ML20070R684
| ML20070R684 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/27/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9104010329 | |
| Download: ML20070R684 (9) | |
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p m Wt DUKEPOWER March 27, 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, 414/91-03 Violations 413,434/91-03-01, 413/91-03-02 and 413/91-03-03 Reply to a Notice of Violation Gentlemen:
Enclosed is the response to the Notice of Violation issued February 27, 1991 by Alan R.
Herdt concerning failure to follow procedures or inadequate procedures, failure to ensure the emergency personnel hatch between upper and lower containment compartments was operable and a mode change while in the Technical Specification Action Statement for an inoperable train of the Residual Heat Removal System.
Very Truly Yours, f -b M.
S.
Tuckman, Vice President Nuclear Operations WRC/RES91-03 Attachment f,
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U.
S. Nuclear Regulatory Commission March 27, 1991 Page 2 xc:
W/ Attachment Mr. Sewart D..Ebn'eter 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.
7 Catawba Nuclear Station Mr. R.
E. Martin Office of Nuclear Reactor Regulation U.
S.
Nuclear Regulatory Commission OWFN, Mail Stop 9H3 Washington, D.C.
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9 DUKE PCVKR C NPANY REPLY TO NOTIC? 0F VIOLATION 413, 415/9.-03-01 Technic ' Specification (TS) Sect ion 6.8.1, requires that. written procedures shall Se established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Implicit in this requirement is Ihe stipulation that the procedures be adequate for the task being performed.
Operations Management Procedure (OMP) 1-8, Authority and Responsibility of Licensed Reactor Operators and Licensed Senior Reactor Operators, Sectlan 7.0, Authority and Responsibility of Licensed Reactor Operators, Part 7.2.B.
requires that the operator at the Controls (OATC) shall: a) be knowledgeable of the unit status at all times; b) ensure the unit is safely operated in compliance with Technical Specifications and operating procedures and, c) ensure that control room instrumentation is routinely surveyed and information.f rom this survey is evaluated to assure safe unit operation.
Station Directive 2.12.7, Fire Detection and Protection, assigns the ultimate responsibilities of ensuring that the plant fire detection and protection requirements are met to the Fire Protection Console Operator (FPCO). Among the FPCO's duties and responsibilities are the monitoring of alarms on the Fire Protection Console (FPC), which is located in the control room, and the verification of fire detection and protection system impairments to ensure that fire watch surveillances are conducted as required.
Contrary to the above:
A.
On January 8, 1951, the Unit 2 OATC was not knowledgeable of the unit status, in that for a period of approximately 10 minutes after receiving a Steam Generator Level Deviation alarm and noting a high steam generator level in generator 2A, he did not adequately monitor the indicated level instrumentation for that generator to ef fectively evaluate available information in order to assure that the unit was operated safely, in compliance with operating procedures. This ultimately resulted in a feedwater isolation and an inadvertent ESF actuation.
B.
On January 8, 1991, procedural instructions detailed in work request 3848MES were inadequate in that the work request instructions had-incorrectly specified the placement of electrical jumpers. These erroneous instructions resulted in an inadvertent Auxiliary Feedwater auto-start signal while personnel were performing wiring corrections to the ATWS Mitigation System Actuation Circuitry (AMSAC) on Unit 2.
C.
On January 26, 1991, the Fire Protection Console Operator failed to investigate the cause of a Diesel Cencrator 1B CO2 trouble alarm to determine if the system was impaired and if a fire watch was required.
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RESPONSE
1.
Reason for Violation item A.
The Operator at the Controls (OATC) was' distracted from the control boards by other control room activities while the S/G 2A water level was.in alarm.
Inappropriate action was taken in that.the OATC did not restore the S/G 2A water level to the normal level'to clear the S/G 2A Level Deviation Alarm.
Item B.
This incident was attributed to an inadequate review of step by-step instructions which were developed for a' unique corrective maintenance situation.
When plant conditions required for maintenance could not.be mot, changes were made to the origina1Lwork request instructions.
Adequate review of the changes was:not performed.
Item C.
This incident occurred due to miscommunicationibetween the Shif t-Supervisor, Control' Room Operator and.the FPCO.-
2.
Corrective Actions Taken and Results Achieved Item A.
