ML20079B964
| ML20079B964 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/03/1995 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9501090185 | |
| Download: ML20079B964 (16) | |
Text
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' DukeMerCompany DLRm
. Cuauba Nuclear Generation Department Vice11esident 4800 CancofdRoad (803)8313205 Office c:
thrk, SC29745 (803)8313426 Fax DUKEPOWER January 3,-1995 U. S. Nuclear Regulatory Commission 4
ATTN:
Document Control Desk Washington, D.: C.
20555
Subject:
Catawba Nuclear Station Dockets 50-413 and 50-414 Reply to Notice of Violation Inspection Report 50-413/94-27 and 50-414/94-27 Attached is Duke Power Company' c response to the four (4)
Level IV violations cited in the Notice of Violation (NOV) of Inspection Report 50-413/94-27 and 50-414/94-27, dated December 1, 1994.
These violations were identified during the resident's monthly inspection tour.
If you have any questions concerning this response, contact Kay Nicholson at 803-831-3237.
Sincerely, d4 S.
D. L. Rehn
\\ KEN: RESP 94.27 xc:
S. D. Ebneter, Regional Administrator R. E. Martin, ONRR R. J.
Freudenberger, SRI 9501090185 950103 PDR ADOCK 05000413 g
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[v DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION l
413,414S 4-27-01 l
.i A.
Technical Specification 6.
- 8. 1, Procedures and Programs, requires, inapart, that written procedures be established, implemented and.. maintained covering activities referenced in i
Appendix A of Regulatory Guide 1.33, ' Revision 2,
February
- 1978, which includes Removal and -Restoration Tagout r'
procedures for removing safety-related
. equipment from' service.
I i
i Technical Specification 3.7.6. requires two Control Room Area j
Ventilation Systems to be OPERABLE in all OPERATIONAL MODES-
[
Surveillance Requirement 4.7.6.e.3. requires that the system
{
maintain the control room at a positive pressure of greater
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than or equal to 1/8 inch water gaug" 91ative to. adj acent '
areas.
i Contrary to the above, Unit 2 Tagout 24-1980, dated October 18, 1994, was not adequate in that it did not adequately i
prescribe an activity affecting quality.
Tagout 24-1980 erroneously delineated the " tagged position" of damper 2CR-D-10 as " closed" during the performance of maintenance on the B
train Control Room Area Ventilation System Air Handling Unit.
Damper 2CR-D-10, the Air Handling Unit
[
Suction Damper,.was required to be secured in the closed i
position to maintain the Control Room Pressure Boundary.
The damper was verified to be closed, but was not secured in i
the closed position during the implementation of Tagout 24-l 1980.
As a result, for approximately seventy minutes on the i
morning of October 18,
- 1994, both Control Room Area i
Ventilation Systems were inoperable in that they could not maintain positive pressure greater than or equal to 1/8 inch water relative to adjacent areas in the control room.
l This is a Severity Level IV Violation (Supplement I).
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E DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-0I i
RESPONSE
i 1.
Reason for Violation On October 18,.1994, at 0438 hours0.00507 days <br />0.122 hours <br />7.242063e-4 weeks <br />1.66659e-4 months <br />, with Unit 1 and Unit 2 both in Mode 1,
Power Operation, at 100 percent power, Operations tagged out Train B
of the Control Room Ventilation and Chilled Water System (VC/YC) per Tagout 24-1980.
At 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, Technical-Specification. 3.0.3 was unknowingly entered when the maintenance crew opened access panels on B Train VC/YC to-begin routine maintenance.
Outuard air flow through the open access panel as a result i
of an unsecured backdraf t damper created a bypass flowpath, i
causing the running VC/YC Train A to be inoperable in that it was not capable of adequately pressurizing the Control Room.
l 1
Tagout 24-1980 was implemented to remove the Unit 2 (Train B) Control Room Air Handling Unit for routine preventive i
maintenance per Work Order 94075617-01.
The tagout included I
a tag for damper 2CR-D-10 (Unit 2 Control Room Area Air Handling Unit Suction Isolation Damper) with a
tagged position of " closed". At 0512 hours0.00593 days <br />0.142 hours <br />8.465608e-4 weeks <br />1.94816e-4 months <br />, a Non-Licensed Operator (NLO) proceeded to place the tags.
The manual dampers 2CRA-D-1 and 2CR-D-4, which were also required to be typed
" closed", were found open and each held in place with its respective securing device.
