ML20113F441
| ML20113F441 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/17/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8501240021 | |
| Download: ML20113F441 (3) | |
Text
y DUKE POWER GOMPANY P.O. HOK 33180 CHARLOTTE, N.C. 28242 HAL B. TUCKER TE_EPHONE (704) 373-4331 wwa emessonst January 17, 1985
= = = = - -
Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
~Re: RII:PKV/PHS 413/84-95
Dear Mr.'0'Reilly:
Please find a'ttached a. response to Violation No. 413/84-95-01 as identified in the above referenced < inspection report. Duke Power Company does not consider any information contained in this inspection report to be proprietary.
Very truly yours,-
kb. Y jg
.Hal B. Tucker LTP/mjf-Attachment ec: h1C Resident Inspector Catawba Nuclear Station Robert Guild, Esq.
P.'O. Box 12097 Charleston, South Carolina 29412 Palmetto Alliance 2135 Devine Street Columbia, South Carolina 29412 Mr. Jesse L.~ Riley Carolina Environmental Study Group 854.Henley Place Charlotte, North Carolina 28207
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION Violation 413/84-95-01:
10 CFR 50, Appendix B, Criterion XI as implemented by Duke Power Company
. (DPC), Topical Report, Duke-1-A, Section 17, paragraph 17.2.11, requires
.that a test program shall be established to assure that.all testing required
' is identified and. performed in accordance with written test procedures which incorporar,e the requirements and acceptance limits. Also, this criterion 1
requires that test results shall be documented and evaluated ~to assure that
' test requirements have.been satisfied.
l Contrary;to.the above, a test program has not been established to assure
.that all testing required to demonstrate that the systems and components
- perform satisfactorily. Test procedures were not used and the test results
- were improperly documented and evaluated in the instances cited below.
1
- 1.. Testing was performed on a modification te_the Unit 1 diesel generator turbocharger without using a test procedure (a work request was used Lin~ lieu of:a test procedure) and, consequently, the results obtained-were not properly documented and evaluated to assure that requirements
, had been satisfied.-
---2.
A modification was performed in the Nuclear Instrumentation System to rinstall a redundant boron dilution alarm in the control room.- Procedures to assure that the system would perform satisfactorily in service were not accomplished prior to classifying this system as operable.
These examples are'not intended to be all inclusive.
IResponse:-
1.
Duke Power admits, that'in the example cited as instance-1 in the violation.
testing was. performed' to verify the adequacy, of a' modification to.the Unit 1 7
diesel / generator turbochargers without using a. test procedure.. -However, Duke Power does not agree that the boron dilution alarm as discussed in Section 11 of'repo'rt'413/84-95, is'an. example of a-failure 1to implement.
.the requirements of 10CFR50, Appendix B,' Criterion XI.
' l
.In the Introduction to Appendix B of 10'CFRL50 it is stated:
2 "Every applicant'for an operating license is~ required to-include, in-its
~ final safety analysis report, information pertaining' to the managerial and administrative controis-to be used to assure safe operation. Nuclear
- power. plants'and fuel reprocessing plants include structures, systems-and components.that prevent or mitigate the consequences of postulated accidents'that.could cause. undue risk to the. health and safety of the'
.public."
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o 413/84-95-01 page Therefore "important to safety" and " safety related" (as it is used in
- Appendix B) are synonymous and are interpreted to apply to those systems, structures and components that are needed to mitigate the consequences of an accident that could cause undue risk to the health cnd safety of the public.
The boron dilution alarm, installed and cited as instance 2 in the Notice of Violation does not serve as a component that mitigates the consequences of an accident.
It is therefore "non-safety related" and does not fall under; Duke Power's Quality Assurance Program required by Appendix B.
.As_you know,-there is a current controversy surrounding the definition of "Important to Safety'.' as to whether there exists some classification beyond
" Safety Related". Even if one were to recogn'ize that this additional classification exists, Commission statements to date do not indicate that
-a licensee would have to have an NRC-approved quality assurance program to govern this equipment.
Indeed it.has been stated that it would be expected
- that. normal licensee administrative controls would provide sufficient quality controls for this type of equipment. This particular modification was designed
- and installed-under guidance existing in Duke Power Company's " Administrative Policy Manual for Nuclear Stations", and it is Duke's position that sufficient Lquality assurance controls were applied to ensure that the equipment was L
operable prior'to service.
2.1 The violation occured because a formal test procedure was not written to ensure proper functioning'of the unit one. diesel generator turbocharger's lubrication system'after a modification to ensure adequate, but not excessive, lubrication was performed.- The post-modification testing was documented on a Nuclear Station Work Request.
13.
The re'sults of the above tests have been properly documented, evaluated and approved. ;These results showed that the turbocharger's lubrication system was modified correctly-to prevent. recurrence of_the problem identified in
' Significant Deficiency' Report 413-414/84-05. Also, all Nuclear Station
-Modifications implemented as.of October 25, 1984 on safety-related equipment were reviewed'and'any retests'that were necessary were implemented.- Concurrectly with this review,.all accountable engineers'for~ station modifications were instructed on;their responsibilities concerning retest requirements after a modification has:been completed.
'4.'. Maintenance Management Procedure (MMP) 1.0 has been revised to more clearly identify that the, accountable engineer for a modification is' responsible jforJensuring that. functional verification and retests are identified clearly.
- Station Directive 4;4.4 (Processing Nuclear Station < M difications) will also o
-be' revised to indicate'that the accountable engineer for a modification is
' responsible for ensuring that_ retests for operability, after a modification is'
' complete, are properly documented.~ 1 Those two directive. changes should preclude further: violations.
5.
Maintenance, Management. Procedure 1.0 has been revised.
Station Directive 4.4.4 will be'revis4d before March-1, 1985. Catawba Nuclear Station will. be in compliance;at this time.
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