ML20012B869

Comments on SALP Repts 50-413/89-32 & 50-414/89-32 Covering Areas of Radiological Controls,Maint/Surveillance,Security/ Safeguards & Engineering/Technical Support.Disputes Conclusion That Trend in Safeguards Area Declining

ML20012B869
Person / Time
Site:	Catawba
Issue date:	03/02/1990
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003190070
Download: ML20012B869 (8)

Text

.

(

a

-:\,A I .

• e Duke 1%urr CLvnpany i Hit B Mn j

?.0 Bar 33198 ,, ., Vice President y Charlotte, N C 28242 Nuc!rur hvduction (704)3 73-4511 I

4 DUKEPOWER March 2,-1990 l

[.

U. S. Nuclear Regulatory Commission i

.. Attention:- Document Control Desk k Washington, D. C. 20555-  ;

Subject:

Catawba' Nuclear. Station Docket Nos.: 50-413 and 50-414 c ,

SALP Report.50-413/89-32 and 50-414/89-32 Gentlemen:

I' -

By letter dated January 23, 1990 the NRC transmitted the Systematic Assessment of Licensee Performance (SALP) report for the Catawba Nuclear

• Station.. A meeting was held on January 31, 1990 at the Catawba Station to

discuss the report.

Generally, I agree with the SALP board's assessment of plant and personnel performance during this period. I do have some comments pertaining to

~

specific areas of the report which will provide additional information that may not have been available to the SALP board. These comments are provided below and are Rrouped by functional area.

R,adiological Controls The second. paragraph on page 12 of the SALP report states: "There have been problems with radiation monitors." The remainder of the paragraph discusses

the problems _ that have been' identified with the Steam Generator blowdown radiation monitors and describes the corrective actions planned to resolve the problem. There has been a dedicated effort during this SALP period to improve the availability and operability of the radiation monitors that should be mentioned in the SALP report.

i The station established a working group in June 1988 comprised of s

individuals _from Design Engineering, Radiation Protection, Operations, and Maintenance.. The' purpose of this working group,was to identify problems associated with the radiation monitors (EMPs) and develop solutions for resolving the problems. The results of this effort are graphically depicted in Attachment I. The increase in availability has two components. First, e the radiation monitors are failing less frequently. Secondly, the increased management attention on failures that do_ occur result in a reduction in the repair time and a more rapid return to service of the equipment.

4 h

? \\

_a

b L

U. S. Nucl= r R:gulctory Commicalon March 2, 1990 -

Page Two The Steam Generator. Blowdown monitors have been inoperabic for several i months as stated in the report, llovever, ef forts to resolve this problem have been ongoing and are receiving top priority. The radiation monitor  !

l working group developed several alternative solutions for correcting the

. problems associated with these specific monitors. The station is currently performing tests to assess the feasibility of the desired modification and is striving to have the Unit 2 radiation monitors operable by mid-1990.

Maintenance / Surveillance On page 14 of the SALP report, the following statement is made:

The licensee's performance in the area of testing systems and components following maintenance activities clearly declined.

I admit that there have been two errors in judgement during this fifteen month SALP period with regards to the adequacy of post maintenance testing.

One of the events pertained to testing a Containment flydrogen Skimmer Fan circuit breaker and the other was associated with the Auxiliary Feedwater Pump Turbine as stated in the SALP report. Although it was ultimately determined that post maintenance testing had proven to.be inadequate in these two incidences, there are several points that must be considered when evaluating overall station performance.

The testing of the circuit breaker was performed in accordance with accepted industry standards and practices at the time. In retrospect, a different test program may have been helpful, however, it cannot be ignored that the vendor's unsubstantiated breaker curve, deficient quality control during the assembly process, and inadequate qualifications testing for the type of <

breaker in question contributed to the event. With regards to the Auxiliary Feedwater Pump Turbine, there is no question that the post maintenance testing was inadequate, llowever, the initial decisions that were made

concerning the root cause of the pump test failures were reasonable based upon the information available at that time. When it was discovered that urroneous conclusions had been reached, the follow-up work was handled in a thorough and timely manner. Additionally, subsequent corrective actions were unusually broad and ultimately led to the full understanding and resolution of the problem.  ;

There have been a number of cases where the Catawba staff has performed very broad and in-depth reviews of events related to post maintenance testing.

