ML19325C532
| ML19325C532 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/10/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910170012 | |
| Download: ML19325C532 (24) | |
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<, ' HA1.II.TUCKEH Ten.menown i Bl 1 vics reassoaser - (704) 073-4th34 "
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i o : (: . ' ',, $g[t , Ji f.S.1Niiclear Regulatory Commission Document Control Desk l C[, NH IWashington, D.C. '20555 ,
~ Sub,)ect: Catawba Nuclear Station Docket Nos. 50-413:and 50-414 NRC Inspection Report Nos. 50-413, 414/89-09 i Reply to Inspector Follow-up Items Gentlemen:
Enclosed.is the response to Inspector Follow-up Items identified in Inspection- t Report ~ 50-413, 414/89-09 issued July 10,.1989 by Albert V. Gibson. ! Very truly yours,- ' g - y l
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4 . Ital B. Tucker-WRC76/lcs r4
-xct- Mr. S.'D. Ebneter-
' Regional Administrator- ;
T Region II 101 Marietta Street, NW, Suite 2900 , Atlanta, Georgia 30323 Mr. W. T. Orders NRC Resident Inspector-Catawba Nuclear Station m. s \- t
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- - R. L.-;; Gill, Jr.
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- R. O. Sharpe - MNS ,
- 7. G. Hudss E. E Parris !
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REPLY TO A WEAKNESS (IFI) {l 413, 414/89-09-03 1 V Controls on the thermal power computer and its inputs are weak. This computer is used for normal determination of plant' power level and for adjusting the gain on the nuclear. , instruments. (Paragraph 2.b)
RESPONSE
- 1. Corrective Actions Taken and Results Achieved'. .
The-Unit 1 procedure used to perform a check of the : computer inputs to the thermal power calculation was added to the Catawba Periodic Test (CPT) test tracking , program. This was a committed action.
- 2. Corrective Actions to be Taken to Avoid Further Incidents.
The Maintenance Management Procedure concerning control of the Standing Work Roquest program will be revised to
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ensure that the cognizant System Exports roccive notification of any instrumentation that will exceed its normal. calibration frequency. This is a committed action.
- 3. :Date of Full Compliance.
Duke Power will be in full compliance by December 1, 1989.' 1 i
r~ns ; ilh , l :V , 3 DUKE POWER CCMPANY REPLY 'IO A WEAKNESS (IFI) 413, 414/89-09-04 One 10CFR50.59 Evaluation was weak concerning a modification to the nuclear service water pit strainer instrumentation. Annunciators described in the FSAR'were disabled for about 30 days with no written consideration of compensatory action. f
RESPONSE
.l. Corrective Actions Taken and Results Achieved.
A. A review of the 10CFR50.59 Evaluation was performed and it was determined that even though the RN Pit Screen Hi D/P annunciators were not specifically stated in the 10CFR50.59 Evaluation as being described in the FSAR, , it was apparent that the preparer knew this because the FSAR Section.9.2.1, Nuclear Service Water System, was listed as an FSAR Section consulted. It was also decided that the information contained on Page 3 of 3 of the evaluation answered the appropriate questions: Screening for'10CFR50.59 Applicability and Unreviewed Safety Question (USQ) Evaluation. Addressing what compensatory measures will be taken for removing a piece of equipment from service is not a concern of the + l 10CFR50.59 Evaluation. Any compensatory actions necessary when removing a piece of equipment from , service is determined by Operations and would be l- included in the body of the procedure. The need for compensatory action was listed in the 10CFR50.59 Evaluation for the level of the SNSWP because of the requirement of Tech. Spec. 3/4.7.5. The specific
- compensatory action was still not specified in the evaluation; instead, it was left up to the operator.
'2. Corrective Actions to be Taken to Avoid Further Incidents.
A. All modifications will be looked at on a case to case basis, but compensatory measures for a piece of equipment being removed from service will not normally be included in the 10CFR50.59 Evaluation.
- 3. Date of Full Compliance.