Both 2CRA-D-1 and 2CR-D-4 were properly closed and secured using its respective securing device.
Backdraft damper 2CR-D-10 was found closed since no fan was running in that train. The NLO noted that there was a securing device attached to a chain near the position indicating handle, but not being used on this damper.
Since i
the Tagout did not specify " secured", the NLO did not secure the position indicating handle in the closed position.
s This violation is attributed to less than adequate work practices, in that a NLO in the Operations' Support Group i
who initially developed the " preplanned tagout" selected an inappropriate tagged position for the dampers. Preplanned' i
tagouts are computer generated, and as such the tagged positions are selected from a
" pick list".
Of the selections that were available at the time,
" closed" and
" locked closed" were the two options from the list that most nearly fit the desired tagged position of " secured closed".
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i DUKE POWER COMPANY CATAWBA NUCLFAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-01
" Closed" was chosen because the NLO felt that
" locked closed" implied that a padlock would be required.
The NLO did not take appropriate action tof ensure that the proper tagged position was listed on the " preplanned tagout".
2.
Corrective Actions Taken and Results Achieved The open access panels were closed and work was stopped that involved access to the ductwork until the damper could be secured.
The damper 2CR-D-10 was secured closed.
Operations' management has reviewed key aspects of this event with all operators to ensure a clear understanding of their responsibilities when tasks cannot be completed as required.
This event was discussed in the Operations Shift Managers' meeting on 11/03/94 and was covered in operator requal as follows:
E Shift 11/04/94; C Shift 11/15/94; A Shift 12/02/94; D Shift 12/09/94; B Shift 12/16/94.
l The tagging program's
" pick list" has been revised to include " secured closed" as a possible selection for tagged position.
Preplanned tagouts for the VC/YC trains have been revised to require that the dampers be " secured closed".
3.
Corrective Actions to be Taken to Avoid Future Violations The corrective actions taken as outlined in Section 2 above l
and also described in LER 414/94-006 are considered adequate i
to avoid future violations.
l 4.
Date of Full Compliance Duke Power Company is now in full compliance.
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DUKE POWER COMPANY CATAWBA NUCLEARSTATION.
1 REPLY TO NOTICE OF VIOLATION l
413,414/94-27-02.
B.-
Technical Specification 6.8.1, Procedures and
- Programs, requires, in part, that written procedures be established, implemented and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978, which includes emergency and operating i
procedures for wither responding to or recovering from a reactor trip.
Implicit in this requirement is the
}
stipulation that the procedures be adequate for the circumstances.
Technical Specification 3.7.1.2. requires at least three.
independent steam generator auxiliary feedwater' pumps and associated flow paths to be OPERABLE in OPERATIONAL MODES 1,
[
2, and 3.
Surveillance Requirement 4.7.1.2.1.a.4 requires that each valve in the flow path be in the fully open
{
position whenever the Auxiliary Feedwater System is placed l
in automatic control or when above 10% RATED THERMAL POWER.
Contrary to the above, procedure EP/2/A/5000/ES-0.1, Reactor l
Trip
Response
and procedure OP/2/A/6100/05, Unit Fast i
Recovery, were not adequate in that they did not adequately prescribe an activity affecting quality (i.e.,
the realignment of the auxiliary feedwater system).
As a
result, between approximate 6:55 p.m.
on October 19, and 4:45 a.:4.,
on October 21, 1994, Unit 2 was above 10% rated i
thermal power with the flow control valves in the flow path of two of the auxiliary feedwater pumps in the closed position.
This condition existed in excess of the Technical Specification required action time for two auxiliary feedwater punips and their associated flow paths to be operable.
This is a Severity Level IV Violation (Supplement I),
f applicable to' Unit 2.
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DUKE POWER COMPANY CATAWHA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-02 l
RESPONSE
1.
Reason for Violation During a control board walkdown conducted on 10/21/94, the Nuclear Control Operator (NCO) found 2CA-60, 2CA-56, 2CA-44 and 2CA-40 closed.
These flow control valves for the motor driven auxiliary feedwater (CA) pumps are required to be opened when the CA System is in standby readiness alignment as stated in Technical Specification Surveillance 4.7.1.2.1.a.4.
The flow control valves had been closed since approximately 1800 on 10/18/94 following the Unit 2 Reactor Trip.
As part of the Unit 2 recovery from the reactor trip, the CA pumps were secured when the feedwater (CF) pump was placed in the header.