Operations evaluated adding to the Operations. Procedures, OP/1,2/A/6250/02, " Auxiliary Feedwater System, Manual-
-Operation of-the Motor Driven Auxiliary Feedwater Pumps lWhcu
- Aligned for Standby Readiness" Enclosure 4.3, using_a temporary S/G hi level alarm on the computer if the computer and data point are-in servico.- The Unit-'l computer alarm-was set between the Deviation Alarm and Hi Hi S/G 1evel Alarm.=
item B.
MES personnel involved in.this event IIave been reminded of the importance of proper independent verification -of: work request instructions.
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Item C.
Station-Directive-2.12.7, " Fire Detection and' Protection" was revised to specify'indiv.idual responsibilities more cicarlyithan provious-directives and procedures.:-Therefore, preventing future reoccurrences.
3.
Corrective Actions to be Taken to avoid further Violations-l Item A.
Operations is pursuing a change-to the Unit 2 computer alarm to occur between the deviation and 111-111 level alarms by
- August 1,. 1991.
Evaluate the arrangement of the Nuclear Control Operator (NCO) tables in the Control Room so the NCO is facing the control boards.- This is to be completed by-August 1, 1991.;
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Changes will be made to operations Management Procedure (OMP) 2-17, Control Room and Unit Supervisor Logbook, to allow the NCO responsible for the Balance of Plant (BOP) activities to make logbook entries. This is to be completed by June 1, 1991.
Operations management will emphasize during shift meetings to always achieve expected or desired results prior to diverting attention to other matters. This will be completed be May 15, 1991.
Item B.
The maintenance programs will be reviewed and revised by June 15, 1991 to ensure that proper guidance is provided for the independent verification of the development of procedure steps. These steps apply to unique corrcctive maintenance situations only, and not to routine maintenance procedures which rocciva adequate reviews prior to their execution.
Appropriato maintenance personnel will be trained by August 15, 1991 on the changes made to the maintenance independent verification process.
Item C.
Actions taken in Section 2 above ensure avoidance of further violations.
4.
Date of Full Compliance Duke Power is now in full compliance.
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i DUKE POWER COMPANY REPLY '10 NOTICE OF VIO1ATION
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- 413/9bO3-02 1
Technical Specification, Section 3.6.5.5. requires-the personnel access doors' i
and equipment hatches betwocn the containment s upper and lower compartments to be operable and closed when t.he unit is in Modes 1 through.
~ 4.
With a personnel access door or equipment hatch inoperable or open I
except for personnel transit, the door / hatch is to be restored to-its operable or closed _ position'vithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the unit must be placed in at least hot standby within the next.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
1 Contrary to-the above, on January 10,:with the unit in_ Mode.3, tho' i
emergency personnel hatch in t.ho-barrier between the _ Unit 1 ; upper and lower containment compartments was_ determined to be inoperable in that the j
hatch was found closed but not secured.
This hatch had.apparently been inoperable since January 4, 1991, when the unit was shut-down for a forced outage.
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RESPONSE
1.
Reasons for Violation This incident-is attributed'to equipment failure / malfunction. One'(1)l of four_.(4) locking arms was incorrectly adjusted which permitted only one (1) bearing surface to exist rather than-four. (4) as designed. The single point of contact that existed was a beveled surface which tended to force the latching mechanisms to an uniatched position when a repetitive downward force was applied.. Personnel stepping on and off:tho-hatch eventually-forced the locking arm to retractfand becomo unlatched.- lleavy traffic existad.in-the immediate area of the hatch during lower iee condenser work which began on January 4, 1991.
2.
Corrective Actions Taken and Results Achieved Upon discovery,' work _ request 9077 SWR was issued'to cl'ose and a.
lock hatch on Unit.jl. -
b.
- Work request 4716 SWR.was'lasued to verify hatch onl Unit 2 to be closed and-locked.
c.
Problem Investigation Report.1-C91-0017 was initiated to datormine_ root cause and identify corrective-action to-bo impicmented.
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-d.
' Personnel entered the area and' replicated the conditions. described in Section 1.
Corrective actions _to=provent reoccurrence were
-identified at this time.
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t 3.
Corrective Actions to be Taken to Avoid Further Violations a.
Adjust latching arms for proper hatch securement. This will be performed during U1EOC5.
b.
Modify hatch by installing a match mark t.ab underneath the handwheel. This tab will also serve as the location for placing the tamper scal in a more restricting configuration. This will be perforaxn1 during UlEOC5.
c.
