ML20058F590
| ML20058F590 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/29/1993 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312080189 | |
| Download: ML20058F590 (9) | |
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1 Duke hmn(heuny D. L Ron Catawla hiear Generation Depamnent 1>ce hesident GX)Cn 3rd Raad (M3)U13E'S Offste York.& 29N5 (M3)DI3C6 Fax DUKEPOWER
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November 29, *993 b
U.
S.
Nuclear Regulatory Commission I
ATTN:
Document Control Desk Washington, D.
C.
20555
Subject:
Catawba Nuclear Station Dockets Nos. 50-413 and 50-414 i
Reply to Notice of Violation l
Inspection Report Nos. 50-413/93-26 anc. 30-414/93-26 Attached is Duke Power's response to the two (2) Level IV violations cited in the Notice of Violation of Inspection i
Report 50-413/93-26 and 50-414/93-26.
j One of the violations involved two examples of failure to j
adequately implement the independent verification process, t
'which resulted in a reactor trip and a TS 3.0.3 entry.
The other involved two examples of failure to report a TS violat on.
f and ESF actuation as is required by 10 CFR 50.73.
Very truly yours,
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D. L.
Rehn l
\\ KEN: RESP 93.26 i
xc:
S.
D.
Ebneter Regional Administrator, Region II R.
E. Martin, ONRR R. J.
Freudenberger Senior Resident Inspector
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l DUKE POWER COMPANY
~j CATAWBA NUCLEAR STATION i
P". PLY TO NOTICE OF VIOLATION VIOLATION 413,414/93-26-01 i
Notice of Violation Technical Specification 6.8.1, Procedures and Programs, requires, t
in part, that written procedures be established, implemented and i
maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes l
licensee procedures controlling maintenance arid the plant j
independent verification process.
j Catawba Nuclear Site Directive 4.2.2, Independent Verification, and procedure IP/0/A/3890/01, Controlling Procedure for Troubleshooting and Corrective Maintenance, each require that, before an action is l
performed that involves independent verification, both individuals will verify that the component on which action is to be performed is the correct component.
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Contrary to _he above:
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[ Example 1]
i On September 25, 1993, Instrumentation and Electrical (IAE) technicians failed to adequately implement Catawba Nuclear Site Directive 4.2.2 and procedure IP/0/A/3890/01.
The technicians failed to properly independently verify that-sliding link A-5, associated with the Containment Floor and Equipment Sump Pump 2A start
- circuit, was located in electrical cabinet 2ATC14, and erroneously opened sliding link l
A-5 in cabinet 2ATC16.
This caused the closure of the "A"
Steam Generator Main Steam Isolation Valve, 2SM-7, resulting in a Unit 2 reactor trip.
[ Example 2]
On September 23, 1993, IAE technicians failed to adequately implement Catawba Nuclear Site Directive 4.2.2.
The technicians failed to properly independently verify a wire i
that was to be removed and inadvertently caused the "A" train Control Room Veniliation chiller to trip.
This resulted in inoperability of the "A"
train and entry into Technical Specification 3.0.3.
i This is a Severity Level IV Violation.
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t DUKE POWER COMPANY CATAWBA NUCLEAR STATION i
REPLY TO NOTICE OF VIOLATION VIOLATION 413,414/93-26 RESPONSE:
1.
Reason For Violation
[ Example 1]
i Several contributing factors led the IAE technicians to i
e misidentify link A-5 to be in cabinet 2ATC16.
t The technicians had begun. troubleshooting the WL sump pump circuits in cabinet 2ATC16 the previous i
day.
i TP9 majority of the components and circuits for these pumps were located in 2ATC16.
i These two factors tended to put the technicians in the mind set that all of their work would be in cabinet 2ATC16.
Beneath both links on the diagrams,
- 2 was listed i
as the legend reference for the links'- location.
On the diagram for pump 2A2,
- 2 referred to 2ATC16 in the legend.
On the diagram for pump 2A1,
- 2 referred to 2ATC14 in the legend.
This difference was not noticed by the technicians.
l When viewing the diagrams, the technicians laid one diagram on top of the other diagram.
This caused the technicians to view both diagrams as one.
