ML20154L390

Responds to Violations Noted in Insp Repts 50-369/88-20, 50-370/88-20,50-413/88-29 & 50-414/88-29.Corrective Actions: Operations Personnel Implemented Change to Procedures in Steam Generator Cold Wet Layup Recirculation

ML20154L390
Person / Time
Site:	Mcguire, Catawba, McGuire, 05000000
Issue date:	09/16/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8809260167
Download: ML20154L390 (9)

Text

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Me Mwr Company Itu a r.sa

- PO Ben MiM isce in sihnt l Charlour. N C 28:42 Nu av rmdu. twn l (104)3 3 4111 7 DUKEPOWER September 16, 1988 I

L U.S. Nuclear Regulatory Commission  !

Document Control Desk }

k'ashington, DC 20555 [

f Subjeet: 14coutre Nuclear Statten I Doctret Nos. 50-369 -370 Catawba Nuclear Station Docket Nos. 50-413 -414  ;

Reply to a Notice of Violation  !

Gentlement I i

Pursuant to 10CTR2.201, please find attached Duke Power Company's response to [

violations 370/88-20-01 and 369, 370/88-20-02 for the McGuire Nuclear Station I (attachment no. 1), and violation 413, 414/08-29-01 for the Catawba Nuclear i Stetton (attachment no. 2).

Should there be any questions concerning this matter, contact S.E. LeRoy at -

(704) 373-6233. I t

Very truly yours, l j Nel B. Tucier SEL/328/==f l t

Attachment act Dr. J. Nelson Crace Dr. K.N. Jabbour Regional Administrator, Region II U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 101 Marietta St., NW, suite 2900 Office of Nuclear Regulatory Atlanta, CA 30323 Regulations  ;

Washington, DC 20555 {

Nr. Darl Nood U.S. Nuclear Regulatory Consission Mr. V.T. Orders Of fice of Nuclear Reactor Regulation NRC Resident Inspector l Washington, DC 20555 Catawba Nuclear Station I

Nr. P.K. Van Doorn NRC Resident Inspector McGuire Nuclear Station

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1. 4 Document Control Desk September 16. 1988 Page 2 bxc P.M. Abraham A.V. Carr R.M. Dulin R.M. Clover C.W. Craves W.A. Haller C.W. Hallman C.L. Harlin V.D. King P.C. LeRoy M.D. McIntosh i T.B. Owen R.P. Puth R.O. Sharpe 1 J.E. Thomas J.C. Torre R.L. White FA Tech Services NRC Coordinator (EC-12/55)  ;

o.S. Kilborn W~

R.L. Gill S.A. Cevehr P.B. Nr.rdoci MC 815.01 CN 815.01 (26)

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i ATTACHMENT NO. 1 Duke Power Company McGuire Nuclear 3tation Reply to Notice of Violation Inspection Report 50-369, 370/88-20

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Violation 370/88-20-01 A. Technical Specification 6.8.1 requires that written rocedures be

, established, implemented, and asintained covering th ictivities  ;

, recommended in Appendix A of Regulatory Guide 1.33 Rg tsion 2,  !

yebruary 1988.  !

l t Regulatory cuide 1.33, Revision 2, February 1978. Appendix A. requires that procedures be written, implemented, and raintained for energining, filling, draining, startup, shutdown, and changing modes of operstion of l safety related systems. ,

McGuire procedure OP/2/A/6350/05, AC Electrical Operation Other than l Normal Lineup, specifies the nethod to be used to allu 6900 volt i i switch gear assemblies to their alternate power supp. . ,.

.: l McGuire procedure OP/2/A/6250/03A Steam Cenerator Cold Wet Layup l i Recirculation, specifies the method to be used to drain and refill steam i generators, i McGuire Operations Management Procedure 2-17. Tagout/ Removal and i j

Restoration (R&R) Procedure, states in part that the purpose of a  !

Tagout (R&R) Record Sheet is to allow the removal and restoration of l equipment to be accomplished in a specific manner by directing the  !

sequence of the steps involved in repositioning the equipment and ,

j indicating the desired removal and return position, j Tagout R&R Number 28-616. Tagout for Busline 25. specified the method to  :

1 be used to realign the off-site electric power supply to t* nit 2 to allov ,

j amintenance on busline 28 [

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! Exaerle No. 1 I  !

5 Contrary to the above, procedure OP/2/A/6250/03A, Steam Generator Cold l Vet Lay up Recirmlation, was inadequate in that performance of the .

procedure caused an Engireered Safety Teatures actuation, n e procedure i j failed to bicek the auto start signal to the turbine driven auxiliary  ;

i feedvater pump on low-low level in twa steam generators, p Reply to Example No. 1 t

4 1. Admission or denial of violation ,

i ne violation is admitted as stated.