Duke Power is in full compliance now.
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l Jr. ^ DUKE POWER COMPANY. Page 1 of 2 t REPLY TO A WEAKNESS (IFI) 413, 414/89-09-05 s Auxiliary operators on rounds failed. to frisk immediately 1 after exiting contaminated areas.- (paragraph 2.c) , 1
RESPONSE
- 1. - Corrective Actions Taken and Results Achieved.- .
l A. The OSTI review was conducted immediately following refueling outages on Unit #1 and #2. Budget and manpower limitations resulted in. a dilution of normal decontamination resources
.during outages. As a result, approximately 15-Safety Related Pump Rooms were contaminated during the review period.
The decontamination program at the time of this- 1 response has achieved a condition where only three (3) of the Safety Related Pump Rooms' are contaminated. . Station Directive 3.8.3 (Contamination Provention, ' Control and Decontamination Responsibilitics) was , revised August 28, 1989 to simplify the frisking requirements for Operators performing routing surveillances. These changes will create a more officient work process and contribute to improved compliance. ,
- 2. ~ Corrective Actions to bc Taken to Avoid Further Incidents.
and manpower limitations exist, A. Since budget
' additional management attention can be directed to the particular category of contaminated safety related pump rooms as we assess our status- and develop decontamination plans. The Monthly Report <
documenting contamination status and decontamination efforts / plans will be revised to indicate under " Priority Items" a permanent category of " Contaminated Safety Related Pump Rooms". In addition, the Radiation Protection Monthly Status Report will be revised to indicate a category for " Contaminated Safety Related Pump Rooms". The availability of this information to station management will provide sufficient attention to maintain Safety Related Pump Rooms in acceptable condition to support Operations personnel performing routine inspections.
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Thes two;- reports , ref erenced ' ; will' be'~ revis'edf toi*includel a ' Lthe!above changes.4 Reports published after iSeptember} y"' y 3 ' 30,11989 willJbe in this'new format. 7, , Ja
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3gs y DUKE POWER COMPANY REPLY TO A WEAKNESS'(IFI). 413, 414/89-09-06. Control.of doors was weak, as indicated by the three open fire doors or security doors found by.the team. (paragraph 2.g.).
RESPONSE
- 1. Corrective Actions Taken and Results Achieved.
A. Upon notification of the prob 1cm with the' door to the diesel generator room (AX302) maintenance personnel. replaced the automatic closer and replaced the weather stripping which was preventing the door from completely closing. I
- The problem with the door on the Unit 3 side of the control room was created when the tile in the corridor leading to the control room was replaced with now, thicker tile. Work request H001593MES has been written to correct this problem by removing the tile and grinding down a high spot on .
the concreto bcncath the tilo. The door at the entrance to the IAE offico arca is a non-committed fire door (i.e., this door is in a non-vital arca, but designated as a fire door to prevent property damage). The Safety section at Catawba has roccived permission from the insurance carrier for Catawba to allow the doors in this' area to remain open when personnel are in the area.
- 2. Correctivo Actions to be Taken to Provent Further l' Incidents.
A. All members of Radiation Protection arc in a position-to be involved in incidents which cause a Security or Fire Door to f ail to perform an intended function. In addition, all members of Radiation Protection are in a position due to proximity to many of these doors, to identify problems which have previously gone undetected. A package identifying this weakness and requesting Radiation Protection personnel be sensitive to this problem during their work activitics has been prepared and distributed to Radiation Protection Supervision for presentation to all employees. Presentations will be completed by September 30, 1989. l i
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4 ' I B.- JA preventativoimaintenance; program is-being: established to inspect'and maintain all doors in ; the auxiliary building on a periodic basis; the.