At this point, no clear procedural guidance existed.
Reactor Trip Response Procedure, EP/2/A/5000/ES-0.1, had a step that prompts the NCO to take the CA pumps off if not needed to feed the S/Gs, however, at that point in the emergency procedure the decision was made to continue to use CA for S/G level control due to the CA System response being different from typical post-trip operation.
This was due to B Train Solid State Protection System (SSPS) being in " TEST" at the time of the trip.
Therefore, the l
crew did not secure CA to ensure post-trip data could be collected accurately and the CA System response fully understood.
The step was checked off and not flagged; therefore, not revisited when the CA pump was secured.
The Unit Fast Recovery Procedure, OP/2/A/6100/05, was used to place the first CF pump in the header.
This procedure does not make mention of placing the CA System in standby readiness unless the CA System was currently being used to feed the S/Gs.
2.
Corrective Actions Taken and Results Achieved The valve controllers for 2CA-40, 2CA-44, 2CA-56 and 2CA-60 were positioned to 100% open.
CP/2/A/6250/02, Auxiliary Feedwater System, Enclosure 4.1, j
Placing The CA System in Standby Readiness, was completed to 2
7 DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-02 verify the CA System was in standby readiness, with no additional discrepancies noted.
Procedure EP/1 (2) /A/5000/ES-0.1, Reactor Trip Fesponse, has been revised to provide clear guidance for returning the CA
'i System to standby readiness A, step has been-added to OP/1-(2) /A/ 6100/ 05, Unit Fast Recovery, to require the operators to align CA for standby readiness if CA pumps are off.
i.
OMP 2-22, Shift Turnover, has been revised to add valves 1 (2 ) CA-4 0, 1 (2 ) CA-4 4, 1 ( 2 ) CA-56, and 1 ( 2 ) CA-60 to the Control Room Indication Checklist that is performed by the control room operators as part of shift turnover routine.
l Operations has revieued the Control Room Indication Checklist for each unit to determine if other key components needed to be added or deleted.
This review did not identify any needed changes.
l Senior Operations management has clarified and enhanced the Operations philosophy for responsibilities of operators with r
special emphasis on Control Board monitoring and required actions when securing equipment.
This philosophy was communicated to all Operations personnel in Licensed Operator Requalification, Segment 10.
3.
Corrective Actions to be Taken to Avoid Future Violations The corrective actions taken as outlined in Section 2 above dnd those also described in LER 414/94-007 are considered adequate to avoid future violations.
4.
Date of Full Compliance Duke Power Company is now in full compliance.
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i DUKE POWER COMPANY 1
CATAWBA NUCLEAR STATION i
REPLY-TO NOTICE OF VIOLATION 413,414BM1-03 l
Notice of. Violation l
C.
Technical Specification 6.8.2,; ' Procedures and Programs,-
requires, in.part, that written L procedures be established, implemented and maintained
~ covering the activities referenced in Appendix A of Regulatory. Guide 1.33, Revision 2,
February
~1978, which includes licensee procedures
.l controlling testing'of the reactor protection system.
.l t
Nuclear Policy Manual (NSD) 704, Technical Procedure Use'and Adherence, Appendix A, Management Expectations for Procedure Use and Adherence, requires that any time during. the performance of a procedure, the anticipated results are'not 1
or will not be obtained, the performer should immediately stop, and report the condition to supervision.
IP/2/A/3222/00D, Analog Channel Operation Test Channel IV
- 7300, requires the Solid State Protection System (SSPS) i Train A Multiplexer Test Switch to be placed in'the "A+B" position during the conduct of testing.
Upon completion of j
testing, the procedure authorizes the switch to be placed back in its " normal" position.
i Contrary to the above, on October 18, 1994, Instrumentation-(
and Electrical (IAE) technicians failed to adequately j
implement NSD 704 and IP/2/A/3222/00D in that, activities l
were not stopped and supervision contacted after identifying l
a potential conflict in which it was recognized that anticipated results would not be obtained.
The conflict l
arose due to simultaneous testing which involved placing the i
Multiplexer Test Switches.in both SSPS trains in the "A+B" position.
This condition was recognized to potentially cause confusing indication to Control Room Operators.
In j
order to resolve this conflict, IAE technicians decided to i
place the SSPS Train A Multiplexer Test Switch back in its
" normal" position out of sequence with when this action was authorized by procedure IP/1/A/3222/00D.