This may have contributed to the technicians not i
noticing the difference in the two legends.
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[ Example 2]
The root cause of this event is attributed tc less than adequate work practices due to self-checking / independent verification not being adequately applied to ensure that the correct component was identified prior to removal from service.
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Prior to the conductor removal, two IAE Specialists l
performed a
correct self-check / independent verification, but due to the physical arrangements j
of the electrical panel and the required physical 1
movement of the individuals
- involved, visual I
conte.t with the internal conductor terminating at l
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION r
REPLY TO NOTICE OF VIOLATION 1
VIOLATION 413,414/93-26-01 C1 on relay GK was not retained.
After this loss f
of visual contact with the internal conductor, a
.i second self-check / independent verification was not performed to ensure that the IAE specialists. had returned to the correct component.
At this point, one of the IAE specialists-returned to a crouched position to remove the internal conductor terminating at C1 on relay GK and inadvertently removed the internal conductor terminating at L1 on timer GJ.
A contributing factor in this event was the scheduling of l
activities on Train A VC/YC while Train B was inoperable.
i This was not a direct cause of the inadvertent internal conductor removal, but led to the TS 3.0.3 entry.
2.
Corrective Actions Taken And Results Achieved
[ Example 1}
This event was investigated by the Catawba Safety Review Group (CSRG) and documented in Licensee Event Report (LER) 414/93-03, Reactor Trip Due To Inadvertent Closure Of Main Steam Isolation Valve, submitted to the NRC on 10/25/93.
This event and correct verification techniquer have been reviewed with involved personnel.
j Details of this event were communicated to IAE personnel through electronic mail and through discussions with their supervisors.
Good practices when using electrical diagrams to ensure the link, wire, or device will match to the correct cabinet name legend on the diagram have been communicated to all IAE personnel.
[ Example 2]
This event was investigated by the CSRG and documented in LER 413/93-09, Technical Specification 3.0.3 Involving Control Room Ventilation System, submitted to the NRC on 10/25/93.
IAE personnel involved in this event received additional training on self-checking / independent verffications.
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t DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 413,414/93-26-01 i
This event was communicated to IAE personnel and included l
e a ocod practice of using temporary tagging as an aid when performing self-checking / independent verification in areas which limit the view and movement of the personnel involved.
The work schedule philosophy which allowed the scheduling of work activities on a train of equipment while its redundant train was inoperable was reviewed.
It was determined that restricting the scheduling of work activities on a train of equipment while its redundant train is inoperable would not be an effective means to i
prevent recurrence of this type of inadvertent event..
3.
Corrective Actions To Be Taken To Avoid Further Violations
[ Example 1]
IAE will revise IP/0/A/3890/01, Control'.ing Procedure for
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Troubleshooting and Corrective Maintenance, to include a separate sign-off for self-checking and independent verification to verify the written action steps agree with the drawing.
The procedure steps will also be enhanced to more clearly identify the actions to be taken.
The procedure revisions will be completed by 03/24/94. [ Assigned to IAE]
I AE will evaluate similar type procedures to determine if
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changes are warranted. This evaluation will be completed by 03/24/94. IAssigned to IAE]
Operations will communicate the details of these events i
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to licensed operators through operator proficiency training by 03/24/94. [ Assigned to OPT]
[ Example 2]
I This event will be communicatad site wide by 12/07/93 to o
notify station personnel of this event and to reiterate the significance of performing self-checking / independent verification properly. [ Assigned to HPES]
A HPES review will be performed on this event by 03/01/94.
This review will perform a front end analysis of the self-checking / independent verification training program and will also provide recommendations to aid personnel performing self-checking / independent i
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 413,414/93-26-01 verifications in areas in which visual contact with a component can not be continuously maintained. [ Assigned to HPES]
4.
Date Of Full Compliance Duko I ower Company is now in full compliance.
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DUKE POWER COMPANY CATAWBA' NUCLEAR STATION
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REPLY TO NOTICE OF VIOLATION VIOLATION 414,414/93-26-02
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Notice of Violation 10 CFR 50.73(a)(2)(1)(B) requires that the licensee submit to the NRC a Licensee Event keport for any operation or. condition l
prohibited by the plant's Technical Specification within 30 days after the event has been discovered.