. doors 11eading.to-the diesel generator rooms will - be inspected and necessary maintenanco performed -;
quarterly. This should climinate' mechanical problems associated with these doors. This program will be in place by November 1, 1989. . C. To provent creating situations that cause doors to- i drag, all NPD maintenance personnel and Construction and Maintenanco Department personnel associated with installation of flooring materials
' wil1~be cautioned to assure that door operation is not impaired. This action'will be complete by November 1, 1989. ,
F D. -All non-committed fire doors are being marked with permanent signs. Any doors which are not required to be maintained in a closed position will also-be marked with permanent signs to indicato'this condition and avoid ,ny confusion. This action will be completed by March 1, 1990. 3.. Date of Full Compliance A. The Maintenance Section will be in full compliance by March 1, 1990. l B. Tho~ Radiation Protection Section will be in full compliance by September 30, 1989. I w ,. y--eeer
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f DUKE PGER COMPANY L REPLY 10 A WEAKNESS (IFI) , 50-413,414/89-094)7 c In the Independent Verification and Safety Tag procedures, three items of potential improvement are identified. (paragraph 2.1)
RESPONSE
- 1. JCorrective Action Taken and Results Achieved A. Based on operr. tor. knowledge of the independent verification process and its intent combined with our past record of minimal errors, we believe-the efficiency of operation out weights the effectiveness of the recomended practice. No cortective action will be taken.
l: - B. Verification of vaNa position by remote indication satisfies the requirements , cof independent verification and also accomplishes the job with respect L to dose-ALARA. Operators are trained-to be alert to signs of material L. ' degradation'of components whenever they are observed. Based on current l' operating practices we do not believe that the remote verification of " valve' position constitutes a deficiency. No corrective action will be taken.> r L C. Plant procedures will be revised to direct the operator to include on l the Removal and Restoration tagout sheet (R&R),'in addition to the isolation
. boundary valves,~the valve on which maintenance is actually-being performed.
'All other valves inside the boundary remain in the position required by their operating procedure. Change from this required position muct be
.docunented on the R&R sheet.
- 2. Corrective Action to be Taken to Avoid Further Incidents, A. Corrective action stated in item 1 shall resolve the recognized deficiency with no further action required.
- 3. Date of Full Compliance Duke Power will be in full compliance by December 1, 1989.
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p;', a f ., & [y ' DUKE POWER COMPANY k-REPLY TO A WEAKNESS.(IFI) i 413,414/89-09-08 Several deficiencies were noted'during observation of a
-performance test on one of.the Containment Spray pumps !
(paragraph-2.m.).
- 1. No.Section 2.0 reference for the KF system.
2.-Momentary lack of adequate miniflo during throttling process. *
- 3. Significant digit mismatch between acceptance criteria and available data. .
i 4.' Poor communication between remote location of throttle valve and meter that reads flow.
- 5. Instrument 1NSTH5010 broken with an incorrect laminate tag. Also, NS Pump-1B motor covers were either' loose or missing.
RESPONSE
- 1. Corrective Actions Taken and Results Achieved.
.A. Item 1 will'be resolved by climinating all valve t lineup references to'KF valves on the subject procedurc~and the other threc NS pump procedures.
KF101B'and KF103A valves on both units are not required to perform an IWP test on these pumps. B. Item 2 will be resolved by noting throttle valvo-positions for each NS pump after flow has been setup. This information will be used to accurately determine the " Required Initial Test Position" in both the periodic test procedure lineups as.well as the Operations' ops. C. Even though the accuracy specified in the procedure (i.e. to a tenth of a gpm) exceeds that available from the instrument, the acceptance criteria for the test can still be met by reading a value of 615 - 625 gpm which is within the instruments capability. l The instrument in question meets the IWP requirement for accuracy. For this reason we feel a change to L the procedure is not required at this time. D. Item 4 has been evaluated by Performance and determined not to be a significant weakness provided 1 I Item 2 is resolved. l l l l
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iL - Item Sa is being'followed up and will bc:rcsolved p' with'a work' request'if problem is~still outstanding. , 1
' Item 5b has been resolved by initiating a'chango to the NS pump'procedurcs. Motor cover removal and replacements will now bo performed per those procedures.