Develop a procedure reflecting the hatch modifications, points and instructions for latch adjo"; aents and correct closure. This procedure will be completed by the end of U1EOC5.
d.
Identify the area surrounding the hatch as sensitive equipment and "Do Not Step" will be p'14.ced on the hatch itself, c.
All the above actions will be implemented for the Unit 2 cmergency hatch during U2E004, f.
Operations will add a visual inspection of the hatch seal in Modus 1-4 to the Reactor Building Rounds.
4.
Date of Full Compliance Duke Power is now in full compliance.
DUKE POWER COMPANY.-
REPLY TO NOTICE OF VIOLATION 413/91-03-03 l
Technical Specification, Section 3.5.2, states that'for Modes 1,-2, and 3, two independent ECCS subsystems shall be operable with each subsystem including an operable ND pump and an operable flow path capable of taking suction j
from the FWST on a Safety Injection signal _and. automatically transferring suction to the containment sump during theLrecirculation phase of operation.
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Action Statement a, of TS, Sect' ion _3.5.2 states that with one ECCS subsyttem
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inoperable, the inoperable subsystem must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or-the unit must be placed=in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Technical Specification 3.0.4 requires.that entry into an operational mode or j
other specified condition shall not be made when the conditions for-the Limiting Condition for Operation are not met and the associated Action
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Statement requires a shutdown if they are not met within a specified tine i
- interval, Contrary to the above requirements, Unit 1 was taken from Mode 2 to Mode 1 i
with-thn lA ND Pump inoperable, a violation of the requirements of TS, Section 3.0.4.
RESPONSE
1 1.
Reason for Violation This incident is attributed to Inappropriate Action for the closure of 1FW-27, due to a less than adequate knowledge of the function and r
operability impact of 1FW-27A.
i The OATC who had just initiated actions to perform a plant mode change, closed 1FW-27A while performing a stroke test. The Operator-.
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at the_ Controls (OATC) mistakenly thought the valve-received an auto-oper signal on a Safety Signal (SS); thus closure of the valve could be
~ owed.
1FW-27A actually receives an auto-close signal on low FWST e 11 (~ 37%). This mindset also contributed to the_0ATC's l
. f ailure to consider and recognize the valve's -impact of 1A ND Pump operability. This is evident in that prior to-requesting the closure of IFW-27A, the Nuclear License ' Operator (NLO). performing the test read f
the procedural caution statement to the10ATC which warned that closing lFW-27A may cause the 1A ND Pump to operate without an i
available suction source, yet the -ND _ train's abilityf to-perform its -
safety function was not questioned.
2 2.
Corrective Actions Taken and Results Achieved t
This incident was discussed with all involved Operations Shift i
l personnel prior to the next shif t turnover.
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An Operator _ update package v99 issued to inform all10perations Shift I
personnel holding licenses about the incident and the ' lessons learned.
i The update places emphasis on explaining the function of 1FW-27A, its ef fect on 1A ND Pump operability, and clarification of the caution statement in the test procedure.
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Operations management has clarified to licensed shift personnel that review of'in progress test ~ activities prior to plant mode / condition changes must include tests already underway, _as _ well as procedures held in the Control Room as in progress.-
3.
Corrective Actions to be Taken to avoid further Violations i
A formal mechanism to track periodic _ tests which are in-progress in the control room and ~1n. the field will be developed by June 1,199A.
Operations will enhance PT/1,2/A/4200/53A & B. by June 1, 1991 to-ensure that the portodic test explicitly-states the impact on ND System operability with 1FW-27A or FW-55B closed.
Operations Training Group will explain and discuss this incident with all shift personnel during roqualification-training. This discussion-will emphasize the importance of group communication and interface between-shift personnel from the start through'the completion of any testing involving the Control Room.
In addition, it will reemphasize the
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Operations policy of CR0s rocciving direct confirmation and approvcl from the Control Room Senior Reactor Operator (CRSRO)' for allE tasks that may affect _the operability;of;any safety related system or the configuration of any system which has a significant effect on-plant operation.' This will 'tx3 completed by August 1, 1991.
Operations Management Procedure (OMP) 1-8 will txi revised to reflect i
the above corrective action by June 1, 1991.
b 4.
' Date of Full Compliance.
Duke Power is now in full compliance.
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