ML20066G418
| ML20066G418 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/18/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101280043 | |
| Download: ML20066G418 (6) | |
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s II'I His.1 * ;l DUKE POWER January 18, 1991 U, S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Subj ect: Catawba Nuclear Station, Units 1 and 2 Docket Pos. 50-413 and 50-414 NRC 'inspcetion Neport No. 50-413, 414/90-30 Violations 413, f.14/90-30-01 and 414/90 30-03 itoply to a Notice of Violation Contlement Enclosed 18 the response to the Notice of Violation issued December 21, 1990 by Alan R. lierdt concerning failure to follow procedures and failure to perform required post maintenance testing.
Very truly yours.
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H. S. Tuckman, Vice Ptosident Nuc1 car Operations WRC/220/1cn xet Mr. Stewart D. Ebneter Regional Administrator. Region 11 U. S. Nuclear Regulatory Conanission 101 Marietta St., NW., Suite 2900 Atlanta, Goorgia 30323 Mr. W. T. Orders NRC Resident Inspector Catavba Nuc1 car Station
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DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/90 30-'jl Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained coveriig the activities referenced in Appendix A of Regulatory Guide 1.33, Revision P, % bruary 1978.
Implicit in tiis is the stipulation that the procedures be adequate for the task being performed.
Station Directive 2.12.7, Section 4.3, requires that any gt;up/section dperson)respinsificfordegradinganyfirebarrier,incluJ9pfiredoors,is responsible f or e,wrini that a fire watch is provided until 3he barrier is returned to service.
Operations Manageoent 'recejure 2-17, Control Room and Unit Euper",sor i
Logbooks, requires 'n S'ction 7.0, General Instructions, that sufficient logbook entries shall or made to permit the reconstruction of the sequence of events during a shift.
, wther, sectio,. 10.0, Unit Supervisor Logbook Entries, requires that n $.rics in the unit supervisor's logbook shall provide a details -hronological vork iescription of problems identified during the
.)rrectit e action initiated.
shift t Statior 1:e;tive ?.o.1, Problem Jnvestigation Process and Regulawy Reporting, section 4.0, requires that any employee who has knowled; /d a problem that meets the criteria of Enclosure 3 of the same directi n,
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respont ible in inform his supervisor or responsible technical contatt u ift' iate an investiqP,19n.
Section 5.1 of the directive requires that 4 identified problev thas mnts the criteria in Enclosure 3 shall be docume m d Js soon as pMctics / nnd Civered promptly to the Compliance Section, thb initiating t he inytN1atics nrocess.
Procedure OP/2/A/6250/06, Mei i Steam Enclosure 4.3, requires that valve 71V-66, the S usm Generator (ower Operated Relief Valve (PORV) Line Drain, bv closed, and its associated rupn cap installed when the system is aligned for~
punt operation.
~ Contrary to the above:
A.
On November 3B, 1990, maintenance personnel degraded fire barrier TS27#1, tH fu s door to Unit 1 Auxiliary Feedwater Turbine Pump (CAPT) contro paner re a, bGt failed to fellow Station Directive 2.12.7, in that the persormi Mocked the dcor open and departed the area without es%b11shing a fire catch.
B.
On November 30, 1990, tw Unit 1 operations supervisor was informed that frie door TS27#1 had bee sgrader) and a fire watch had not been posted.
Suuequently, when the cot egi ecom and Unit Supervisor Logbooks were rev ywed, it wag detected thtt the licensee had failed to document the event /prpblem.
C.
On November 30,1990, an event w urred involving the licensee's failure to post a fire watch for a degrat d fire b-arrier.
A Problem Investigation Report (PIR) was rec; tired te have been initiated as soon m
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- Page 2-Las practical af ter detection of the-problem, but the licensee failed to initiate the Report until December 5, 1990, after conversations between the licensee and the resident inspectors concluded that a PIR was appropriate.-
D.-
On November 14, 1990, during a stroke test on the ?L Steam Generator PORV 2SV-13, the licensee failed to follow OP/2/A,6250/06, in tMt 2SV-66 was found open and its pipe cap had not been installed.
This 1
resulted in an_ inadvertent steam release during the performance of the stroke test.
RESP 0NSE::
1.
Reasons for Violation if Admitted item A.
Personnel error was the cause of the violation of Station Directive 2.12.7, Fire Detection and Protection, in that Mechanical Maintenance (M/M) personnel failed to implement fire
' watch requirements as required by Section 4.3 of Station Directive 2.12.7.
Item B.
The operator failed to log the event in the Unit Supervisor and Logbook and follow through with the formal PIR= process. The Item C.
operations supervisor discussed this. incident with the crew involved in opening the door and considered that.to be sufficient.
Item D.
The operator failed to review the tagout when identifying tags to be lifted for testing of the PORV _ Contributing to this was an inadequate procedure in that the tag removal procedure did not' provide a checklist of other means to aid in lifting tags for-testing.