10 CFR 50.73(a)(2)(iv) required tha
.ae licensee submit to the NRC an LER for any event or condition that resulted in a manual or r
automatic actuation of any engineered safety feature.
The opening of the Ice Condenser lower inlet doors during a containment pressurization event is considered an automatic actuation of an i
engineered safety feature, j
Contrary to the above:
[ Example 1]
On August 18, 1992, the licensee's f ailure to perform portions of the outside containment leakage testing at the required frequency required by Technical Specification 6.8.4.a.
was identified.
The licensee failed to submit a Licensee Event Report for the violation of Technical Specification 6.8.4.a.,
Primary Coolant Sources Outside Containment, within 30 days of discovering the violation.
[ Example 2]
On January 31, 1993, with Unit 2 (erroneously stated in Inspection Report as Unit 1) in Mode 4, a water hammer event occurred in the Residual Heat Removal Sys'em suction piping j
and caused a pipe break in a vent line connected in the RHT suction piping inside containment. The subsequent containment pressure increase caused the Ice Condenser lower inlet doors to open.
The licensee failed to submit an LER for this event within 30 days.
t This is a Severity Level IV Violation.
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L DUKE POWER COMPANYi CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 414,414/93-26-02
RESPONSE
1.
Reason For Violation
[ Example 1)
The Catawba Periodic Test (CPT) program was developed to comply with all Technical Specification curveillance requirements.
At the time the program was developed, surveillance frequencies were derived ' from Technical Specifications Table 1.1 and 4.0.2, due to our understanding that the 25% grace period applied-to all Technical Specification surveillances, including those in the Administrative section.
When this question was originally brought to our attention, our evaluation concluded that a violation of technical specifications had not occurred since technical specification intervals as originally applied under our CPT program had not been exceeded.
After further review and discussions with the r
NRC, station management has determined that it may not have been appropriate to apply the 25% grace period to surveillance requirements to the Administrative section of Technical Specifications.
[ Example 2)
The cause for not reporting the ice condenser door opening as an ESF actuation is that policy guidance / management expectations were not well defined or understood.
Nuclear System Directive (NSD) 202, 10 CFR 50.72 Reports, provides guidance for determining the reportability of station events or conditions.
Although section 202.7.2 of this directive defines ESF actuations and lists ESF systems, it does not give direction on actuation of a passive system. Procedure RP/0/B/5000/13, NRC Notification Requirements, provides guidance for reporting of plant conditions..4 of this procedure list ESF actuations for Catawba. Although this enclosure states that it is a guideline only and that it may not contain all ESF actuations, it does not list the ice condenser in the list of actuations.
In response to an event involving McGuire Nuclear Station ESF actuation reportability, Catawba Operations Training provided training on what constitutes an ESF actuation.
This training along with other Containment Building related training does not include momentary opening of the ice condenser doors.
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l DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 414,414/93-26-02 2.
Corrective Actions Taken And Results Achieved i
[ Example 1]
1 CSRG has initiated an investigation of this event in preparation of submitting a LER to the NRC.
[ Example 2]
The investigation of this event was originally documented in a Station Report.
This Station Report was later revised due to additional evidence that the ice condenser doors had opened and submitted to the NRC on 10/25/93 as LER 414 /93-04, Ice Condenser Door Opened Due To Residual Heat Removal System Transient.
3.
Corrective Actions To Be Taken To Avoid Further Violations r
[ Example 1]
An LER concerning this event will be submitted to the NRC by 12/23/93. [ Assigned to SRG)
Based on the results of the LER investigation, planned j
corrective actions will be developed.
A supplement to f
this violation response will be submitted to the NRC outlining the corrective actions to be taken to avoid further violations by 01/10/94. [ Assigned to RGC]
[ Example 2]
NSD 202 will be reviewed and revised as necessary by l
02/30/94. [ Assigned to NS]
Operations training will be revised to reflect NSD 202 changes if necessary by 03/30/94. [ Assigned to OPT]
RP/0/A/5000/13 ESF actuation reporting requirements will be revised as necessary by 02/30/94. [ Assigned to RGC) i 4.
Date Of-Full Compliance Duke Power Company is now in full compliance.
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