- 2. Corrective-Actions to be Taken to Avoid Further I Incidents. ,
A._ Normal periodic procedure upgrades should correct similar weaknesses to Item 1 in otaer procedurcs if they exist'. B. A review of other IWP procedurcs revealed no problems similar to Item 2. C.. Not applicable. D. Not applicabic with the resolution of Item 2. E. Item 5a is not considered a generic problem. No r
- 'further action deemed necessary. Item 5b
- Motor cover removal and replacement on certain IWP tested pumps aro_now performed por their respectivo
' procedures.
- 3. Date of Full Compliance.
Duke Power will bc in full compliance where deemed necessary on January 1,.1990.' Item-2 cannot be resolved-until all the NS pumps' arc retested. These pumps-are tested quarterly.
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W .. V e fd , L DUKE POWER COMPANY REPLY TO A WEAKNESS (IFI) g - 413,414/80-09-09 t' ., Scaffolding procedures do not address seismic considerations and resultant inoperability;of safety equipment. (paragraph 2.r.)
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i RESPONSE: , 1.- Corrective Actions Taken and Results Achieved. , A. A' review of existing scaffolds was performed-by Design Engineering personnel.. No areas of concern relative to installed scaffolds were r identified. U B.- .The scaffold crew personnel assisted in the review addressed in A above. Through this review, the crew members have become aware.of concerns based on seismic considerations. 1
' 2 .~ Corrective Actions to be Taken to Avoid Further Incidents.
A. A guideline is being developed to address the administrative controls ' and technical details concerning the erection of scaffolds. This , j' guideline is being developed by a team of representatives from various L Duke Power departments. I B. - A site specific procedure will be generated to include information from the above guideline and to address seismic considerations in the , erection of' scaffolds.
- L 3. Date of Full Compliance.
The date of full compliance will be July 1, 1990. v v v + W
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? Duke Power Company F Reply to a Weakness (IFI)
' > 413, 414/89-09-10 h
- i. " .-IAE Maintenance does not use portable equipment to facilitate timely locating of DC ground faults. -(paragraph 2.5) !
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RESPONSE
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- 1. Corrective Action Taken and Results Achieved A. A review of the practices for locating DC ground faults was undertaken. -The supervisor _ felt that he was unable to use the portable ground locating equipment because of its sensitivity.
This equipment is so sensitive that it picks up noise from surrounding AC circuits, to the point that you can't distinguish the tone received when a ground is present because the noise =from surrounding AC circuits is too loud. We have contacted McGuire personnel about the equipment they use that is similar to ours. They have experienced the same problems even after special filters were installed on their tester at
- the factory. This test equipment is a model 201002 DC ground fault detector made by Electrom Co.
B. We are actively trying to check for DC ground faults by using other types of test devices that would allow us to test with the circuits energized. . 2.. -Corrective Actions to be Taken to Avoid Further Incidents A. We have obtained an additional piece of test equipment that
- i. will enable us to test for and locate DC ground faults more efficiently. We feel that we can better locate DC ground
.7 faults than with the model 201002 tester.
Our approach will be to ask Operations personnel to ^ B. de-energize any circuits on the bus that will have no impact on the safe operation of the plant. If the ground still is present, we will then test the active circuits with our tester until the ground is located. C. A thorough review of all avenues will be conducted to ensure the most efficient way to locate DC ground faults is used.
- 3. Date of Full Compliance This information will be covered with all IAE Supervisors and General Supervisors at Catawba Nuclear Station by October 30, 1989.
pl , DUKE POWER COMPANY , REPLY 10AWEAKNESS(IFI) 50-413,414/89-09-11 TherearemanysignificantdeviationsbetweentheEDPsand.thePSIG(PlantSpecific Technical Guidelines) where there should be none. This is primaril being made in the EDPs before being made in the guidance document PSIG). (y due to chang y 3andAppendixB)
RESPONSE
1 '. Corrective Action Taken and Results Achieved.
