ML20151H875
| ML20151H875 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/08/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804200571 | |
| Download: ML20151H875 (5) | |
Text
/4 4l' DUKE POWER GOMPANY v.o. nox saise citARLorrE. N.O. 98949 HALB. TUCKER' TmLarnown wwm persenewt (704) 073-4531 stuaan emootmon April 8, 1988 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,' D. C. 20555
Subject:
RII/PKV/MSL Catawba Nuclear Station Docket Nos. 50-413 and 50-414 IE Report 50-413,-414/88-08
Dear Sir:
Please find attached a reply to the Notice of Violction for Violation 413,414/88-08-01 and Violation 413,414/88-08-02 as transmitted with the subject Inspection Report.
Very truly yours,
,4 A
pm Hal B.-Tucker LTB/6020/sbn Attachments xc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station-8804200571 000408 DR ADOCK 0500 3
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5 Duke Power Company Reply to Notice of Violation 413, 414/98-08-01 Failure to Follow Prccedures Resulting in Two Inadvertent Safety Injections Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Revision 2.
(1) OP/1/A/6100/01, Controllit d Procedure for Unit Startup, step 2.60 cautions the operator not to exceed 1955 psig reactor coolant system pressure prior to steam generator pressure being greater than or equal to 725 psig as this will cause a safety injection on low steam pressure.
Contrary to the above, on January 23, 1988, reactor coolant system pressure was allowed to exceed 1955 psig prior to steam generator pressure being greater than or equal to 725 psig. This resulted in a safety injection on Unit 1.
(2) Catawba Nuclear Station Directive 3.1.1 Safety Tags and Delineation Tags sections 5.3.5 and 8.4.4 require the person designated to remove a safety tag to receive the completed tag stub from the recalling authority, obtain recall approval from the recall authority, take the stub to the equipment and verify the tag number and stub number agree prior to removing the tag.
Contrary to the above, on February 9, 1988, an equipment operator designated to remove safety tag #410 of tagout number 28-223 on the SSPS Output Relay Mode Selector Switch, removed the tag and repositioned the switch without having received the completed tag stubs and without having obtained recall approval from the recall authority (Assistant Shift Supervisor). This resulted in an inadvertent safety injection on Unit 2.
Response
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation Complete descriptions of the related incidents were reported in Licensee Event Report (LER) 413/88-07 and LER 414/88-03. The Unit 1 incident occurred when a Control Operator (RO) read but did not understand the meaning of the procedure caution. While procedures and training were deemed to be adequate, this is a low frequency evolution which this individual may not have performed previously.
The Unit 2 incident occurred as a result of a mis-communication between an Assistant Shift Supervisor (SRO) and two Non-Licensed Operators (NLO).
In an effort to assure effective performance of and proper sequencing of the tasks leading to placing "A" Train SSPS to OPERATE, the SRO directed the NLO's to first "walk through" the tasks. As a
' Violation 413,41 sd-08-01 Page 2 part of this process the NLO's confirmed that they were in possession of the tag stub associated with the tag placed on the TEST /0PERATE switch.
Prior to actually beginning to; perform the sequence of tasks, however, the SRO specifically instructed on NLO to not operate the TEST /0PERATE switch.
(This information was not transferred to the second NLO.) The SRO then determined to increase his level of assurance that the switch would not be manipulated by retrirving and maintaining possession of the associated tag.
stub. The second NLO, unaware of the directions provided the first NLO, but having previously verified that the first NLO was in possession of the tag stub and believing that his assignment was to remove the tag and place the switch to the OPERATE position, performed these tasks without being in personal possession of the tag stub or the approved R&R ditecting the manipulation of the switch.
(3) Corrective Actions Taken and Results Achieved All individuals involved in these incidents have been counseled regarding j
their performance (none have any previous record of poor performance).
These incidents have been discussed in detail with all Shift Supervisors and reviewed with other shift operations personnel.
(4) Corrective Actions to be Taken to Avoid Further Violations The root cause of these procedure violations is human error. These errors could have been avoided by more effective independent review of individual actions by supervision and others. A management meeting was held on April L
1, 1988, with all Shift Supervisors to emphasis the need for greater l
supervisory involvement in non-routine activities, higher quality l
communications and attention to strict compliance with procedural I
requirements. Effective results in these areas should prevent recurrence.
(5) Date of Full Compliance Duke Power Company is presently in full compliance.
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Duke Power Company Reply to Notice of Violation 413, 414/88-08-02 10 CFR 50, Appendix B, Criterion XCI as implemented by Quality Assurance Program (Duke 1-A, Amendment II) Section 17.2.16 requires that measures be established to assure that the cause of significant conditions adverse to quality be determined and corrective action taken to preclude repetition and items of the same type be evaluated to determine whether or not they can be expected to. continue to function.
Contrary to the above, corrective action measures to preclude repetition of a significant condition adverse to quality were inadequate in that during the implementation of Temporary Station Modification Work Request 5831 IAE and Exempt Change CE-0840, to correct faulty motor mounting hardware for 2ND36B, the licensee failed to properly evaluate applicability of the modification to 2hD-2A.
Being that the modification was not applied to 2ND-2A, this contributed to the motor of 2ND-2A ejecting from the actuator when operated on February 1, 1988.
RESPONSE
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation This violation was due to insufficient familiarity with and adherence to Quality Assurance Program requirements.
Personnel associated with the 2ND36B assessment and corrective action did not take steps to identify additional same-type installations as directed by Section 17.2.16 of the QA Topical Report.
Following the identification of the motor bolt problem on 2ND36B a Station l
Problem Report (SPR) was written to request appropriate corrective action for this and future same-type installations, however, no evaluation of l
existing in plant installations is specifically required during the SPR l
review process. At the time of the modification, a Nonconforming Item (NCI) report would likely have initiated an appropriate evaluation, however, the l
l involved station personnel were not aware of or familiar with NCI reporting requirements. The use of the NCI program as a problem reporting and evaluation mechanism was well known to the Construction and QA departments but had not been formally communicated to appropriate Nuclear Production Department (NPD) personnel. No Construction or QA personnel were involved with the motor bolt problem, therefore the need for an NCI was not identified. This unfamiliarity of the involvad personnel with processes designed to meet QA Program requirements resulted in the stated violation.
(3) Corrective Actions Taken and Results Achieved l
(a) 2ND2A was replaced with a spare actuator not subject to the motor l
installation problem.
(b) Maintenance history was reviewed to identify any additional valve actuators subject to motor installation problem. Two actuators were identified and corrected.
' Violation 413,414/88-08-02 Page 2 (c) Implementation of the Problem Investigation Report (PIR) program in September of 1986 provides specific guidelines for identification and proper evaluation of items requiring corrective action.
(d) CNS Station Directive and specific training of appropriate personnel provided guidelines and identified individual responsibilities associated with the PIR progiam.
(4) Corrective Actions to be Taken to Avoid Further Violations Actions taken in Section 3 above ensure avoidance of further violations.
(5) Date of Full Compliance Duke Power Company is now in full compliance.
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