This caused an l
SSPS Train A General Warning Alarm to be generated when the switch passed through the " inhibit" position.
Since' a j
General Warning Alarm was already present, a reactor trip on two SSPS General Warnings resulted.
This is a
Severity Level IV Violation (Supplement I),
I applicable to Unit 2.
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4 DUKE POWER COMPANY.
CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-03 i
RESPONSE
l
'1.
Reason for Violation i
This violation ~ is attributed to less than adequate document I
use practices.
The IAE technicians performing the Train B Reactor Trip Breaker and Train B SSPS Periodic Tests did not l
meet management expectations when they' repositioned the SSPS l
Train A multiplexer test switch without specific procedural guidance.
The IAE technicians performing the 7300 System i
Channel IV ACOT also did not meet management expectations in that they allowed the technicians performing the Train B SSPS Periodic Test to reposition a switch that had been positioned in accordance with their 7300 system proceciure.
A contributing cause is the fact that these activities were being performed at the same time, which is not in accordance
. with the station's philosophy for scheduling work.
IAE technicians A
and B
were performing procedure IP/2/A/3222/00D, 7300 Channel IV ACOT, which is normally a one day work activity.
This work activity began on October 17, 1994 and due to the discovery and subsequent repair of a failed component during the ACOT, the remaining portion of the ACOT was carried over and resumed on October 18, 1994.
Also on October 18, 1994 IAE technicians C and D began previously scheduled work per procedures IP/2/A/3200/08B, Train B Reactor Trip Breaker Test, and IP/2/A/3200/02B, Train B SSPS Periodic Test.
Each team was well experienced with their assigned work activity, and had successfully performed their tasks numerous times before in accordance with these same procedures.
While they were proficient on their assigned tasks, neither team was fully aware of the details of the other team's work, and not aware that their procedures would require multiplexer test switch manipulation in different trains of the Solid State Protection System (SSPS).
Technical Specification Surveillance Requirement 4.3.1.1 l
imposes a two hour limit on bypassing a train of the reactor trip breakers for testing.
The bypass condition is accomplished by placing a Reactor Trip Bypass Breaker in the
" connect" position, which also generates a General Warning condition in that train of the SSPS.
Technicians C and D had placed the B
Train Reactor Trip Bypass Breaker in the
" connect" position, and were in this "two hc r window", when 2
i
e DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27 g they reached a step in their procedure that required placing the SSPS Train B multiplexer test switch in the-
"A+B" position.
The technicians recognized an. unusual situation'in that the SSPS Train A multiplexer test. switch was already in the "A+B" position.
Rather than.. continue' on with their F
procedure step to position the B train switch, technicians C and D stopped to evaluate the impact of this - action on the current system alignment.
Both technicians stated that they were unsure of the impact on1 plant and system operation if both switches were in the "A+B" position.
They evaluated the situation by discussing the status of each team's in-progress work with Technicians A and B.
IAE technicians A, B,
C, and D agreed that the most appropriate action would be to return the SSPS Train A multiplexer test switch to the " Normal" position, and communicated this action plan to OPS.
With the Train A switch in the " Normal" position, technicians C and D could continue with their procedure and complete their tests within the two hour time limit.
Technicians A and B evaluated the status of their work, and could identify no alignments in the A Train that would cause a problem with the multiplexer test switch being returned to the " Normal" position at t' cat time.
Their assessment did not consider the condition of the SSPS Train B, which was still in a General Warning condition due to the bypass breaker position, nor the fact that the A Train multiplexer test switch was considered to be under their control since it was positioned in accordance with their procedure.
Technician C then returned the SSPS Train A multiplexer test switch to the
" Normal"
- position, which generated a General Warning alarm in the SSPS Train A as the switch passed through the " Inhibit" position.
With a General Warning already present in the SSPS Train B,
the General Warning in SSPS Train A resulted in a reactor trip.
The initial actions of technicians C and D were in accordance with the management expectations for procedure use and adherence, in that they recognized an abnormal condition and stopped their work activity.
They reviewed the situation with OPS and other IAE technicians, and arrived at a decision the intent of which was to return the SSPS to a normal condition and permit them to continue work in accordance with their procedure.
However, in returning the SSPS Train A multiplexer test switch to the " Normal" position, they did so without specific procedural guidance which did not meet the management expectation for procedure use.
