ML20086H640
| ML20086H640 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/02/1991 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9112090267 | |
| Download: ML20086H640 (3) | |
Text
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G DUKEPOWER i
December 2, 1991
-U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report No. 50-413,414/91-21 Reply to Notice of Violation Enclosed is the response to the Notice of Violation issued October 31, 1991 concerning failure to follow procedures or inadequate procedu*as.
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Tuckman, Vice President Catawba _ Nuclear Generation Department CRL/RES91-21 Attachment xc:
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Ebneter Regional Administrator, Region II a
W. T. Orders Senior Resident Inspector R.
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DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/91-21-02 Technical Specification (TS) 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2,
Febr uary 1978.
Implicit in this requirement is the stipulation that the procedures be adequate for the tasks being performed.
Procedure OP/2/A/6100/09A, Unit 2 Annunciator Response For 2A D/G Panel, requires in part that the operator immediately reduce engine load upon the receipt of a high jacket water inlet temperature and/or 1.igh lube oil outlet temperature alarm.
Nuclear Production Department (NPD)
Directive 3.1.1, Independent Verification Requirements, Catawba Nuclear Station (CNS) Directive 4.2.2, Independent Verification Requirements, N42 Analog Channel and IP/1/A/3240/04I, Power Range Operational Tect, each require that, before an action is performed that involves independent verification, both individuals will verify that component on which the action is to be taken is correct.
Contrary to the above:
1.
On September 28, 1991, during the process of returning Train A of the Unit 1 Component Cooling Water (KC) System to service following maintenance, Procedure OP/1/A/6400/05, Component Cooling System, was found to be inadequate in that the procedure failed to ensure that required post modification testing of crossover valves in the system was performed prior to realigning the system for service.
This resulted in rendering Unit 1 KC Train B
inoperable, causing the Unit to enter the action requirements of TS 3.0.3 for two inoperable KC trains.
2.
On September 11,
- 1991, operators failed to follow immediate operator actions specified in Procedure OP/2/A/6100/09A, Unit 2 Annunciator Response For 2A D/G Panel, which requires that engine load be reduced upon the receipt of high jacket water inlet or high lube oil outlet temperature alarms.
During the performance of a diesel generator 2A operability performance test, valid high jacket water inlet temperature and high lube oil outlet temperature alarms we.re received and engine load was not reduced.
Failing to reduce engine load resulted in or contributed to significant engine damage due to overheating.
t DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/91-21-02 3.
On September 11,
- 1991, Instrumentation and Electrical (IAE) technicians failed to follow NPD Directive 3.1.1, CNS Directive 4.2.2, and Procedure IP/1/A/3240/04I.
During the return of the Power Range N-42 Channel to service following maintenance, the technicians failed to properly independently verify the required manipulation of the Rod Stop switch associated with N-42 and inadvertently manipulated the N-41 Rod Stop switch.
This is a Severity Level IV Violation (Supplement 1).
RESPOES_E:
1.
Reason for Violation:
1.
In Enclosure 4.8 of OP/1/A/6400/05, Step 2.17 used the term " reissue model work order".
The procedure did not explicitly state that the reissued model work request had to be complete before proceeding further.
This lead the operator to continue on in the procedure before the required testing was completed.
2.
Non-licensed operators (NLos) had inadequate time to complete all response actions due to the rapid transient, multiple alarms and the need to prioritize and select proper response action.
3.
Improper execution of NPD Directive 3.1.1, CNS Directive 4.2.2, and IP/1/A/3240/04I.
While one IAE technician (A) was restoring N-42 to service, the other IAE technician (B) was observing.
When Technician A came to the last switch (Rod Stop Bypass), he got the wrong awitch (N-41 Rod Stop Bypass), Technician B did not recognized the mistake.
Neither Technician A or Technician B communicated properly with each other during this process.
2.
Corrective Actions Taken and Resulls_ Achieved:
1.
Unit One was placed in TS 3.0.3 and the required testing was begun.
The required testing was then completed and Unit One exited TS 2.0.3.
2.
The D/G engine was taken out of service and repaired under the station maintenance program.
Annunciator response procedures were enhanced such that unloading and/or tripping the D/G were given a higher priority in response to D/G engine overheating.
o DUKE POWER COMPANY REPLY TO NOTICE OF VIOLATION 413, 414/91-21-02 3.
Both IAE Technician A and B have been retrained on NPD Directive 3.1.1 and CNS Directive 4.2.2, concerning proper execution of independent verification.
The IAE Department has formed a committee to investigate and recommend actions to improve the way Duke Power performs independent verifications. This committee consists of all levels of management within IAE, most importantly however, technicians themselves are involved in this process.
Also, the Nuclear Generation Department (NGD) Human Performance Excellence Team (HPET) has investigated potential problems concerning labelling and location of switches.
The findings will be reviewed and l
evaluated by Engineering and IAE.
'3.
Corrective Actions to be Taken to Avoid Further Violations:
1.
The wording of OP/1/A/6400/05 will be enhanced to ensure clarity of intent.
The wording enhancement will be used in all affected enclosures.
These changes will be made by August 1, 1992.
2.
The NLOs will be given training on how to recognize and prioritize alarm response on D/G local alarm panels.
This training will be completed by December 1,
1992.
3.
None required beyond those steps already taken and described in the Corrective Actions Taken.
-4.
Date of Full Compliance:
1.
Duke Power is now in full compliance.
2.
Duke Power is now in full compliance.
3.
Dur.e Power is now in full compliance.
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