.A plan has been agreed upon between the Safety Analysis section and the station Document Development section to review all the coments in Appendix B listed as PSIG Deviations. The result of this review will be a change to either
. doctanent so that the difference in guidance is eliminated. Technical Verification of_the E0Ps, a required step in the Verification and Validation program, will serve as the process by which this plan will be implemented. The Safety Analysis
'section performs the Technical Verification process. All of the identified deficiencies will be corrected through this review process by 12-31-90.
- 2. Corrective Action to be Taken to Avoid Further Incidents.
The Technical Verification process is designed to provide a means by which changes made to the EDPs are verified to be technically correct. Verification of technical correctness may lead to a modification of the PSIG, with appropriate justification, or a rejection of the E0P change as written. This process provides a functional means to ensure the E0Ps accurately and consistantly reflect the guidance in PSIG. Sufficient resources and timely efforts will
'be committed to this process to avoid future inconsistencies between E0Ps ,
and PSTU.
- 3. Date of Fbil Compliance.
Duke Power will be in full compliance by December 31, 1990. ; L L 1 l
pm 1 4.! 7_.: , 9 DUKE NWR WMPANY -i n REPLY 10AWEAKNESS(IFI) c 50-413,414/89-09-12 Many technical and human factor discrepancies were identified in the EDPs. . Eachoneislisted(paragraph 3.b.andAppendixB). RE51MSE:
- 1. Corrective' Action Taken and Results Achieved A.. A formal process for the inclusion or dismissal of the items listed in Appendix B into the E0Ps has been planned, but not implemented.
Consideration will be given to each item based on the benefit realized to make the procedure more user friendly or technically correct. To ensure those items deemed beneficial are incorporated into the procedure properly and consistantly, the actual rewrite of the E0Ps will follow the publishing of the revised EP/AP Writer's Guide. l- B. A0Ps are currently under revision to upgrade them to the current standard for E0Ps. The AOP revision took priority over the E0Ps based on the recuest of licensed operators and the inspection team's recomencation. Complete revision of the A0Ps to address l the items identified by the inspection team will be accomplished I after the publishing of the revised EP/AP Writer's Guide. l: C. Discrepancies between PSIG and E0Ps will be resolved in the process ! of Technical Verification of E0Ps during the revision to address inspection team concerns.
- 2. Corrective Action to be Taken to Avoid Fbrther Incidents.
A. -Revising of the EP/AP Writer's Guide will establish a new standard
'for future EDP/AOP development. The methods for maintaining the L standard and are already)
Validation established (V&V processes and well as descrfoed docmentedManagement in Operations by the Verification Procedures. B. AOPs, which were not formally subjected to the V&V process in previous revisions, will be scrutinized under V&V criteria in subsequent revisions.
- 3. 'Date of Full Compliance.
Duke Power will be in full compliance on December 31, 1990.
we o , y; E i DUKE F0WER COMPANY l REPLY 'IU A WEAKNESS (IFI) 50-413,414/89-09-13 Many. labeling discrepancies between E0Ps and panel indication were identified. Each one is listed. (paragraph 3.c and Appendix D)_ RESPGtSE: g 1. Corrective Action Taken and Results Achieved. A. Consideration of the-labeling discrepancies noted in Appendix D will be_ accomplished during the revision of the EP/AP Writer's Guide. Control board / panel labeling is not necessarily the nomenclature by which the operator identifies his indication / controls. Based on training and day to day operation, a functional nomenclature has evolved. Guidance provided to the procedure writer in the
-EP/AP Writer's Guide must allow enough flexibility so that nomenclature familiar to the operator can be used.
B. Consideration of the labeling discrepancies will also include proposals'to change control board / panel labeling so as to more functionally describe the indication / control items.