The management expectation is 3
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION i
REPLY TO NOTICE OF VIOLATION 413,414/94-27-03 that.IAE Technicians C and D would have followed the direction of Nuclear Site Directive. 704, Technical Procedure Use and Adherence, which would have led them to stop the activity and-to-contact their supervisor when they encountered the situation in question.
The actions taken by technicians A and B did not meet the management expectation for procedure use and adherence in that they permitted a switch that had been positioned.in accordance with their procedure to be repositioned by other personnel.
The need for maintaining control of equipment / components that have been aligned per a procedure is an expectation of procedure use and adherence.
With regard to the contributing cause of conflicting. work activities performed at the same time, IAE technicians C and D found themselves in an unusual position when they discovered an unexpected alignment of the SSPS Train A multiplexer test switch.
That situation had not been encountered in any of the numerous times they had previously performed this work without incident.
The Reactor Trip Bypass Breaker and the 7300 ACOT work activities are not typically performed at the same time, and would not have been on this date if the 7300 System ACOT had completed on the previous day as was expected.
2.
Corrective Actions Taken and Results Achieved f
The IAE technicians involved with this event have been counseled on their failure to meet the expectations for proper procedure use and adherence.
The responsibility for maintaining control of equipment that has been positioned or aligned to support a work activity has been communicated to all Maintenance personnel.
The communication also reinforced the expectation to stop work and contact your supervisor when an unexpected situation or response is encountered during the conduct of your work.
The scheduling philosophy at Catawba requires train related work to be completed within designated work weeks with no overlap between trains allowed.
This philosophy has been clearly communicated to all station personnel.
A policy has been adopted that requires prior approval by the Station Manager for performing any cross train work (e.g. Train A work 4
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION ^
REPLY TO NOTICE OF VIOLATION 413,414/94-27-03 during a Train B week).
This policy has been clearly communicated'- to all station personnel and is controlled through the work scheduling process.
A formal policy has been developed and put into place for evaluating the impact of carryover work on other work that is scheduled for the next day.
F 3.
Corrective Actions to be Taken to Avoid Future Violations The corrective actions taken as outlined in Section 2 above and those also described in LER 414/94-007 are considered adequate to avoid future violations.
4.
Date of Full Compliance Duke Power Company is now in full compliance.
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t DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION j
413,414/94-27-04 Notice of Violation l
D.
Technical Specification 6.8.1, Procedures and
- Programs, requires, in part, that written procedures be : established, f
. implemented and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision.
2, February
- 1978, which includes licensee procedures i
controlling maintenance on safety-related systems.
Instrumentation Procedure IP/0/A/3890/01, Controlling Procedure for Troubleshooting and Corrective Maintenance, Section 10.1, Preliminary Requirements requires IAE and Operations personnel to determine the impact of planned troubleshooting activities on plant operations and. ef fects.
on Technical Specification requirements.
Contrary to the above, between October 18-22, 1994, licensee personnel failed to properly implement IP/0/A/3890/01.
IAE and Operations personnel did not adequately evaluate the impact on plant operations and the effects on Technical Specifications of planned troubleshooting activities to t
investigate and repair the loss of indication from Power Range Nuclear Instrumentation Channel N44.
During the period of the troubleshooting
- activity, Power Range Instrumentation Channel N44 was considered inoperable.
On r
several occasions, the control power fuses to Power Range Nuclear Instrument Channel N44 were reinstalled which unknowingly reinstated the High Neutron Flux and High Neutron Positive Rate reactor trip bistables.
Since these reactor trip bistables were not maintained in the tripped condition, the action requirements of Technical Specification 3.3.1. were not complied with.
L This is a Severity Level IV (Supplement I), applicable to Unit 1.
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DUKE POWER COMPANY f
CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-04
RESPONSE
1.
Reason for Violation This violation is attributed to less than adequate communication between the IAE and OPS personnel during their pre-job discussion of the scope of troubleshooting activities i
to be performed on Channel N44 of the Nuclear Instrumentation System (NIS).
As required per the controlling procedure, the IAE technicians did not identify sufficient details of their planned work scope to OPS personnel such that the effects of their actions on plant operation and Technical Specification requirements could be determined.
Contributing causes - were inadequate work practices by OPS to maintain positive control of the NIS control power fuses, and inadequate procedures for IAE in terms of guidance for replacement of the NIS control power fuses.
IP/0/A/3890/01 was being used by IAE personnel to perform the troubleshooting activities to investigate and repair the loss of indication for Channel N44 of the NIS.
