ML20079C647
| ML20079C647 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/18/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106240305 | |
| Download: ML20079C647 (5) | |
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e ouxepowen June 18,1991 U. S. Nucleat Regulatory Commi:.sion ATrN: Document Control Desk Washington, DC 20555
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Maintenance Team Inspection (50-413/90-201 and 50-414/90-201)
Duke Power has reviewed the Maintenance Team Inspection (MTI) report for Catawba Nuclear Station dated January 4,1991. The inspection was conducted during the weeks of November 12-16 and November 26-30,1990. The report was thoroughly reviewed and action plans were formed to address t!'c areas needing improvement. Items noted in the report were also compared with other assessment results.
In conducting the review, a number of items were noted that may have been given undeserved significance and not representative of the performance in these areas. Attached is a list of specific comments which are referenced to the items in Appendix A of the MTI report.
Thank you for providing the opportunity to present these viewpoints. Once again, it should be emphasized that actions are being taken to improve in all areas mentioned in the MTI report.
Very truly yours, Y\\. h.
I M. S. Tuckman Attachment CRIJMTIRESP 0.
9106240305 910618 PDR ADOCK 05000413 1<)
l 0
U. S. Nuclear Regulatory Commission June 18,1991 Page 2 xc: S. D. Ebneter Regional Administrator, Region Il R. E. Martin, ONRR W. T. Orders Senior Resident inspector S. A. Varga, Director Division of Reactor Projects 1/11, ONRR
1 9
1of3 1.
Inadequate Procedures Duke Power recognizes ihe need to upgrade the technical quality of our maintenance procedures. A significant effort has been underway to enhance the technical quality and useability of our procedures. Management has shown strong support for this effort by dedicating a large amount of resources, people, and equipment to upgrade procedures. One of the largest crews in Mechanical Maintenance is the procedure writers crew and top of the line computer resources have been dedicated to the procedure area to streamline the writing process and enhance graphics.
Another major part of the procedure upgrade program is crew involvement through the validation process to ensure the procedure is uscable. It is also Duke's expectation i
l that if personnel in the field encounter a situation in which a procedure is obviously incorrect, unsafe, will damage equipment, or will result in it. correct data, the work is to be stopped until the procedure can be changed using the methods outlined in the Station Directive.
The following specifics are to be noted:
l Item (3), page A-1; a review of the wording differences noted in the report had previously been conducted by Nuclear Production Department personnel, and it was
- concluded that the differences were either of low significance or that station policy was more conservative.
Item (4), page A-2; did not give consideration to the impact of mock-up training.
The process was performed on a mock-up prior to-the actual field work. The
_ process used was verified during multiple sessions on the mock-up by the same l
personnel who performed the actual field work. The ability tc verify correct l
dimensions and results through mock-up disassembly reduced the need for field measmements which would have been made in a high radiation area. The total process of mock up work and field guidance, when used in conjunction with the procedure, provides results that are superior to the results achieved from using the procedure alone.
Item (5), page A-2; Duke Power admits that the emergency DC lighting issue was not handled in a timely manner as stated on page A-7.
However, the DC l
Emergency Lighting Maintenance Program has been upgraded based on recommendations from a Design Engineering analysis.
As a result, the "DE Emergency Lighting (ELD) System Periodic Maintenar.ce and Testing Procedure" (IP/0/B/3450/02) has been revised to implement these engineering 1 commendations. This revision includes a requirement for 100% annual capacity testing and monthly operability testing of all emergency lighting units. This should
2 of 3 keep the battery plates clean and the acid active, thus improving the reliability of i
the DC emergency lighting units.
Duke Power believes that the combination of increased resources dedicated to upgrading the technical quality of procedures along with increased involvement from Ocid personnel will increase the accuracy and uscability of our procedures.
2.
Eailure to Follow Procedures Duke Power has aggressively worked to reinforce its expectnions for conformance to procedures and feels that the performance generaiiy meets expectations, if personnel i
in the field encounter a problem with performing a procedure as written, they are expected to stop the work until the procedure can be changed using methods outlined in the Station Directive.
The following specifics are to be noted:
Items (1), (5), (6), and (7), pages A-4 and A-5; these findings are cases where the procedure was not followed literally, but the intent of the procedure was met.
These procedures have been revised to provide more realistic criteria for meeting the original intent upon which the procedure was based or training is being provided
- to ensure that the literal requirements are met.
3.
Failure to Promptly identify and Correct Deficiencies 4
Duke Power is d;veloping a " lower tier" deficiency system to reinforce and improve this area. The " lower tier" system is a system for documenting and tracking items of lower significance with provisions for escalating issues up to the PIR level when the appropriate conditions are met.
The following specifics are to be noted:
Items (b), (c), and (d), page A-7; Duke admits that PIR's should have been written for these instances. However, in each case Duke new that the event occurred, new why the event occurred, and had undertaken means to prevent tl.cse events from reoccurring, item (c), page A-8; Duke Pcwer believes that the appropriate priority I.ad been assigned to the original work request. Other indications of steam generator level were available and there were also other means available for trending this parameter. The work request priority was increased by a plant staff member only in response to the inspectors repeated instance that the work be performed sooner.
3of3 4.
Shelf Life This deficiency was entirely corrected before the MTI team left Catawba. Duke Power feels that while this is a correctly identified deficiency in the control proces; in Materials, this one deliciency was not representative of the performance in this area. An assessment of the Matenals functions performed two weeks after th MTI visit, by an independent group outside of Duke Power, found the functions to be a strength.
5.
Indeoendent Verification It is Duke Power's policy for both individuals performing a procedure to verify an action prio o the m mipulation of a component. Even though the two individuals are working clcsely together, each individual is independently responsible for performing verification. Should an individual perform a task alone and make a mistake, the mistake would not be discovered until after any potential damage had occurred. It is Duke's position that, by acting together, wrong train and unit type mistakes will be stopped before they happen.
This method for performing Independent Verification also has a safety benefit because the two individuals working closely together form a buddy system. This helps to reduce the potential for injury that exists in the harsh environment of a nuclear station.
Therefore, there was no failure to adhere to tne Independent Verification requirements detailed in the procedures because the Duke Power policy for Independent Verification was followed.
.