2._-CorrectiveActionsThenandResults-Achieved-l
' Item A.-
Problem Investigation Report (PIR)-1-C90-0355 was originated-to address'the root cause of this-incident.
L Involved personnel were counseled as to the severity of this
-incident.
Appropriate disciplinary action.has been administered in accordance with the Duke Power Policy Manual.
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g iStation Directive 2.12.7 was reviewed by Mechanical Maintenance Management'to ensure proper guidance and instruction-was j'
provided to-personnel.- The review concluded that sufficient detail-and instruction had been provided to meet Technical-L Specification 6.8.1 requirements when administered to M/M j
personnel.
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Page 3 Item B.
The logging of this event is not considered necessary.
The increased attention to the PIR process will ensure proper follow-up actions when an event occurs, item C.
The Operations philosophy en generation of PIRs was initially discussed with all shifts at the Shift Supervisors meeting on December 7, 1990. Operations Management determined that we need to increase our sensitivity to initiating PIRs.
If there is any doubt on the need for a PIR, then write one.
A representative from the Compliance group attended the Shift Supervisors meeting of 1-4-91.
The PIR threshold was discussed by all present.
It was re-emphasized that PIRs would be generated, as required, based upon the initiating criteria in S.D. 2.8.1.
Item D.
The test was secured and 2SV-66 was closed, The policy of lifting tags for testing was temporarily suspended until a tag lifted for testing checklist is developed; which is to provide increased controls over the process of lif ting tags for testing.
3.
Corrective Actions to be Taken to Avoid Further Violations item A.
The involved personnel will cover the details of this incident with all M/M crews at their weekly safety meetings. This will allow the significance and impact of this violation to be communicated and heighten awareness to detail to all personnel in M/M. This communication will be documented on a weekly safety meeting sheet and will be completed by 3/1/91.
Item B.
Actions taken in Section 2 above ensure avoidance of further and violations.
Item C.
Item 0, "A Tags Lif ted for Testing checklist" is to be developed by 4/1/91 for inclusion in the OMP 2-18, Tagout Removal and Restoration (R&R) Procedure.
4.
Date of Full Compliance Duke Power is now in full compliance, u
DUKE POWER COMPANY REPl.Y TO NOTICE OF VIOI.ATION 414/90-30+03 10 CFR 50, Appendix B, Criterion XI requires in part that a trat pro'jrum be optablished to assuru that all testing required tr. demonstrato that structures, sy s toros, and components will perform satisf actorily incorvice ir identified and performed in accordance with written test procedures.
Contrary to the above, on September 21, 1990, required stroko-time and leak rate testo were not performed on containment isolation valve VP 17A af ter the valve had boon cycled during maintenance. This resulted in the licensee's failure to detect that the valve had not closed properly when cyclod, which in turn rondered the valve inoperable.
The Unit was operated from September 25, until Nov6n.bor 7 in Modos 1-4 during which time the valve was required to be operable.
RESPONSH 1.
Roanono for violation if Admitted The required leak rate test was not performed due to the lack of adoquate adminiotrativo controls to ensure that testing is conducted following any cycling of the Containment Purgo Ventilation (VP) system loolation valven.
The maintenarse work and the subsequent valve cycling was correctly determined to require no otroke-time retest.
An optical isolator which providos Operator Aid Computer (OAC) indication of valve position was replaced under the original repair work request. As required by the Post Maintenanco Retont program a functional was completed which verified correct OAC valvo position indication after the isolator was replacod.
Isolator replacement does not require a stroko-time test since it in no way affecto the stroke time of the valvo.
The functional that was performed required a leak rato toet but again this act_vity did not require a stroke-time test since it also did not affact cne stroke time of the valvo.
2.
Corrective Actions Taken and Raoulto Achieved a.
SWR 50325 was issued on 11/7/90 to repair valve 2VPl7A following failure of the semi-annual surveillanco.
The leakage was repaired and the valve was successfully tested on 11/8/90.
b.
The Catawba Nuclear Station Post Maintenance Retest Manual was reviood 11/30/90 and approved 12/3/90 for all 18/ unit VP system l
containment isolation valves to specify that a leak rate test to required following any valvo cycling, including functionals.
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Page 2 3.
correctivo Actionn to be Taken to Avoid Further violationn a.
The test procedure for leak rate testing the
'P system containment isolation valves will be reviood by June 1, 1991 to specify that if VP penetrations are to be leak rate tooted due to VP System operation then all nine penetratione must be tested.
If all nino penetrations had been touted on 9/25/90 following the Unit 2 forced outage, the failure of valve 2VP 17A to fully close would -
have boon detected.
b.
The Operatione procedore for VP System operation will be rovined by June 1, 1991 to requate notification of Performance when the VP system in shutdown for the last time prior to tho unit entoring mode 4.
This change will provido added aneurance that the VP system containment isolation valvos are leak topted following valvo cycling due to system operation prior to entering modos requiring containment intogrity.
4.
Date of Full Complianco Duke Power Company le now in full compliance.
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