2. Reason for the violation if adeitted:

) i j The IAE Technician involved risinterpreted plant data. }

Also, the Operating Procedure for draining the steam generators, p

O .

Attachment No. 1 Page 2 Steam Generator Cold Wet Layup Recirculetion (OP/2/A/6250/03A), did not include steps to defeat the Steam Generator Low Low Lovel setpoint ESF actuation, even though this action is neces?ary and performed every time prior to draiaing the Steam Generators.

3. Corrective steps which have been taken and results achieved:

Operations personnel implemented a change to procedures OP/1&2/A/6250/03A, Steam Generator Cold Wet Layup Recirculation, which now include steps for IAE personnel to defeat the Otrer Cenerator few Low Level ESF actuation prior to draining a steam generator. Also, procedures OP/1&2/A/6100/01, Cont' tolling Procedure for Unit Startup, were revised to include steps to verify the Steam Generator Low Low Level ESF Actuation is reinstated prior to entering Mode 4 (Hot Shutdown).

4. Corrective eteps planned to avoid further violations:

t' Procedures OP/1&2/A/6250/03A, Steam Generato- Cold Wet Layup Recircu!.ation, will be revised to clarify the ,' ap to defeat all Feedwater Isolation signals. The clarific.cion will specify which Feedwater Isolation signals are to be defeated.

5. Date when full compliance will be achieved:

October 1, 1988 Example No.2 Contrary to the above, proced.re OP/2/A/6350/03, AC Electrical

, Operation Other Than Normal Laneup, wr.a not properly implemented in that an incorrect electrical lineup of the Unit 2 6900 volt switch gear assemblies was made on June 24, 1988 which resulted in a loss of s,11 ,

Unit 2 off site power. In preparation for maintenance on the 2B off-site busline, a reactor operator incorrectly aligned all four 6900 volt switch gear assembifes to the 2B off-site busline instead of the 7A off-site busline as intended by the procedure. When the 2b cusline was subsequently 'temoved from service, a loss of all off site power occurre), .aasinc an Engineered Safety Feature actuation.

Reply to Example No. 2: l

. 1. Admission or denial of violation:

The violation is admitted as stated. ,

2. Reason for the violstien if admitted:

The Operations personnel involved mistakenly powered all four 6900 V. switchgear assemblies from 2B busline prior to de-energizing 2B busline for work. The action taken by the individual involved was inadvertently directed toward the s cong goal because he performed the opposite action than he L had intended to perform. The individual is an experienced operator who was fully qualified to perform this task.

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. Attachment No. 1 Page 3

3. Corrective steps which have been taken and results achieved:

a. Normal off-cite power was restored to Unit 2 by 1037 on June 24, 1988.

b. Operations management personnel have reviewed this incident with a representative from each shift.

c. Operations reviewed Procedure OP/2/A6350/05 for possible enhancement, and determined that with the number of possible variations of alignment, a revision would not be practical and probably would not have  !

pre 'nted this incident from occurring.

4. Corrective steps planned to avoid further violationst, No additional steps are required.

5. The date when full compliance will be achieved:

McGuire is in full compliance at this time.

Example No. 3 ,

Contrary to the above, Removal and Restoration (R&R) procedure 26-616, Tagout for busline 2B, was inadequate in that it did not direct the sequence of steps required to operate the 2B busline Primary Circuit Breakers when the 2B off-site busline was removed from service on June 24, 1968.

There 3 examples constituta e severity level IV (Supplerent I) violation and apply to Unit 2.

j Reply to Example No. 3:

1. Admission or denial of violations i The violation is admitted as 6tated.

2. Reason for the violation _1f _admittedt l

Operations staff personnel felt that the generic procedure along with the verbal instructions given with the R&R were sufficient to l accomplish the desired alignment; however, thic was not the case.

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3. Corrective steps which have been taken and results achieved

a. Normal off-site power was restored to Unit 2 by 1037 on June 24, 1988.

b. Operations management personnel have reviewed this incident with a representative from each shift.

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. Attachment No. 1 '

Page 4

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4. Corrective steps planned to avoid further violations:

A meno.will be written and sent to all Operators emphasizing that the R&R is to allow the removal and restoration of equipment in a specific manner by directing the sequence of the steps involved in repositioning the equipment and indicating the desired removal and return position.

5. Date when full compliance will be achieved l September 30, 1988 i

Violation 369,370/88-20-02 ,

B. Technical Specification 6.2.3.3 requires the Station Safety Review Group maintain surveillance of plant ectivities to provide

independent verffication that these activities are performed correctly and that human errors are reduced as much as possible.

