperature during investigation of DG connecting rod bearing rotations.
05000414/FIN-2014004-0130 September 2014 23:59:59CatawbaNRC identifiedFailure to implement fire impairment requirements for a degraded committed fire barrierAn NRC-identified non-cited violation (NCV) of the Unit 2 Facility Operating License, Condition 2.C.5, Fire Protection Program, was identified for failure to implement and maintain all provisions of the approved fire protection program. The inspectors identified a degraded committed fire barrier that was not evaluated as a fire impairment. The inspectors determined the failure to perform the required fire impairment actions was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating System Cornerstone attribute of Protection against External Factors (fire) and adversely affected the cornerstone objective in that there was no reasonable assurance the degraded fire barrier would fulfill its designed 3-hour fire rating. The inspectors determined the finding was determined to be of very low safety significance (Green) because a fully functioning automatic suppression system on either side of the barrier was in place. This finding had a cross-cutting aspect of identification (P.1), as described in the Problem Identification and Resolution cross-cutting area as the licensee failed to enter the damaged fire barrier into their corrective action program which prevented the appropriate fire protection program reviews and compensatory actions.
05000413/FIN-2014004-0330 September 2014 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation10CFR50, Appendix B, Criterion XVI required in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Significant conditions adverse to quality must be corrected to prevent recurrence. Contrary to the above, from 2006 to May, 2014, the licensee failed to prevent recurrence for a significance condition adverse to quality in that the licensee did not establish corrective actions for standby lube oil conditions that contributed to three DG bearing rotations discovered during maintenance inspections on the 1A and 2A DGs. The inspectors determined that the violation was of very low safety significance (Green) because the rotated bearings did not prevent the DGs from performing their safety function. The issue is documented in the licensees corrective action program as PIP C-14-2352.
05000413/FIN-2014009-0131 March 2014 23:59:59CatawbaNRC identifiedReview the Root Cause Analysis for the #7 Bearing Rotation and Effectiveness of Previous Corrective ActionsThe inspectors reviewed the RCA from the 2006 bearing failure of the 1A DG and the resultant corrective actions. The inspectors also reviewed the interim actions as they related to the most recent #7 bearing rotation on the 1A DG. The licensee was still conducting the RCA for the #7 bearing rotation and was also reviewing their previous corrective actions to prevent recurrence for the 2006 bearing failure. The completed RCA and corrective actions will need to be reviewed to determine if the 2006 CAPRs were ineffective and if the new CAPRs are adequate. This is identified as URI 05000413/2014009-01: Review the Root Cause Analysis for the #7 Bearing Rotation and Effectiveness of Previous Corrective Actions.
05000413/FIN-2014002-0131 March 2014 23:59:59CatawbaNRC identifiedNOED 14-2-001 to allow bearing replacement and testing of the 1A diesel generatorThe inspectors identified an unresolved item (URI) regarding NOED 14-2-001 granted on March 6, 2014. The inspectors reviewed NOED 14-2-001 and related documents to determine the accuracy and consistency with the licensees assertions and implementation of the licensees compensatory measures and commitments, those of which included deferring non-essential surveillances and other maintenance activities on the 1A DG, the auxiliary feed water (AFW) turbine-driven pump, the standby shutdown system and switchyard, and posting of dedicated fire watches in selected risk significant areas. Additional inspection is required to conduct a review of the LER, root cause, and planned corrective actions. This URI is identified as URI 05000413/2014002-01, NOED 14-2-001 to allow bearing replacement and testing of the 1A diesel generator.
05000413/FIN-2014009-0231 March 2014 23:59:59CatawbaNRC identifiedReview of Completed PDO and Compensatory ActionsThe inspectors reviewed the licensees corrective actions and noted that while an immediate determination of operability (IDO) had been performed, a prompt determination of operability (PDO) had not been initiated. The licensee had established interim actions, but the inspectors questioned the completeness of those actions relative to the LO temperature difference and effects it may have on the bearing positions. The inspectors also questioned the current bearing crush on the DGs (Unit 1 and Unit 2). The licensee initiated a PDO with a scheduled completion date of April 17, 2014. This is identified as URI 05000413/2014009-02: Review of Completed PDO and Compensatory Actions.
