IR 05000414/1989019

Discusses Insp Rept 50-414/89-19 on 890616-28 & Forwards Notice of Violation.Violation Noted:On 890602,upper-range Pressurizer Transmitter Isolation Valves on Reactor Vessel Level Instrumentation Not Opened Prior to Entering Mode 3

ML20247C692
Person / Time
Site:	Catawba
Issue date:	08/31/1989
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
Shared Package
ML20247C696	List: IR 05000414/1989019 ML20247C702
References
EA-89-138, NUDOCS 8909140083
Download: ML20247C692 (3)

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AUG 814

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• : Docket No. -50-414-J 'R License No. NPF-52 EA 89-138'

L g . Duke Power. Company .

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ATTN: Mr. H. B. Tucker Vice President A Nuclear ProdJction Department 422 South Church Street Charlotte, North Carolina 28242 Gentlemen:-

SUBJECT: NOTICE OF VIOLATION -

(NRCINSPECTIONREPORT-NO.' 50-414/89-19)

This refers to the Nuclear Regulatory Commission (NRC) inspection at the Catawba

' facility en June 16 - June 28,'1989. .The inspection included a review of the

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circumstances surrounding an event where both channels of the Reactor Vessel Level Instrumentation System (RVLIS) on Unit 2 were discovered inoperable' by your staff on June 16, 198 The. report documenting this inspection was'sent.to you by letter dated J,1y 14,

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1989. - As a result' of this inspection, a significant failure to comply. with NRC regulatory requirements was identified'and, accordingly, NRC concerns relative to the insp'ection findings were discussed in Enforcement Conferences held on July 20, 1989.and August 15, 1989. The letter summarizing these Conferences

..was sent to you on August-29, 198 The. violation. described in the enclosed Notice of Violation (Notice) involved a

'1 failure to open the upper range pressure transmitte isolation valves on either channel of the Unit 2 RVLIS prior to entering Mode 3 on June 2,1989. The violation resulted from poor judgement, inattentics to detail and inadequate management controls for maintenance in several areas. A maintenance supervisor assigned two technicians, who were not qualified to perform unsupervised maintenance on RVLIS, to restore thF system to operable status. This action was not in accordance with the Employee Training and Qualifications System (ETQS) program. The supervisor incorrectly presumed that the task was simple enough for the technicians to perform, failing to comprehend the basis for the qualification requirements. The technicians failed to properly restore the system.to operable status due to their unfamiliarity with the system and the use :of an inadequate procedure. The technicians used a system calibration procedure in which inapplicable steps had been marked "N/A" by a second maintenance supervisor. The marking had been performed without adequate attention to detail resulting in the appearance that key restoration steps were not applicable. Furthermore, the inadequate restoration was not identified by a third supervisor, who reviewed the completed work packag PDR ADOCK 05000414 i\

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gyg 311989 Duke Power Company -2-You had the opportunity to prevent the inoperability of the RVLIS system during

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post-maintenance testing but failed to do so due to the inadequate scope of testing. Although your Maintenance Manual requires in Procedure 1.0 that a functional verification be performed on systems after maintenance to demon-strate that the component / system will operate as designed, and guidance is also provided stating that instruments should be verified for correct reading on local and remote gauges, your post-maintenance functional verification of the RVLIS system consisted of merely checking the reconnected instrument lines for leak You also had the opportunity to discover the RVLIS inoperability earlier had you performed a more complete channel check of the RVLIS. It was determined that >

although RVLIS is comprised of two channels each with three ranges, (lower, dynamic and upper) you only perform a channel check on the dynamic range when the reactor coolant pumps are running. Vendor documents provided information as to the expected readings of the upper range of RVLIS with pumps runnin Had that information been used as the basis for a channel check, your staff would have discovered the inoperable channels earlie In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation described in the enclosed Notice has been categorized as a Severity Level III violatio We are aware that there are other indicators of reduced reactor vessel level in addition to the upper range RVLIS, but we consider the unavailability of any required ranges of RVLIS, especially under the circumstances of this case, to be a significant regulatory concern. Normally, a civil penalty is assessed for a Severity III violation. However, in recognition of Duke's initiative in identifying the violation through a monthly RVLIS system walkdown, promptly reporting the event to the NRC, and taking comprehensive corrective actions, after consultation with the Director, Offi e of Enforcement, and the Deputy Executive Director for Nuclear Material Satety, Safeguards, and Operations Support, I have decided that a civil penalty will not be proposed in accordance with Section V.G.3 of the Enforcement Polic You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your re-sponse, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and results of future inspections the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be plat ed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No. 96-51 . - _ - _ _ .

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AUG 311989 Duke Power Company -3-Should you have any questions concerning this letter, please contact u

Sincerely,

/c/

Stewart D. Ebneter Regional Administrator Enclosure:

Notice of Violation cc w/ enc 1:

T. B. Owen, Station Manager Senior Resident Inspet!or - McGuire State of South Carolina -l I

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