Contrary to the above, a review of McGuire Safety Review Group (MSRG) activicies covering the period of 198t through June 1988

1. revealed that the MSRG did not perform routine independent surveillance of plant operations a* i maintenance activities to [

provide independent verification that these activities were performed correctly. '

This is a severity level IV (Supplement 1) violation ard applies tu both units.

Reply:

1. Admission or denial of "fo1Ations  ;

The violatica le admitted in that an insufficier.t nuraer of independent i in-plant reviews /suricillances were perfcised during the perica stated to j adequately meet the tatsnt cf IkGuire Technical Specification requirteent  ;

6.2.3.3. However, Duho believed that the requirements were being met i through the combAned pertermance of in-plant reviews /gurveillances ard ,

unusual event investigations.

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2. Reason for the violdtfon if admitted:

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Duke believed that the requirements were being met through the  !

j combined performance of in-plant reviews /surveillances and unusual event investigations.

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l 3. Corrective steps which have been taken and results achieved

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, a. Management has increased the emphasis and the percentage of MSRG I time for proactively conducting in-plant reviews.

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b. Management has emphasized to the MSRG to document the

! conduct of surveillance / programmatic type activities when performed in conjunction witn incident investigations, where deemed

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1 appropriate.

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Attachment No. 1 Page 5

4. Corrective steps planned to avoid further violations:

a. Proposed McGuire Technical Specification changes will be submitted to the NRC for approval that will clarify the MSRG functions, responsibilities, and authority.

b. The SRG Charter will be revised accordingly to be consistent with the proposed Technical Specification wording and issued upon NRC approval of the proposed Technical Specification revision.

c. Time and resources will be more equitably allocated in the MSRG and to carry out the functions ani responsibilities specified in the proposed Technical Specification change and will be periodically monitored.

5. Date when full compliance will be achieved:

a. The Technical Specification Revision will be submitted upon final review and approval of McGuire management and Duke's Nuclear  ;

Safety Review Board. '

b. Upon approval of the proposed Technical Specification revision.

c. McGuire is in full compliance at this time.

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, ATTACHMENT NO. 2 DUKE POWER COMPANY CATAWBA NUCLEAR STATION -

Reply to Notice of Violation Inspection Report 50-413, 414/88-29 Violation 413, 414/88-29-01

• Catawba Technical Specification 6.2.3.1 states that the Catawba Safety Review Group (CSRG) shall function to examine plant operating characteristics, NRC issuances, industry advisories, reportable events, and other sources whfeh may indicate areas for improving plant safety and shall make detaffed rccommendations fer revised procedures, equipment modifications, or other means of improving plant safety to the director, 1

Nuclear Safety Review Board, Contrary to the above, no objective evidence exists that the CSRG reviews NRC issuances, industry advisories, or other sources which may indicate areas for improving plant safety in order to make detailed 4 recommendations for revised procedures, equipment modifications, or other '

meses of improving plant safety.

Tnis is a Severity Level V violation (Supplement I).

Reply

1. Admission or , denial of violation:

. The violation is admitted in that an insufficient number of independent in-plant reviews /surveillances were performed durir.g the period stated to ,

adequately meet the intent of Catawba Technical Specification requirement 6.2.3.1. However, Duke believed that the requirements were being ret i throust the combined performance of in-plant reviews /surveillances and i unusual avant investigations.

2. Reason for the violation if admitte,d1 Duke believed that the requirements were being met through the combined 7 i performsoce of in-plant reviews /surveillances and unususi event reports. '

3. Corrective steps which have been taken and results achieved  !

, a. Management has increased the emphasis and the percentage cf '

CSRG time for proactively conducting in-plant reviews.

b. Management has emphasized to the CSRG to docum' int the conduct of surveillance / programmatic type activities when performed in conjunction with incident investigations, where deemed appropriate.

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Attachment No. 2 l Page 2 l 4 Corrective steps planned to avoid further violations:

a. Proposed Catawba Technical Specification changes will be submitted to the NRC for approval that will clarify the CSRG functions, responsibilities, and authority.

b. The SRG charter will be revised accordingly to be consistent with the proposed Technical Specification wording and issued upon NRC approval of the proposed Technical Specification revision.

c. Time and resources will be more equitably allocated in the CTAG to carry out the functions and responsibilities specified in the proposed Technical Specification changes and will be perio/ically monitored.

5. Date when full compliance will be achieved:

a. The Technical Specification Revision will be submitted apon final review and approval of Catawba Management and Duke's Nuclear Safety Rsview Board.

b. Upon approval of the proposed Technical Soecification revision.

c. Catawba is in full compliance at this time.

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