ML20081K295
| ML20081K295 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/22/1995 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503290047 | |
| Download: ML20081K295 (4) | |
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Cahuvba Nudear Genemtion Depanment '
11cePresident 480)ConcontRoad (803)8313205 Oflice Yortr.SC29745 (803)8314426k 1
mm March 22,1995
-i U. S. Nuclear Regulatory Commission
.A'ITN: Document Control Desk Washington, D.C. 20555 1
Subject:
Cata'wba Nuclear Station Dockets'50-413 and 50-414 Reply to Notice of Violation Inspection Report 50-413,414/94-30 l
Attached is Duke Power Company's respone to the one (1) Level IV violation cited in Inspection Report 50-413, 414/94-30, dated February 21,1995. This violation was identified during the routine announced inspection in the area of i
engineering and technical support conducted by McKenzie Thomas.
. If there are any questions concerning this response, please contact Kay -
Nicholson at (803) 831-3237.
j Sincere r,
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D. L Rehn
\\ KEN: RESP 94.30 xc:
S. D. Ebr eter, Regional Administrator R. E. Martin, ONRR R. J. Freudenberger, SRI 3290047 950322 Q
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,414/94-30-01 Notice of Violation 10CFR50 Appendix B Criterion XVI, Corrective Actions, as isnplemented by the Duke Pouer Conq>any Topical Quality Assurance Program (Duke 1-A) Aniendonent 16 and 17, requires that nicasures shall be established to assure that conditions adierse to quality are corrected and corrective action taken to preclude repetition.
Contrary to the above, a licensee Temporary Station Modification (TSM) audit dated Novemler 9, to Decemler 21, 1994, demonstrated that the corrective actions for a previously identified condition adverse to quality uvre inadequate to preclude repetition of the adverse condition. On July 19,1994, a Catawba Problein Investigation Process (PIP) report identified an adverse condition of a failure to perform required audit terifications of active TSMs. NRC non-cited violation 50-413, 414/94-17-08 also identified this issue. The corrective actions urre completed and the PIP closed on Novemler 15,1994. A subsequent TSM audit completed on Dexmler 21,1994, failed to include verification of thirty active TSMs, demonstrating a repetition of the adierse This is a Seitrily Level IV Violation (Supplement 1).
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' DUKE POWER COMPANY
' CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION -
413, 414/94-30-01
RESPONSE
1.
Reason for Violation PIP 0-C94-1026 (initiated 7/19/94) addressed the problem of not performing TSM audits due to inadequate communication and transfer of responsibilities resulting from a reorganization of the Catawba Nuclear Station Engineering Division.
PIP 0-C95-0078 (initiated.
1/18/95) addressed the problem of some TSMs not being in the audit program. At the time of closure of PIP 0-C94-1026, in November,1994, it was not recognized that there may not have been compliance with the TSM site directive in regard to ensuring that the requirement of forwarding copies of TSM addendums to Electrical Systems and Equipment Engineering (ESE). Receipt of a TSM addendum is the " flag" ESE needs to include a TSM in the audit program. It was, however recognized that the site directive for TSMs could be enhanced to include a signoff in the ' ISM addendum section of the directive (i.e., working area of the directive) to supplement the requirement that was in the body of the site directive. This was viewed as a " human engineering" change to strengthen our program and was a part of the PIP 0-C94-1026 resolution. This change was approved 11/03/94. A' more thorough resolution for the PIP 0-C94-1026 would have required a cross check of the internally generated ESE database against the Work Management System (WMS) listing of TSM work orders to ensure the ESE TSM audit database was accurate. This was, however, done after closure of PIP 0-C94-1026, as a result of resolving some minor documentation deficiencies during transfer of the audit function between Engineering personnel. This resulted in the generation of PIP 0-C95-0078.
The root cause for not having the 30 TSMs identified in the audit program was failure to follow Site Directive 4.4.5. Copies of the TSM addendums were not forwarded to ESE. The cause for not identifying these as a result of PIP 0-C94-1026 (NCV 413, 414/94-17-08) was inattention to detail. The resolution of PIP 0-C94-1026 did not address-the possibility that the TSM list maintained by ESE was not accurate.
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Corrective Actions Taken and Results Achieved The comparison of the ESE audit database and a special WMS report of TSM work orders resulted in adding approximately thirty (30) new 2
DUKE POWER COMPANY
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CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 413,41V94-30-01 TSMs to the audit function. A recent TSM audit has been performed which includes the newly identified TSMs.
The TSM site directive. has been strengthened by adding a signoff to the TSM addendum to ensure compliance with identification of new TSMs to ESE.
Until the current ESE audit database can be integrated into a WMS special report,' a manual cross-check of the database to a WMS TSM report will be performed on a monthly basis to ensure that all TSMs are accounted for in the audit process.
3.
Corrective Action to be Taken to Avoid Future Violations ESE will ensure TSM audit requirements are communicated to appropriate site groups by 05/01/95. This item is being tracked as corrective action #6 in PIP 0-C95-00078.
The Work Control Group will ensure that all TSMs are appropriately coaed in WMS by 05/01/95. This will further ensure that the manual cross-check of the TSM audit database to WMS provides a complete list of outstanding TSMs. This item is being tracked as corrective action #2 in PIP 0-C95-0078.
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Date of Full Compliance Duke Power Company is now in full compliance.
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