05000413/FIN-2013005-0131 December 2013 23:59:59CatawbaNRC identifiedFailure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection ProgramAn NRC-identified NCV of the Fire Protection Program (FPP) required by 10 CFR 50.48 and License Condition 2.C.5, was identified for failing to adequately implement transient combustible controls. Transient combustible material stored adjacent to the B rod control motor generator (MG) set and in front of a manual hose station was not in an established housekeeping area, and was not evaluated for acceptability by the site fire protection engineer (FPE) as required by the FPP specified procedure, Nuclear System Directive NSD-313, Control of Combustible and Flammable Material. The failure to control transient combustibles in the Unit 2 electrical penetration room in accordance with NSD-313 was a performance deficiency. The performance deficiency was more than minor because if left uncorrected it could lead to a more significant safety concern in that an electrical fault in the adjacent MG set panel could ignite the combustibles which could lead to a potential plant transient. The finding was determined to be of very low safety significance (Green) as the combustibles did not meet the criteria requiring a phase 2 or 3 analysis as described in IMC 0609, Appendix G, Attachment 1, Checklist 2. This finding had a cross cutting aspect in the Resources component of the area of Human Performance because the personnel involved were not adequately trained in the procedural requirements of NSD-313.
05000413/FIN-2013004-0130 September 2013 23:59:59CatawbaSelf-revealingInadvertent Operation of the Unit 1 Standby Makeup PumpA self-revealing finding was identified for inadvertent operation of the Unit 1 Standby Makeup Pump (SMP) during the performance of a job performance measure (JPM). The licensed operator performing the JPM operated plant equipment which was contrary to procedural requirement to only simulate equipment operation. The inspectors determined that operation of plant equipment during the performance of a JPM was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems attribute of Equipment Performance and adversely affected cornerstone objective because the SMP was unavailable to perform its safety function during unplanned testing and maintenance. The finding was determined to be of very low safety significance (Green), based on the results of a detailed risk assessment and an external events. The finding was not assigned a cross cutting aspect because the PD resulted from an isolated human performance error.
05000413/FIN-2013403-0130 June 2013 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation
05000413/FIN-2013403-0230 June 2013 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation
05000413/FIN-2013003-0130 June 2013 23:59:59CatawbaNRC identifiedFailure to Inspect Control Room Door SealAn NRC-identified non-cited violation (NCV) of Technical Specifications, 5.5.16, Control Room Envelope Habitability Program, was identified for failure to implement and maintain all provisions of the program. The seals on the control room doors were not being inspected and maintained as required. The performancy deficiency (PD) was more than minor because, if left uncorrected, the seals could continue to degrade and challenge the control room habitability envelope. The inspectors determined the finding was of very low safety significance (Green) because the lack of control room door seal inspections only represented a degradation of the radiological barrier function provided for the control room. The cause of this finding was related to the cross cutting-aspect of providing complete, accurate and up-to-date design documentation, procedures, and work packages of the Human Performance cross-cutting area because the necessary procedures and work packages were inadequate to assure compliance with the licensees Control Room Envelope Habitability Program.
05000413/FIN-2013007-0130 June 2013 23:59:59CatawbaNRC identifiedFailure to Identify and Correct Deficiencies in the Emergency Lighting System Preventive Maintenance ProgramThe inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50.65, Maintenance Rule, for the licensee\'s failure to identify and correct deficiencies in the 8-hour emergency light preventive maintenance program. The licensee entered the issues into their corrective action program as PIPs-C-13-03973, C-13-00996, C-13-03536 and C-13-03537. The deficiency will be mitigated by the operators use of flashlights until the deficiencies are corrected. The licensee\'s failure to identify and correct deficiencies in the emergency light preventive maintenance program was a performance deficiency. The performance deficiency was more than minor because it adversely affected the Mitigating Systems cornerstone of protection against external events. Specifically, the high failure rate of emergency light testing resulted in a lack of reasonable assurance that adequate lighting would be available during fire events. The inspectors determined the finding to be of very low safety significance (Green) because the inspectors noted that operators were required to obtain and carry flashlights. The inspectors identified a cross-cutting aspect in the corrective action program component of the problem identification and resolution area.