Post maintenance testing and root cause determinations at Catawba have identified several generic industry issues and have resulted in Part 21 reports being generated. Some of these events are listed below: ,

1. Catawba's experience with the flydrogen Skimmer Fan circuit breaker ultimately resulted in a Part 21 being issued by Westinghouse and l

l

,. <(

d U. S. Nuc1ccr R;gulctcry Commiccion L March 2, 1990 .- **

l Page Three an LER (413/89-26) by the station. The breaker was removed from the market and the issue has heightened industry awareness of vendor breaker qualification testing.

2. When the actual root cause of the Auxiliary feedwater Pump Turbine overspeed trips was diagnosed, extensive follow-up investigations thoroughly explored the valve stem corrosion phenomena. A Part 21 report and LER (414/89-17) were submitted by the station.

3. Duke and Catawba staff conducted independent D/P testing of BORG Warner Valves to establish valve factors based upon an NRC identified concern. Duke's testing revealed non-conservative valve factors on behalf of the valve manufacturer. ,

Some examples of the in-depth post maintenance testing conducted during the ,

SALP period includes  ;

1. Extensive Steam Generator PORV post maintenance testing. This ,

testing actually challenRed the power operated relief valves under  ;

full main steam pressure to ensure the valves would function under design basis conditions. The testing spanned a three month interval from June to August 1989.

2. Excellent maintenance and post maintenance testing have resulted in a significant increase in the availability and operability of the radiation monitors over the last SALP period. See the comments >

under the Radiological Controls functional area for additional information on this effort.

3~. Comprehensive post maintenance testing of Condenser Steam Dump Valves was performed to assure proper operation after poor i performance was identified during plant cooldowns.  !

t The problems associated with the equipment and events listed above have been ,

resolved primarily due to the efforts of the Maintenance Engineering i Services (MES) group that was established during the first half of the SALP period. The SALP report acknowledges that the MES group was " matured to become a vital component in the' licensee's program for solving persistent '

problems and maintaining plant reliability." Post maintenance testing is recognized by the station as being a very important aspect of ensuring plant reliability. I believe that the current organizational structure of the MES group as well as the mindset of the MES individuals to keep pursuing a problem until-it is fully understood and resolved, has established an ,

improvinn trend of performance with regards to post maintenance testing -

activities at the end of this SALP period.

/ 1 l:

l

U. S. Nuclear Regulatory Commission i- March 2, 1990 -

Page Four Security and Safeguards The discussion in the SALP report for this particular functional area does not support the performance rating of "2 Declining." I admit that with one ,

exception, the problems detailed in the report occurred. However, little or no credit appears to have been given for the extensive self-assessment and corrective actions that resulted when the station identified the events.

! TLa second paragraph on page 17 discusses problems associated with the station's access control program. There have been several instances of incorrectly issued security badges as stated in the SALP report. However, as the station continues to identify these events and take corrective +

action, the number of events continues to decline. Attachment II is a graph depicting the number of security events over the last two years associated r with incorrectly issued badges and access without a badge. A definite ,

downward trend is evident. Additionally, the SALP report states that a-deceased individual remained on the validated access list at Catawba for four months. This is an extremely negative statement, the basis for which I do not understand. A review of station records indicates that this event did not occur at Catawba.

The third paragraph on page 17 of the report discusses the enforcement conference held in August 1989. The paragraph ends by stating that the

" licensee described actions undertaken or planned to correct identified problems." Throughout the SALP period, the station has identified Security and Safeguards problems as they have occurred and taken effective corrective actions to totally preclude or substantially reduce their recurrence.

Following the SALP meeting on January.31, 1990, a second meeting was held with the NRC to clarify what I perceived as incorrect conclusions en behalf of the NRC with regard to the number and severity of security related incidences at Duke Power. My letter dated January 31, 1990 which contains a

-response to the Notice of Violation 89-23, discusses in depth, the security events at Catawba and the corrective actions taken as a result of these events.

At the bottom of page 17, an NRC Regulatory Effectiveness Review of the

• station physical security program is discussed. Weaknesses were identified in the implemented programs, but once again, as stated on page 18:

" Corrections for the majority of these weakness (es) have been undertaken, completed, or scheduled."