- 2. Corrective Action to be Taken to Avoid Further Incidents.
i A. Revising the EP/AP Writer's Guide to establish a standard for referring to indications /and controls and maintaining the standard by the Verification and Validation processes will provide a method of quality control for the E0Ps and A0Ps. l- B. Control board / panel nomenclature is a controlled item. To change chis nomenclature requires approval of management at various levels
! based on plant configuration control. 'Ihis process is considered l adequate and will not require modification to make changes, deemed necessary, based on this inspection.
I'
- 3. Date of Full Compliance.
I l Duke Power will be in full compliance with our commitment to consider I the labeling concerns listed in Appendix D by June 1, 1990. Based on the EP/AP Writer's Guide, those concerns involving only a procedure revision will be completed by Dec 31, 1990. For those items of concern L requiring Control Board / panel labeling modification, the full compliance l- date will coincide with the end of the respective unit refueling outage in 1991; 1EOC5 and 2EOC4.
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l [i DUKE IOER 00MPAW REPLY 10 A WEAKNESS 50-413,414/89-0)-14 ancy between the E0Ps and the S/G pressure meter in ! There is a room the control discrep(paragraph 3.c and Appendix B item 1.g.) RESIMSE:
- 1. Corrective Actions Taken and Results Achieved.
The marking of the S/G steam pressure gauges has been addressed by originatic<a of work requests 432120PS and 511720PS (Unit 2 and Unit 1respectively). The ranges, which depict abnormal conditions for normal at power operation, have been specified. The corrective action will redesignate the lower red range on each S/G pressure meter starting at 725 psig (Iow S/G Steam Pressure SI setpoint) and ending at 0 PSIG on the scale. This work requires removal of the meter from the control board and thus has not been completed with the units at operating temperature and pressure.
- 2. Corrective Actions to be Taken to Avoid Further incidents.
The red range marking of control pnel meters is a functional process and considered an operator aid, wien performed correctly. Individual responsibility for this process has been reassigned to better utilize our personnel resources and assure the process functions as intended.
- 3. Date of Full Compliance.
- Duke Power will be in full compliance by the end of the next scheduled refueling outage 1EOC-4, 2EDC3 (Unit 1, Unit 2 respectively) 1990.
c:w . , 'f . l /c; F ; L. j 1 L DUKE POWER 00NPANY REPLY 10 A WEAKNESS (IFI)' 50-413,414/89-09-15 Many writer's guide discrepancies were identified in the EDPs. Each one is. listed (paragraph 3.c. and Appendix C). , RESPGtSE:
- 1. Corrective Action Taken and Results Achieved.
A.- A decision has been made to revise the EP/AP Writer's Guide. Based'on the comments of the inspection team, it is evident that more detailed guidance should be provided te the E0P and AOP writer. B. Many of the discrepancies noted in Appendices B, C and D can only be addressed after decisive guidance is established in the EP/AP
-Writer's Guide. Thus revisions to the E0Ps and A0Ps will be made based on the revised EP/AP Writer's Guide and comments deemed appropriate from reports 50-413,414/89-09.
- 2. Corrective Actions to be Taken to Avoid Fbrther Incidents.
A. IbecurrentprocessesofVerificationandValidation(V&V) provide an efficient and adequate means of assuring BOPS conform to written guidance. No corrective action is necessary. B. AOPs will be subjected to the V&V processes to assure conformity with written guidance and compatibility with operational experience.
.3. Date of Full Compliance.
Duke Power will be in full compliance with regard to the EP/AP Writer's Guide by June 1, 1989 and, with regard to the revised E0Ps and A0Ps, by Dccember 31, 1990.
99: 7 sq yf ., pl.[ f E pp e . DUKE POWER COMPANY I REPLY 'IO A WEAKNESS (IFI) _ 50-413,414/89-09-16 '
' Noise level in the control room'during auto-start of both ventilation trains during S/I' response is excessive (paragraph 3c).
RESPONSE
- 1. Corrective Action Taken and Results Achieved.
'A design ~ study has been initiated to review the problem with excessive noise in the Control Room due to'the operation of the ventilation system.- A test-will be performed to determine noise levels'for various configurations'of_
the ventilation system. Based on the test results a resolution of the problem will'be proposed to management for corrective action.