05000413/FIN-2013405-0331 March 2013 23:59:59CatawbaNRC identifiedSecurity
05000413/FIN-2013405-0431 March 2013 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation
05000413/FIN-2013405-0531 March 2013 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation
05000413/FIN-2013405-0131 March 2013 23:59:59CatawbaNRC identifiedSecurity
05000413/FIN-2013405-0231 March 2013 23:59:59CatawbaNRC identifiedSecurity
05000413/FIN-2012005-0231 December 2012 23:59:59CatawbaNRC identifiedAssociated Circuit Issues from 2004 Triennial Fire Protection AuditCatawba License Condition 2.C(5), Fire Protection Program, stated, in part, that Duke Energy Carolina, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). UFSAR 9.5.1, Fire Protection System, stated, in part, that Catawbas original Fire Protection Program was submitted by letter as the Fire Protection Review which included a response to Branch Technical Position (BTP) APCSB 9.5-1, General Guidelines for Plant Protection. The BTP stated, in part, that redundant safety-related systems that are subject to damage from a single fire hazard should be protected by a combination of fire retardant coatings and fire detection and suppression systems, or a separate system to perform the safety function be provided. NUREG 0954, Safety Evaluation Report related to the operation of Catawba Nuclear Station, Units 1 and 2, dated February 1983, documents the NRCs acceptance of the licensees commitment to Appendix A to Branch Technical Position ASB 9.5-1 for the fire protection program. The Fire Protection Review was documented and maintained in the Plant Design Basis Specification for Fire Protection. Contrary to the above, since initial plant operation, the licensee failed to provide a separate system to adequately perform the safety function of redundant safety-related systems subject to damage from a single fire hazard and not protected by a combination of fire retardant coatings and fire detection and suppression systems. The licensee did not have adequate procedures to operate the SSF in a timely manner to mitigate the effects of a fire-induced spurious opening of the unprotected PORVs and block valves to ensure the safety function they perform would be provided. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for these nonconformances in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, it was likely these issues would have been identified and addressed during the licensees transition to NFPA 805, they were entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, they were not likely to have been previously identified by routine licensee efforts, they were not willful, and they were not associated with a finding of high safety significance (Red). Therefore, the criteria of the interim Enforcement Policy and Section 11.05(b) of IMC 0305 have been met.
05000413/FIN-2012005-0131 December 2012 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation10 CFR 50 Appendix B Criterion XVI, Corrective Action, stated in part that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, on September 29, 2012, the licensee failed to correct a condition adverse to quality in a timely manner. The licensee determined that a 2B EDG speed indication malfunction did not affect operability and did not implement corrective actions at that time. Approximately 23 days later, the licensee determined that the speed indication malfunction was a result of a failed power supply that affected the automatic closure of the 2B EDGs output beakers which rendered the EDG inoperable. The resident inspectors, with the assistance of a senior risk analyst, performed a risk evaluation using the SAPHIRE 8 risk analysis software and determined the finding was of very low safety significance (Green). This issue was entered into the licensees corrective action program as PIP C-12-8991.
