ML20097J899
| ML20097J899 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/23/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20097J892 | List: |
| References | |
| NUDOCS 8409240101 | |
| Download: ML20097J899 (3) | |
Text
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DUKE POWER GOMPANY P.O.1,0X 33180 CIIAMLOTTE, N.C. 28242 HALB.TUGKER TE LEPHONE vma,esasomwr UM) DWM May 23, 1984 3tl gy gg p l,
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Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 Re:
RII: GAB /LEF/CFS 50-413/84-18 50-414/84M/a
Dear Mr. O'Reilly:
Please find attached responses to Violations No. 413/84-18-04 and 413/84-18-05 as identified in the above referenced inspection report.
Please note that the corrective action for Violation No. 413/84-18-05 extends to Unit 2 as well.
We feel that the proper development of responses to Violations No. 413/84-18-01 413/84-18-02, and 413/84-18-03 require a review of our preventive maintenance and materials procedures. Therefore, the responses to these violations will be delayed until June 10, 1984. Duke Power Company does not consider any information contained in this inspection report to be proprietary.
Very truly yours, k
sg Hal B. Tucker LTP/php Attachment cc: NRC Resident Inspector Catawba Nuclear Station
'Mr. Robert Guild, tsq.
Attorney-at-Law P. O. Box 12097 Charleston, South Carolina 29412 Palmetto Alliance 21351 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley CarolinaEnvironmentalStudyGroupf 854 Henley Place Charlotte, North Carolina 28207 8409240101 840831 PDR ADOCK 05000413 0
t 1.
Response to Violation 413/84-18-04 Part (A)
Quality Assurance Procedure PR-202 is the controlling procedure for QA Condition and, optionally, non-QA Condition Design Nonconformance Reports (DNC's).
The QA Condition suction source for the auxillary feedwater pumps is the Nuclear Service Water System, and the Condenser Hotwell is the non-QA Condition source.
Other non-QA Condition sources include the Upper Surge Tanks and the Auxillary Feedd ster Condensate Storage Tank.
Although non-seismic, these sources of condensate quality water are " preferred" suction sources in order to maintain st um gener-ator water chemistry.
The automatic detection and transfer controls will detect and transfer the pump suctions to nuclear ser vice water upon detection of any of the following postulated failures of the non-seismic condensate supplies:
1.
Depletion of all condensate sources 2.
Loss of source due to pipe break 3.
Partial or complete loss of source due to air leakage into the system from a pipe crack, or failure to isolate a depleted source.
4.
Partial loss of source due to steam void formation in the suction piping caused by excessive friction loss associated with a high flow rate, failure of a valve causing partial closure, or bending or partial obstruction in the pipe.
An NSM was originated.to correct a design deficiency in the non-QA Condition source for the Auxillary FWP's.
A DNC was not written for this deficiency because it is non-QA and therefore optional, in ac-cordance with PR-202.
Quality Assurance Procedure PR-160 is the controlling document for the preparation of QA Condition and, optionally, Non-QA Condition NSM's.
Paragraph 1.2, Origination of NSM within Design Engineering, states that NSMs initiated to correct a design deficiency should be accompanied by a DNC (ref: PR-202).
This statement only suggests that the DNC Report, Form 202.1, be attached to the NSM package for reference.
Nonapplication of PR-202 to QA Condition Design Nonconformances is not permitted by PR-160.
Part (B)
Nuclear Production documents and evaluates all discrepancies associated with pre-operational tests.
If the discrepancy is design related, Design Engineering is notified to evaluate the discrepancy to determine:
- 1) Need for a design change (e.g., NSM)
- 2) Need for revision to test acceptance criteria
(
~'.
- 3) Need for a Design Nonconformance (DNC) as required by PR-202.
If not design related, Nuclear Production evaluates the needed repairs for significance in accordance with station procedures.
In either case, an evaluation for potential reportability is performed in accordance with the controlling procedures.
As stated in Part (A), the NSM was initiated to correct a design deficiency in the non-QA Condition suction source for the AFWP's, and a DNC was not required according to PR-202.
2.
Response to Violation 413/84-18-05 A.
Duke Power Company admits the violation.
B.
Cause of Violation Variation Notice 41747 was prepared and approved in accordance with the controlling QA Procedures, PR-201 and R-3.
The flow dia-grams (CN 2592-1.0 and CN 2592-1.1) were subsequently revised and issued to clear the VN.
At this time, Design Engineering was con-tacted for approval to void VN 41747.
Approval was denied due to the previous transmittal of flow diagrams.
Approval was given to issue VN 42085 which revised the valve cross reference information and incorrectly stated to supersede VN 41747.
Since flow diagrams were revised per VN 41747, no additional changes were required to the flow diagram for VN 42085.
Consequently, Construction voided VN 41747 and removed the cleared copy (from Design Engineering) from the record file.
This action resulted in the flow diagram referencing a voided VN.
Quality Assurance Procedures PR-201 and R-3 are the controlling procedures for Variation Notices (VN's) and do not allow voiding or superseding a VN if the revised drawing has been transmitted.
If the drawing cannot be recalled, approval should be denied and a new VN must be written against released Design documents. This violation was due to personnel error in not properly implementing the controlling QA procedures.
C.
Corrective Action Flow diagrams CN 2592-1.0 and CN 2592-1.1, although technically correct, will be revised to reference VN 42085 for clarification.
People involved have been reinstructed.
D.
Corrective Action to Avoid Further Violations Quality Assurance Procedures PR-201 and R-3 will be revised to add clarification in the processing of voided VNs.
E.
Status Flow diagrams will be revised by June 15, 1984.
Full compliance by August 1, 1984.