-2. Corrective Action'to be Taken to Avoid Further Incidents.
-Corrective action taken, based on' proposals by the design study stated in item 1', should resolve the recognized deficiency with no further action required.
- 3. Date of Full Compliance. .!
-Dateoffullcompliance'isdcpendantonthecomplexity;oftheproposedcorrective
. action. Duke Power will have a proposal for corrective action by December
'31, 1989.
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i fk DUKE POWER 00NPANY: L REPLY 'IO A WEAKNESS (IFI) 50-413,414/89 09-17 _ Deficiencies were identified in simulator effectiveness in training on I.DPs (paragraph 3.d). . s RESPONSE: ,
- 1. Corrective Action Taken and Results Achieved.
A. . % e concurrent use of A0Ps is.-justifiable based on the quantity and control of-resources available during a multi-failure scenario. By conscientious decision the Shift Supervisor may-use more than one AOP at a time. Bis is. allowed-since the AOPs are written to provide various options to sta'ullize the plant after a particular malfunction. We do not consider this a deficiency. i B.- he E0P/A0P' filing methods will be reviewed to determine whether an identification-and retrieval problem exists for Control Room personnel. We deficiency noted:was based on the observation of a staff person'c performance. Appropriate corrective action will be taken, if required. ! C. Entry conditions.for EDP/A0Ps will be reviewed in conjunction with the ! review of procedures for other deficiencies noted in this report. Le j E0P/AOPs will be revised as. deemed necessary.
- 2. Corrective Actions to be Taken to Avoid Ebether Incidents. j i
A. Discrepancies discusr.ed in Item 1, with exception of 1.c., are not expected i to recur . B us surveillance programs, to monitor for the repetition t of the; discrepancy, are not required. B. ~ h e EP/AP Writer's Guide and the Verification and Validation processes i will ensure that future revisions to E0P/A0P entry conditions are written to'an established standard. 3.- Date of Full Compliance: ! Duke Power will be in full compliance for the following corrective actions as listed: ;
. E0P/AOP filing method review -
January 2, 1990
. BOP /AOP entry condition review - December 31, 1990
$? ,s 3)fd? ( 3 f Jel l i,n DUKE POWER COMPANY REPLY TO A WEAKNESS (IFI) 413,414/09-09-18 Weakness noted in the site's ETQS (Employee. Training and Qualification System, paragraph 4.a.).
RESPONSE
a .
- 1. ' Corrective Actions'Taken and Results Achieved. i
- v. . , l
~The new Mechanical Maintenance ETQS program is still being developed.-
u - -i - , A. We are working with McGuire, Oconee and the training organization to
' finalize all aspects of the new program. The task rewrite is
~
1 approximately.95% complete. The continuing training plan is being ,
-developed by Production Training Services (PTS), with input from the i stations and' changeover qualification from old tasks to new tasks-should be. started by November'1, 1989. We will not begin our communication to all personnel until the program is finalized. .)
- 2. Corrective Actions to be Taken to Avoid Further Incidents. 1 I
A. 'The new program is scheduled to be implemented by January 1, 1990. g- B... We will communicate, through crew meetings, the requirements of the ! new program to all Mechanical Maintenance Personnel.
"3. Date of Full Compliance.
The: communication to personnel will be completed by March 1, 1990. I 1 I 1 l
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- m. .
9i pl,% er . y 1 L ' rr 1 DUKE POWER COMPANY' -3
-REPLY TO A WEAKNESS (IFI) -l
^
i- 413, 414/89-09 x There-are approximately 131 temporary modifications in effect on site. -Some date back as far as 3 or 4 years.- l i RESPONSE: ! l 1.1 ' Corrective Actions Taken and Results Achieved. L
.In 1986 Catawba Nuclear Station had approximately 320 TSM's
- i. 4 t installed. LAt that time a working group was formed to f identify who was responsible for each TSM and what it would L require to clear them. Most of the older TSM's'which are-installed have' required modifications to be originated to- -
E -clear.them. The Station Directive (4.4.5) has'been-revised' several1 times:since 1986 and it is now clear that the Temporary Modification program shall=not be used to bypass the normal modification process for changes that are ,1 intended to remain permanent. , l.
