ML20034C482
| ML20034C482 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/26/1990 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005040001 | |
| Download: ML20034C482 (7) | |
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- - Duke 1%sxt Compacy Hu R Tww PO Bat 33198 ficePresideil
' Charlotte, NC 28242 Nudear Production (704)373 4531
~ DUKE _ POWER.
~ April 26, 1990 U. S. Nuclear Regulatory Commission ATTN Document Control Desk 1
-Washington, D.C.
20555
Subject:
Catawba Nuclear' Station,-' Units lland 2 Docket Nos.-50-413 and'50-414-NRC Inspection Report Nos.__50-413-and'50-414/90-06 Reply to a Notice of Violation and a Notice of Deviation Gentlemen:
Enclosed'is-the response to the Notice of. Violation'and Notice =of Deviation issued March 30, 1990 by Alan R. Herdt concerning inadequate procedures, failure to follow procedures and failure to complete procedure change corrective action by commitment date.
'Very truly yours, C
Mki fx Hal B. Tucker
.l WRC148/lcs i
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Attachment xc:
Mr. Stewart D. Ebneter
-Regional Administrator U. S. Nuclear Regulatory Commission Region II
-101 Marietta St., NW, Suite 2900
- i Atlanta, Georgia 30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station l
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1 3-DUKE POWER COMPANY j
REPLY 'IO A NOTICE OF VIOLATION 413/90-06-02 Technical Specification 6.8.1 rcquires that written procedures be established, implemented, and maintained covering.the activities referenced in Appendix'A of Regulatory Guide 1.33, Revision 2, February 1978.-
Implicit in this is the stipulation that the procedure be adequate for the task being performed.
l Station Directive 3.1.15, Activities Affecting Station l
Operations-or Operating Conditions,-requires that the Nuclear Control Operator be notified prior = to performing any.
i function which may affect the unit and prohibits personnel other than operators from operating any valve without.the permission of the Shift Supervisor with the exception of cases specified in the Directive.
Contrary to the above:
A)
On or about January 12,.1990, the refrigerant isolation valve on the Train A Control Room Ventilation (VC/YC) l Chiller condenser pressure sensing line was i
inappropriately throttled by a Maintenance Engineering Services representative without notifying the Nuclear l
Control Operator or obtaining authorization from the Shift Supervisor.
This resulted in the inoperability:
of the VC/YC Chiller.from January 21-24, 1990 due.to L
its inability to successfully start on demand as evidenced by a failure to start on January'24, 1990.
B)
PT/0/A/4971/06R, Routine Tost Procedure Brown Boveri Type ITE 27H Relay and PT/0/A/4971/10R, Routine Test Procedure Brown Boveri Type ITE 27D Relay, specified incorrect acceptance criteria for actuation.of the Engineered Safety Features loss of offsite power and degraded bus voltage relays.
This resulted in the failure to adjust as found actuation values which were loss conservative than the. Trip setpoint values of Technical Specification 3.3.2.
C)
On January 12, 1990, during the performance of troubleshooting maintenance on the A Train of the shared control Room Area Chilled Water System, l
Procedure IP/0/A/3190/01, YC. Control Room Area Chilled-Water System Safety Related Instrument Calibration, was found to be inadequate in that the procedure did not embody adequate detail to facilitate successful reinstallation of the valve actuator on Hot Gas Bypass Valve 1YC-362.
This resulted in the actuator being reinstalled with indicator opposite the actual valve position.
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RESPONSE
1-Admission or Denial of Violation Duke Power admits the violation.
2.
Reasons for Violation if Admitted Item A.
The violation occurred due to the inability of an employee in the Maintenance Engineering Services section;to adequately understand the requirements-of the maintenance work control system.and nuclear.
safety-related system,. structure or component operability.
This lack of understanding,by the employee resulted in.his adjusting the controller.
isolation valve without a work request and leaving the valve in an unanalyzed position causing the chiller to become inoperable.
Item B.
This incident was attributed to a Management Deficiency, due to a lack of procedure control'in the areas of procedure preparation and procedure review.
This incident is assigned a contributing cause of Design Deficiency, due toithe incomplete documentation of the-trip setpoint change for the Type ITE 27H relay.
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Item C.
This incident was attributed to inadequate procedure. The procedure did not specify a method z
to verify correct actuator installation after
-maintenance.
L 3.
Corrective Actions Taken to Avoid Further Violations L
Item A.
Work request 2311MES was initiated to open the controller isolation valve.- Controller response was tuned by I&E using approved instrument procedures.
As a result of the employee's actions in this incident and his-demonstrated' lack of, knowledge of-the requirements of the maintenance work control' system and nuclear safety-related system, structure or component operability,-this employee was reassigned to a position in the. Mechanical Maintenance section in which he will perform no work or operability evaluations on safety-related structures, systems, or components.
This is considered an isolated incident and is not a reflection on the understanding by the rest of the personnel in the: Maintenance Engineering Services section on the requirements of properly
a Page-3 maintaining safety-related systems, structures or components.
Item B.
Transmission personnel'promptly recalibrated Brown-Boveri, Type ITE-27D and Type ITE-27H relays to comply with Technical Specifications.
Transmissions personnel promptly recalibrated the NC Pump undervoltage relays for NC Pumps-2A, 2B-and 2D.
