ML20070F148
| ML20070F148 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 02/28/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9103080145 | |
| Download: ML20070F148 (3) | |
Text
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DUKE POWER February 28, 1991 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report No. 50-413, 414/90-32 Violation 413,414/90-32-01 Reply to a Notice of Violation Gentlemen:
Enclosed is the response to the Notice of Violation issued January 29, 1991 by Alan R. Herdt concerning failure to review procedures incorporated into the Performance Manual.
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Tuckman WRC/220/lcs xc:
Mr. Stewart D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW., Suite 2900 Atlanta, Georgia. 30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station 9103080145 910228
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DUKR POWER COMPANY REPI.Y TO NOTICE OF V101.ATION 413, 414/90-32-01 Technical Specifiention 6.8.1 requires that written procedures be established, implemented. and maint.ained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 including administrative procedures, test procedures and material control procedures.
Technical Specification 6.8.2 requires that each procedure required by Specification 6.8.1, and changes thereto, be reviewed and approved prior to implementation and periodically reviewed as set forth in administrative procedures.
Station Directive 4,2.1, Development, Approval and Use of Station Procedures, requires in Section 14.0, Periodic Review of Procedures, that comprehensive periodic reviews of all station procedures be performed, at. intervals not to exceed 2 years for safety-related anu not to exceed 5 years for non-safety related procedures.
Contrary to the above, the procedures incorporated in the Catawba Performance Section Manual, a document which embodies virtually all of the administrative procedures portaining to the operation of the Performance Department, were not being reviewed on a periodic basis as required by Station Directive 4.2.1.
This is considered a Violation of both Technical Specifications 6.8.1 and 6.8.2, and is applicable to both units.
RESPONSE
1.
_ Reasons for Violation Performance personnel misinterpreted the classification of the procedures in the Catawba Performance Section Manual as " guidelines" and therefore considered them not to be subjected to the review requirements of Station Directive 4.2.1.
2.
Corrective Actions Taken and Results Achieved A.lanuary 17, 1991 Intrastation letter was sent to Performance Supervisors requesting they perform a review of specified procedures in the Performance Manual.
3.
Corrective Actions to be Taken to Avoid Further violations Station Directive 4.2.1 is being revised to ensure that all safety-related Station Directives and those parts of section_ manuals which address Safety Related Functions require a maximum review period of two years.
Non-safety related Documents will have a maximum review period of five years.
Station Directive 4.2.1 will be approved by 4/1/91.
All Station Directives and Section Manuals will be reviewed and in compliance with this requirement by 12/1/91.
Performance personnel will review the Performance Section Manual and make revisions as required.
The review and necessary revisions will be completed by 6/30/91.
Performance will add all Performance Section Manual Directives to the Performance Section's two year review procedure (PT/0/A/4000/01) to ensure that the two year review is completed as required by Station Directive 4.2.1 This change will be completed by 6/30/91.
4.
Date of Full Compliance Duke Power will be in full compliance by 12/1/91.