ML20082L535
| ML20082L535 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/29/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109040173 | |
| Download: ML20082L535 (6) | |
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DUKEPOWER August 29,1991 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 i
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413, 414 NRC Inspection Report Nos. 50-413, 414/91-15 Reply to a Notice of Violation Enclosed is the response to the Notice of Violation issued July 30,1991 by Alan R.
h Herdt concerning failure to follow procedures, failure to perform a 50.59 review and failure to abide by Tech Spec requirements for NSRB member qualifications.
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Very truly yours, f/)
>ta bl. S. Tuckman i
Attachment xc: hir. S. D. Ebneter Regional Administrator, Region II hir. W. T. Orders Senior Resident inspector hir R. E. Afartin, ONRR 0 2 9109610173 910s29 x 60
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DUKE POWER COMPANY y;.h ;.
"J REPLY TO NOTICE OF YlOLATION
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413/91-15-01
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echnical Specification 6.8.1 requires in part that written pracedures be established, g,
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Q ir,emented and maintained covering the activitics referenced in Appendix A of Regulatory
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aid: 133, Rev' en 2,1:ebruary 1978, including Operations Management Procedure (OMP) 8, Authority an. kesponsibility of Licensed Reactor Operators anc Licensed Senior Reactor 4.?l..
4 [,.g Operators, Section 7.2.B, describes the responsibilities of the Operator At The Contrels JJ (OATC). Step 7.2.B.8 of the procedure requirci t:2at the OATC discuss and receive direct C ',,
confirmation and approvai num the Control Room Supervisor prior to tasks that may affe.t the
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operability of safety related systems or the configuration of any system vehich has significant M
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effect on plant operation. Step 7.2.B.9.c of the pwcedure requires that the OATC verify that the appropriate automatie actions for an klarm have taken place.
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- . pn My Contrary to the above, at approximately 3:22 a.m., on June 4,1991, when Trah
- V of the Unit 1 Boron Dilution Mitigation System (BDMS) alarmed causing the suction race the
,5 operating 1 A Centrifugal Charging Pump to swap from the Volume Control Tank r j.o the Refueling Water Storage Tank (FWST), the OATC closed the swtion valve from t.
r WST but failed to reorm the suction valve from the VCT. The OATC did not refer to tt e.anunciator response ph ure to verify that the automatic actions for the BDMS alarm Pad taken place, fue OATC did not discuss his actions with the Control Room Supeivisor.
This is a Severity Level IV Violation (Supplement D and ap;) lies to Unit 1 only.
BESPONSE:
1.
Ilungs for Violation:
The OATC responded incorrectly to a spurious Train " A" BDMS alarm by closing the suction valve froin the I;WST prior to re-opening the suction valve from the VCT. The operator did not refer to ti e annunciator re,ranse procedure or discuss his actions with the Control Nom Supervisor as required by OMP l-8.
2.
CorrectireAtiens Taken and Results Achievtd:
Tne correct procedure on responding to an unexpectcd alarm has been re-emphasized to the Control Room Operator involved in this incident.
The correct procedure for responding to an unexpected alarm has been reinforced tc, all licensed operators through the issuance,f an operator update on this inciden:
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t DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413/91-15f?1 3.
Corrective Attlans to be Taken to Avoid Further Viola 11mn:
This incident will be covered during operator requalification training including the automatic actions which occur on a BDMS alarm Modifications to the 13DMS will iie perform:d to eliminate excessive spurious alarms t,y April 1,1992, 4.
Date of Full Compliance:
f Duke Powei < aow in full compliance.
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DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/91-15-02 i
f 10 CFR 50.59 states that a licensee may make changes in the facility as described in the safety r
analysis.eport without Commission approval unless the change involves an unreviewed safety
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question. Implicit in that requirement is the requisite that a review be performed to determine l
th existence of an unreviewed safety question.
j Contrary to the above, on and before June 12, 1991, the control room ventilation system was operated in a modified design configuration, in that, selected inoperable automatic system dampers were operated manually to support system function without a 50.59 evaluation to dete:.niae the existence of an unreviewed safety question.
This is a Severity Level IV Violation (Supplement 1).
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RESPONSE
i 1.
Renson for Violation:
The station failed to recognize that tying the "entilation dampers in a specific position defeated the automatic function described in the FSAR. Therefore, no 50.59 was filled out.
2.
Corrective Actions Tnken and Recults Achiend:
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l A formal evaluation has been performed for the control room ventilation system manual l
operations. This information is being used to develop an operations procedure which will manipulate the system.
3.
Corrective AItion.s to I e Tnken to Avoid Fmfbc Violations:
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Procedural guidance will be placed in UP/0/A/6450/11 (Control Room Area / Chill Water Ventilation System) to allow for manual operation of the Control Room i
Ventilation System. T5 guidance will be supported by a 50.59 evaluation. The procedt:a change will be completed by November 30,1991 b.
A letter will be sent to the appropriate station and design personnel, indicating the need for a closer look into systems described in the FSAR to ensure that no i
modifications are being made to processes described in the FSAR without completing a 50.59 evaluation. This corrective action will be completed by l
December 1,1991.
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DUKE 1 OWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/91-15-02 4.
Date of Full Compliancr:
Duke Power is now in full compliance.
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DUKE POWER COMPANY REPLV TO NOTICE OF VIOLATION 413, 414/91-15-04 Technical Specification 6.5.2.2 requires in part that the Director, members and alternate members of the Nuclear Safety Review Board (NSRB) shall be appointed in writing by the Vice President, Nuclear Production and shall have an academic degree in an engineering or physical science field.
Contrary to the above, on October 3,1990, the license appointed an individual to membership of the NSR3 wh. Joes not possess an academic degr e in an engineering or physical science
- field, RESPONSE :
1.
Renson for Violation:
Prior to the appointment of the subject individual to full membership on the NSRB, he had a two year Associate degree in mechanical engineering technology, held an SRO license and had recently received his professional engineering license. M 1nagement failed to review the requirements of Technical Specification 6.5.2.2 and inadvertently assumed that receipt of his professional engineering license, combined with his other credentials, adequately satisfied these requirements. Accordingly, he was appointed and upgraded to full membership status on the NSRB.
2.
Corrective /.ctions Tnken atti Results Achimd:
Section 4.4.2 cf the Charter of the Nuclear Safety Review Board has been revised to prohibit the appointment of individuals to full board membership when they do not possess a bachelor's or advanced degre.:. The subject individual has been reappointed to the NSRB as an Associate Member, a non-voting member allowed by the NSRB Charter and consistent with the requirements of current technical specifications.
3.
Corrective Actions to be Taen to Avoid Further Violations:
No aiditional corrective actions are planned.
4.
112te of Full Compliance:
The corrective actions described in Item 2 were completed on August 15,1991. Duke Power is now in full compliance.
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