The following Transmission procedures were revised to comply with-Technical Specifications:
PT/0/A/4971/06R, PT/0/A/4971/10R, PT/0/A/4971/12/R, PT/0/A/4971/13/R,-and PT/0/A/4973/05/R.
Transmission personnel recalibrated the NC Pump undervoltage relays for NC Pumps lA, 1B and lD as part of the normal monthly surveillance.
All new or rewritten safety-related Transmission procedures are receiving a cross-disciplinary review, by Maintenance Department personnel, to.
ensure that Technical Specifications.are being complied with~.
L Training was provided to.the QA Audit team-to L
ensure that during future QA Audits, the Audit l
team will promptly-initiate a PIR when audit items are identified that potentially affect compliance with Technical Specification and/or'FSAR requirements.
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Item C.
Actuator for hot gas bypass valve lYC-362 was removed and correctly re-installed on-February 2, i
1990.
Procedure IP/0/B/3190/01 "YC Control Room Area-Chilled Water System Safety:Related Instrument Calibration" was. changed to specify method to verify correct actuator installation under change
- 22 on February 10, 1990.
The change addressed the valve actuator on both trains' chillers.
An internal memorandum initiated and routed to all IAE Supervisors for dissemination to crews, to increase awareness of the potential for this type-problem to occur.
t Page 4 4.
Corrective Actions to be Taken to Avoid Further Violations Item A.
Action taken in Section 3 (above).
Item B.
A change to Technical-Specifications will.be initiated by 2/23/91, to reflect the desired setpoints for the relays addressed in Table 3.3-4, Items 10.a and 10.b, and'in1 Table 2.2-1,LItem 14, and to reflect the desired ~ action'to be taken when a setpoint value is found to be between the Allowable Value and the Trip;SetpointrValue.
(Compliance / Design)
Item C.
Action taken11n Section 3 (above).
5.
Date of Full' Compliance Item A.
Date of full compliance occurred when1the subject was transferred to the Mechanical Maintenance section effective February 1,.1990.
1 Item B.
Duke Power will be in full compliance pending approval of'the Technical Specification + change.
Item C.
The internal memorandum will be complete by May 2, 1990.
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W DUKE POWER COMPANY' I
REPLY TO A NOTICE OP.-VIOLATION
- 414/90-06,
Final ~ Safety Analysis Report, volume 9 section - 9.2.2.2 page. 9.2-13 second paragraph from the bottom states " Any piping connecting the two trains 'of;
-component cooling equipment is provided with two isolation valves. Where this piping is seldom used, manual isolation valves are provided and are locked-Catawba Chemistryi procedure PT/2/A/4208/08, Post Accident Liquid -
closed. "
Sampling System Periodic Test contains the steps-to unlock /open.and~
lock /close 2KCD05.
2KCD05 is the manual isolation valve for component cooling (KC) train 2A return header.
When the periodic test is being performed this periodic test is logged into the Control Room log book and 2KCD05 is unlocked and opened. When this periodic test is completed the valve must be closed and locked prior to logging the periodic-test out of the Control Room logbook.
Contrary to the above on June 15,1 1989, the 2KCD05 was found by the; Resident ;
NRC Inspector to be open and unlocked.
It was later; determined that 1
PT/2/A/4208/08 lacked the procedural clarity needed to ensure this valve was locked closed upon completion of the periodic. test.
It.was agreed that this periodic test would be corrected and clarified by September 20, 1989 to ensure i
that this violation would not occur again.
This periodic test was not approved until February 22, 1990.
RESPONSE
l 1.
Admission or Denial of Violation l
Duke Power Company admits the violation.
i 2.
Reasons for Violation if Admitted a.
A tracking system was initiated in September 1989.
This item was not properly included in this tracking system.
-This particular-commitment was not properly tracked until early 1990.
3.
Corrective Actions Taken-and Resulted Achieved a.
2KCD05 was returned to the closed position and locked.
b.
2KCD03 (KC train 2A supply) was inspected and found to be locked and in the closed position.
This valve prevented the completion of any flow path which greatly eliminate any possibility of a compromise to the KC system.
All other KC valves that are operated within the three procedures c.
were inspected. No other discrepancies were discovered.
d.
An editorial Station Problem Report (SPR) was written and completed on a PALSS KC valve identified as FC 'which should have been LC (locked closed).
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PT/2/A/4208/08 was enrrected andhapproved.s-Also alllother.possiblei
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problems - were corrected.E and Lresolved.j The f other ' problems 1 were valves and-procedure steps that 'were; duplicated between the three' procedures.
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--Interfacing' procedures PT/1/A/4208/08 'and -OP/0/A/6200/21-were i also!
. corrected and approved, g.-
Group training ~ was completed J on. the linportance' of. lbcking U and --
j closing the KC valver upon completion of!either PALSS' periodic-test.
h.
A formal Commitment 1 Tracking System Lwas (initiated 'in ilate T1989 and -
is now:.used to reduce the likelihood of deviationsi of ~ this ~ nature 'in:-
-the future.-
4!
Corrective' Actions be Taken to av51d further Violations.
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The actions taken in SectionJ3 above -will ~ ensure avoidance ofIfurther-violations.
5.
Date of-Full Compliance-Duke Power Company is^now in full compliance.-
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