Additional NIS specific procedures were also being used to perform certain associated activities such as placing the channel in a trip condition and verifying proper indications and alignments.
l i
l Troubleshooting evolutions typically use IP/0/A/3890/01 as the controlling procedure to identify and correct the prob]em.
System specific maintenance and test procedures are also used to ensure proper functional verification and testing requirements are met prior to returning equipment to service.
The system specific maintenance and test procedures also serve as a reference to obtain system specific information such as limitations and precautions on removing and restoring a
component / instrument / channel to service.
Procedure IP/0/A/3890/01, Section 10.1, Preliminary Requirements, j
l requires IAE to confer with the operational control group (in this case the Control Room SRO) to determine effects of the planned work activity on plant operation and Technical Specification requirements.
The management expectation is that this discussion will include a review of the planned work scope, a review and discussion of any applicable Technical Specifications, and identification of any specific limitations.
Procedure IP/0/A/3890/01 was followed as written during the preparation to begin work on the N44 channel, however, the level of review and discussion between IAE and 2
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' DUKE POWER COMPANY CATAWBA NUCLEAR STATION-REPLY TO NOTICE OF VIOLATION 413,414/94-27 OPS personnel as required by:Section 10.1 was not adequate-to identify the. limitation associated with replacing the control power fuses while the channel was'in a tripped condition.
- A detailed review of the appropriate Technical Specification and L
discussion of the scope of work planned to be performed could have identified the conflict with' replacing the control power fuses.
It is the management expectation that effective' pre-job communication between
.IAE and Operations -will accurately identify the scope of planned
- work, and permit proper determination of effects of the work activity on plant operation and Technical Specification requirements.
With regard to the contributing
- causes, OPS. procedure AP/1/ (2) /A/5500/16, Malfunction of Nuclear Instrumentation System, requires the removal of NIS power range instrument fuses and control power fuses upon identification of an-inoperable channel, and verification that associated reactor trip bistables indicate the tripped condition.
There was no additional guidance provided in the OPS procedure concerning reinsertion of these fuses.
Additionally, the IAE NIS system specific procedures contained sections for removal and replacement of the instrument.and control power fuses during certain maintenance and test activities, however these procedures did not identify any limitations for replacement of fuses.
The work scope of troubleshooting the failed NIS indication required-that the instrument power fuses be reinserted to monitor the channel response.
Also during the-course of repairs and functional checkout of the channel, it was necessary to have the control power fuses in place to verify proper operatlon.
Since there was no limitation identified for control power fuse installation..in either the OPS or the IAE procedure, the control power fuses were reinstalled at the same time as the-instrument power fuses, thereby reinstating.the reactor trip bistables for High Neutron Flux and High Neutron-Positive Rate.
It is also the management expectation that activities such as this one have procedural guidance and controls in place to supplement the control process, rather than depending entirely on the communication to identify all effects of the' work activity.
-The IP and AP procedures -for NIS power range channels were inadequate in that sufficient procedural 3
4 DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-27-04 controls or reference to limitations on installing the control power fuses did not exist.
2.
Corrective Actions Taken and Results Achieved NCO removed the control power fuses to comply with Technical.
Specifications.
Expectations for the level of review and discussion between IAE and OPS personnel, as required by IP/0/A/3890/01, have been discussed with the individuals involved with this event.
A communication to all IAE personnel has been made to ensure full understanding of this expectation for all users of this procedure.
OPS has revised AP/1/ (2)/A/5500/16 to provide positive control of the control power fuses.
Senior OPS Management has reviewed with all OPS personnel the expectations of operators, especially licensed operators, during removal, troubleshooting, and return to serv!ce of equipment under OPS control.
Emphasis was placed on our commitment to fully understand work plans that are Tech Spec related and to maintain a questioning attitude throughout the pre-job briefing between OPS and the work crew.
Engineering has developed a method that will allow maintaining the NIS bistables for High Neutron Flux and High Neutron Positive Rate in a tripped condition while performing typical troubleshooting, maintenance, and calibrations.
The channel restoration process for replacement of the control power fuses is dependent on the scope of the work activitiy, and is developed by IAE and Engineering on a case by case basis.
3.
Corrective Actions to be Taken to Avoid Future Violations The corrective actions taken as outlined in Section 2 above are considered adequate to avoid future violations.
4.
Date of Full Compliance Duke Power Company is now in full compliance.
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