- 2. -Corrective Actions to be Taken to Avoid Further Incidents All TSM's-have been reviewed to determine an estimated clearing date and.what station group is responsible for i clearing the TSM.- Approximately fifty percent of the .'
-installed TSM's have been identified to clear during the upcoming Unit 1 and Unit 2 outages in 1990.- The remaining TSM's are not tied to an outage, but do have a current estimated clearing date. ,
'3. Date of Full Compliance
, Catawba Nuclear Station is in full compliance with this
- issue at this time. Catawba h'as significantly reduced the number of TSM's and has an estimated clearing date assigned to all installed TSM's.
According to the Catawba Nuclear Station Performance Indicators, the station's goal is to maintain the number of TSM's to no more than 60. This is a new indicator which is just beginning to be looked at. Catawba expects to achieve this goal by October 1, 1990.
. . . . . - . -- - - . -~ . . - . . ..
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DUKE POWER COMPANY. 1 REPLY 'EO A WEAKNESS (IFI) :; s . 413;;414/89-09 : s a '
;I
.; The' separate' reporting authority : arid duplication of support u
^ ^ functions: for the Transmission- Group is considered a i weakness.
JRESPONSE: Upon l review of the report several-areas are in need of further explanation. , The report Estates that Transmission has its. own procedures, training. program,. l u and equipment calibration. program which is true. These. procedures and programs - ' q L were Lall; developed specifically to support Transmission and Distribution personnel 1 m in performing : their assigned L work activities .at the nuclear stations. Also,, y' i these programs andiprocedures, must meet the same. requirements as those of other
. departments. and in manyx: cases fall under Nuclear Production Department . (NPD)
' policies: and procedures., For J example, procedures used by Transmission.and-1 Distribution -~ (T&D) personnel at the station are originated by ' T&D engineering. >
personnel; however,' the procedures are the same'as any other station procedure-
' and 'must. follow the same station approval process. The only major difference is the originating group, b . Training programs for T&D personnel are developed in cooperation with the l Production: Support Department which also coordinates with other - departments in a- - similiar - fashion. . These ' programs are tailored specifically for T&D personnel, and the- type of work performed by the department .at the station. ,'
They. may; or may not' be the same as other departments programs- depending on the p < l needs' identified. e J '
'The equipment calibration program allows T&D personnel to have their equipment calibrated .at a central location thereby not having to make ~special trips to
!thes stations. to constantly drop off and pick up equipment. - This equipment is used by~T&D-personne1'at other company locations, and the central location offers
- l. convenience and efficient service. .
s
, The report also focuses on limited resources available to support T&D c . activities, The amount of resources assigned to any task should be commensurate
- a
- .with the identified need. This approach has been used in each area pertaining
.to nuclear related activities. Resources for required work are made available onL an' as 'needed basis without comparison to resources supplied by other
. departments and are considered a normal overhead expense associated with nuclear maintenance work.
In. summary, the weakness noted by the report is not perceived as a true weaknes.s. First, the fact that separate reporting authority exists does not necessarily indicate that changes to station programs will not be implemented in kind in the T&D Department, f 5
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n ; I l Effective communication, administrative controls, and audit. practices help ensure
. this ' continuity. Second, the' duplication of service in -this case i s a more - .
efficient and productive way of providing support for T&D personnel performing , work - ati the stations. Procedures - are written by engineeering personnel who 1 have the necessary: experience with .the equipment and the maintenance activities -!
. to - be performed. - Training programs are- tailored to specific T&D needs which may be.different.from those of station personnel.- Finally, equipment calibrations are performed at a central-location- to accommodate T&O personnel that must work at other Duke locations. ! I \
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