05000413/FIN-2012007-0230 September 2012 23:59:59CatawbaNRC identifiedInadequate Implementation of Procedure to Ensure EQ MOV Cycle Limit Is Not ExceededThe team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to establish a procedure to ensure that the requirements in EQMM 1393.01-A01-00, Environmental Qualification Maintenance Manual, were not exceeded to maintain the environmental qualification of motor-operated valves (MOVs). The licensee entered the issue into the corrective action program as PIP C-12-7121, declared MOVs 1KCC37A, 1WL807B, and 2KCC37A as operable but degraded/nonconforming, and instituted guidance to periodically review the cycles of all MOVs to ensure the maximum limit is not exceeded. The licensees failure to establish a procedure to ensure the MOV cycle requirements of EQMM 1393.01-A01-00, were not exceeded was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of procedure quality and adversely affected the cornerstone objective in that, the lack of procedural guidance to track the cycles of MOVs resulted in 1KCC37A, 1WL807B, and 2KCC37A exceeding their environmental qualification cycle limit of 2,000 cycles and decreased the reliability and capability of the MOVs. The team assessed the finding in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and determined the finding was of very low safety significance (Green) because the performance deficiency did not result in a loss of MOV operability. The finding was associated with the cross-cutting aspect of implementation and institutionalization of operating experience in the Operating Experience component of the Problem Identification and Resolution area.
05000413/FIN-2012004-0230 September 2012 23:59:59CatawbaNRC identifiedFailure to Maintain Requalification Examination IntegrityAn NRC-identified non-cited violation (NCV) of 10 CFR 55.49, Integrity of examinations and tests, was identified for the licensees failure to adhere to examination procedure standards that allow no more than 50 percent scenario overlap between examinations. The licensee subsequently revised the 2012 annual operating examination to preclude the scenario overlap issue that would have occurred and entered the issue in their corrective action program as PIP C-12-06949 and PIP C-12-06950. This performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective in that the failure to adhere to examination overlap standards adversely affected the quality of the administration of the operating exams. Using the Licensed Operator Requalification Significance Determination Process, this finding was determined to be of very low safety significance (Green) because no actual compromise of the examinations occurred. The cause of the finding was related to the cross-cutting aspect of procedures of the resources component of the cross-cutting area of Human Performance.
05000413/FIN-2012004-0330 September 2012 23:59:59CatawbaLicensee-identifiedLicensee-Identified Violation10 CFR 55.3 stated, in part, that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator. 10 CFR 50.54(l) stated, in part, that the (facility) licensee shall designate individuals to be responsible for directing the licensed activities of licensed operators, and that these individuals shall be licensed as senior operators pursuant to part 55 of this chapter. Contrary to the above, on June 15, 2012, and June 18, 2012, the facility licensee allowed a person to perform the function of a senior operator who was not licensed by the Commission to perform those functions. The individuals senior operator license had been terminated by the Commissions regional office on June 12, 2012, at the licensees request. The inspectors determined that the violation was not greater than very low safety significance (Green) due to the short time the individual performed the senior licensed operator function, and because the individual was in all other aspects fully qualified and proficient as a senior licensed operator. This issue was entered in the licensees corrective action program as PIP-C-12-5489.
05000413/FIN-2012007-0130 September 2012 23:59:59CatawbaNRC identifiedFailure to Develop Adequate Test to Ensure Minimum SMP Flow RequirementsThe team identified a non-cited violation of Catawba Nuclear Station Units 1 and 2 License Condition 2.C.5, Fire Protection Program, for the licensees failure to establish a leakage acceptance criteria past check valves that supported minimum, post-fire safe shutdown (SSD) design flow requirements of the standby shutdown system. The licensee entered the issue into the corrective action program as PIP C-12-7717 and conservatively limited the allowed Total Accumulative RCS (reactor coolant system) Leakage to gain additional standby makeup pump (SMP) flow margin. The licensees use of inadequate test acceptance criteria for back-leakage through check valves was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute in that, if backleakage through check valves 1(2)NV-46, 1(2)NV-57, 1(2)NV-68, and 1(2)NV-79 was to degrade to the allowed limits in the test procedure, the SMP would not be capable of meeting the 26 gpm reactor coolant system makeup requirement to support the standby shutdown system post-fire SSD function. The inspectors evaluated this issue in accordance with Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, and determined the finding to be of very low safety significance (Green). The finding was assigned the category of post-fire SSD and a low degradation rating that reflected the severity of the identified deficiency. There was no cross-cutting aspect associated with this finding because the condition existed since initial issuance of the test procedure and was not reflective of current licensee performance.
