ML20043F610

Forwards Supplemental Response to NRC 900330 Ltr Re Deviations Noted in Insp Repts 50-413/90-06 & 50-414/90-06. Corrective actions:2KCD05 Returned to Closed Position & Locked

ML20043F610
Person / Time
Site:	Catawba
Issue date:	06/05/1990
From:	Tucker H TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006150147
Download: ML20043F610 (4)

Text

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il I Duhr hwer Company litt B hur Pil Bat 33198 - \* ice President 8 l

Charlotte, N C 2820 ' Nuclear Production (704)3734531 DUKEPOWER w

t June 5, 1990 l

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O. S. Nuclear Regulatory Commission ATTN: Document Control Desk e Washing on, D. C. N 55

Subject:

Catawba Huclear Station Alt, 1 and 2 a Docket Nos. 50-413 and 'e0 4 !$

NRC Inspection Report Not. 'a0-413 and 50-414/90-06

, Supplemental Reply to a Notice of Deviation

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Gentlemen:

Enclosed-is the supplemental response to the Notice of Deviation issued March  !

30, :.1990 by Alan R. Herdt concerning failure to complete procedure change corrective action by the commitment date.

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Very +.ruly yours, Ad k K- ?c _

Hal B. Tucker WRC148/lcs ,

- Attachment 5

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DUKE POWER COMPANY REPLY TO A NOTICE OF DEVIATION 50-414/90-06-01 x

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 l closed." Catawba Chemistry procedure PT/2/A/4208/08, Post Accident Liquid )

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 headeri When the periodic test is being performed, this periodic i test is logged into the Control Room log book and 2KC005 is unlocked and When this periodic test is completed, the valve must be closed and opened. '

locked prior to logging the periodic test out of the Control Room logbook.

Contrary to the above on June 15,1989, the 2KCD05 was found by the Resident NRC Inspector to be open and unlocked, it was later determined that 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 j that this violation would not occur again. This periodic test was not  ;

approved until February 22, 1990. '

RESPONSE

1. Reasons for Deviation

a. A tracking system was initiated in September 1989. This item was a backlogged commitment, and was not properly included in this tracking system This particular commitment was not properly tracked until March 1, 1990.

2. 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 k flow path which greatly eliminates any possibility of a compromise to the KC system.

c. All other KC valves that are operated within the three procedures 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),

e. PT/2/A/4208/08 was corrected and approved. Also all other possible problems were corrected and resolved. The other problems were valves and procedure steps that were duplicated between the three procedures,

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f. Interfacing procedures PT/1/A/4208/08 and OP/0/A/6200/21 were also corrected and approved.-

g, Group training was completed on the importance of locking and ,

closing the 'KC valves upon completion of either PALSS periodic test.

h. A~ formal Commitment Tracking System was initiated in September 1989 and is now used to eliminate the possibility of deviations of new commitments from September 1989. Ongoing and back1cgged commitments-prior to September 1989 were investigated and . verified to be incorporated into this tracking system on March-1,1990.

3. Cctrective Actions to be Taken to avoid further Deviations The actions taken in Section 2 above will ensure avoidance of further deviations.

~4. Date of Full Compliance Duke Power Company is now in full compliance.

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