Finally, under recommendations for this particular section, the report states that management is encouraged to " continue aggressive self-assessment activities in this area" which implies station activities in this area are l

recognized by the NRC.

t

U. S. Nue10 r R:gulctory Commic31on '

March 2, 1990 .* **

Page Five

{

I believe that the NRC is correct in their assumptions that the station is

[ performing aggressive self-assessments. Catawba management is committed to  :

ensuring that an effective security program is implemented at the station f and that compliance with all plan requirements is maintained. As I have t indicated, the level of performance in the security area has not declined, i The station has maintained a solid category 2 level of performance in the Security and Safeguards functional area. I request that the final SALP report properly reflect this fact. i Engineering / Technical Support

, I concur with your overall assessment that the engineering team has provided l exec 11ent and effective support on numerous issues. Design Engineering and r the station engineering staff will continue to place emphasis on overall improvement, and in this vein acknowledge the weaknesses identified in the [

!' areas of operability determinations and engineering design change  !

implementation. Enhancements made in the operability determination process j concerning technical specifications and their associated design bases coupled with ongoing discussions with the NRC Resident Inspectors and other  ;

i Region 11 personnel have corrected the root cause of the identified r weaknesses. ,

Safety Assessment / Quality Verification ,

k In regards to the General Office and Station Regulatory Compliance groups. I l

-believe the overall quality of their efforts has greatly improved since the r last SALP period. During this review period there have been no technical  ;

specification revisions rejected, and the quality of responses to NRC generic letters and bulletins has significantly improved. I_ feel this should be reflected in the report. Overall, the IcVel of performance in -

this functional area has improved. This is reficcted in the SALP report comments relative to the corporate and on-site QA group activities, the CSRG, and the Regulatory Compliance groups. I believe the final SALP report ,

.should assign a performance rating of "2 Improving" for this functional i area.

Summary

{

Although I believe that overall, the SALP report adequately represents the

. quality of performance at the Catawba Nuclear Station I do not concur that the trend in the Security and Safeguards functional area is declining. Nor do I believe that the SALP report is accurate with regards to the statement that station performance in the area of post maintenance testing is  ;

declining. Based upon the comments I have provided on the positive  ;

l accomplishments and management attention given to these areas, I request that the final SALP report be changed accordingly.

?

L l

h 8

i

-c -

. . - = . - -

m he < e e , J , ,

l- 8 t

a*- .. . .

U. S. Nuc1:Cr Regulttery Commiccion J

^

March 2 -1990- e -

6

Page Six ,

i: -

Duke Power will continue to factor in the observations of~the NRC into our  ;

overall efforts-to continually improve performance at our nuclear stations, j in Thank,you for the opportunity to comment _on this SALP report. '

'Very truly yours, j gg

' I Hal'B.. Tucker.

,l j 'RGM/02289001' .f Attachmenti r

-cet Mr.:S. D. Ebneter

. . Regional Administrator,; Region _11 LU. S;' Nuclear Regulatory-Commission

-101 Marietta St., NW, Suite 2900 Atlanta, Georgia- 30323 A r , .

4 Dr.-K.:Jabbour- -

Ua S. Nuclear Regulatory Commission 20ffice of Nuclear Reactor Regulation .

Washington, D. C.:20555  ;

Mr.iW. T. Orders- ,

NRC Resident Inspector Catawba Nuclear Station ,

f

< ^$

. ~

t N

r i

L h

r

~

-t.

RADIATION MONITORING SYSTEM (EMF)

OPERABILITY IMPROVEMENTS ,

100 ,

~

98- e I p -+- aus eransse q -

+ n.n. or.

D C so-p Note: EFF 31 PSDIFICATIEMS CWFLETE gn, _ REStLTING IN 100 % AVAILABILITY SINCE OCTOBER 1989. EFF 34 ISBIFICATIONS u 7g_ CURRENTLY 198ER DESIGN-STUBY WITH INtGENT STATUS Are TOP PRIGtITY.

1 I I I I E I' ,

1987 1988 1989 1990 1991' 2

=

il l>, . ,,llll,lItllll1lIl; l >ll i:

z31mLm d o WZH W 0 l 2 3 4 -

6 7 8

-1 kr o3Ou m tc

, 7

' mob

. $u o3Om m <a, '

m

" mom r' .

M i

s C 7

fV o3Ou m<> r, n ,. - ~A  ;

r.-

"mmm s i

~T -

s u S' W A e

. kV o3Ou mm; r, -, d EB .

- "Gom B C U A a lN t -

d l g TU -

kI o3Ou mmr a, e

s Y LC "mem EE .

O VA ER'

$" o3Ou mma r, F N a TS n,

S AT i

)

"Oe* l u

r e T I

fV c3Ou m ur, T

o O

_, "meo) n, i

N -

s

d. s m,

_ u e

. kV o3Ou mm,,e -

" mom

_ $r o3Ou m y a .

"mem -

s

,_ i m

[

_. 0 .

~.,.

~

, M 4 @cft 5," .

1  ;^

'