05000413/FIN-2012004-0130 September 2012 23:59:59CatawbaNRC identifiedInadequate 3 hour fire barrier between essential switchgear roomsAn NRC-identified Green non-cited violation (NCV) of the Unit 1 and 2 Facility Operating Licenses, Condition 2.C.5, Fire Protection Program, was identified for failure to implement and maintain all provisions of the approved fire protection program. The inspectors identified gaps in the emergency switchgear room (ESR) hatch covers separating two fire areas containing redundant safe shutdown equipment which were not evaluated. The licensee placed the issue into the corrective action program and implemented fire watches and prohibited storage of transient combustibles in the area. The inspectors determined the gaps in the ESR hatch covers was a performance deficiency (PD). The inspectors determined that the PD was more than minor because it was associated with the Mitigating System Cornerstone attribute of Protection against External Factors (fire) and adversely affected the cornerstone objective in that there was no reasonable assurance the gaps in the hatch covers would prevent fire propagation across the 3-hour fire rated barrier. The inspectors determined the finding was of very low safety significance (Green). The cause of this finding was related to the cross cutting-aspect to thoroughly evaluate problems such that the resolutions address causes and extent of condition as described in the corrective action program component of the Problem Identification and Resolution cross-cutting area.
05000413/FIN-2012009-0330 June 2012 23:59:59CatawbaSelf-revealingImproper Unit 2 Zone G ModificationA self-revealing finding was identified for the licensees failure to follow EDM-141, Procurement Specifications for Services. The licensee did not identify the blocking feature for the instantaneous underfrequency protective function in both the vendor specification and the supporting information provided to the vendor. The offsite power supply to Unit 2 would have been lost anytime there was a generator trip from high power and offsite power was provided from Unit 2 without this blocking feature. The licensee corrected the blocking function prior to unit restart. The performance deficiency was more than minor because, if left uncorrected, it would result in a more significant safety concern in that Unit 2 would have had a LOSP anytime the generator tripped from a high power condition. The inspectors determined the finding was of very low safety significance because the programming error was corrected prior to unit restart; therefore, there was no loss of safety function. The same cross-cutting aspect for the Unit 1 finding also applies to this finding; therefore, no separate cross-cutting aspect will be assigned to this finding.
05000413/FIN-2012009-0230 June 2012 23:59:59CatawbaNRC identifiedUnit 2 Offsite Power Circuits Inoperable Due to Improper Unit 1 Zone G ModificationSelf-revealing findings were identified for the licensees failure to follow EDM-141, Procurement Specifications for Services. The licensee did not identify the need for the blocking feature for the instantaneous underfrequency protective function in both the vendor specification and the supporting information provided to the vendor. The offsite power supply to Unit 1 would have been lost anytime there was a generator trip from high power without this blocking feature. This finding resulted in an apparent violation (AV) of Technical Specification (TS) 3.8.1, AC Sources Operating, for Unit 1 and TS 3.8.1, AC Sources Operating, and TS 3.8.2, AC Sources Shutdown, for Unit 2 because the installed modification resulted in inoperability of the offsite power source for both units. Unit 2 was impacted whenever offsite power was provided from Unit 1. The finding does not represent an immediate safety concern because the licensee corrected the blocking function prior to unit restart. The violation was placed in the licensees corrective action program as PIP C- 12-3403. The performance deficiency (PD) was more than minor because it affected the availability and reliability of the Equipment Performance attribute and adversely affected the Mitigating Systems cornerstone objective in that an offsite power supply would not have been available to mitigate expected operational transients and design basis events. For Unit 1, the significance was preliminarily determined to be within the range for a finding of substantial safety significance (Yellow). For Unit 2, the significance was preliminarily determined to be within the range for a finding of greater than very low safety significance (Greater than Green). The safety significance will be designated as To Be Determined (TBD) because the safety characterization is not final. The PD was directly related to the aspect of accurate design documentation in the component of Resources in the cross-cutting area of Human Performance in that the engineering design procedures were not complete because there was no requirement for verification of non safety-related design changes.