ML20196K030
| ML20196K030 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/03/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8803150140 | |
| Download: ML20196K030 (4) | |
Text
Duxe Powen COMPANY l'.O. ISOX 33180 CitAHLOTrE, N.C. 28242 IIAL 11. TUCKER TELEPHONE (704) 37& 4531 twa raremari nuu.
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March 3, 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.-414/87 44
Dear Sir:
Fiesse find attached a response to the Violations 413,414/87-44-01 and 414/87-44-03 which were identified in the subject Inspection Report.
Very truly yours, j so -
tzM fx w
llal B. Tucker LTB/1471/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 I
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8803150140 880303 PDR ADOCK 0500041:3 o
LTB/1476/sbn DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 414/87-44-03 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..13 of procedure OP/1/A/6350/02, Diesel Generator Operations, requires that if Diesel Generator 1B is removed from service, the operator is to transfer the power supply for "B" train Control Room Area Ventilation System (VC/YC) to Unit 2 "B" train emergency bus 2ETB or declare "B" train VC/YC inoperable.
Contrary to the above, on December 1, 1987 with Diesel Generator 1B removed from service, the licensee failed to transfer the power supply for "B" train to emergency bus 2ETB or declare "B" t.cain VC/YC inoperable. Since "A" train VC/YC was inoperable, this resulted in both trains oi VC/YC without an operable source of emergency power for approximately five (5) hours, with Unit 2 in Mode 1.
RESPONSE
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation if Admitted This violation was caused by personnel error.
It was previously recognized that the accident analysis and the Technical Specification intended for one train of control room ventilation cooling to have an operable emergency power supply. Although the Technical Specification wording does not specifically state this, station procedures were written to require a train without an operable emergency power supply to be considered inoperabic. The Shift Supervisor (SRO) mistakenly determined that it was not necessary to comply with the procedure since the Technical Specification wording was satisfied.
(3) Corrective Actions Taken and Results Achieved (a) This incident has been discussed with all Shift Supervisors, with emphasis placed on the requirement to follow procedures.
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(b) A Technical Specification change request will be submitted to the NRC by June 1, 1988.
(4) Corrective Actions to be Taken to Avoid Further Violations (See above)
(5) Date of Full Cc.mpliance Duke Power Company will be in full compliance. hine 1, 1988.
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_m LTB/1476/sbn DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413, 414/87-44-01 Technical Specification 3.7.1.2 requires three independent steam generator auxiliary feedwater pumps and associated flow pathe to be operable. With one auxiliary feedwater pump inoperable resr. ore the required auxiliary feedwater pump 1
to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least Hot Standby within the next l
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Technical Specification 4.7.1.2.1.a.4 requires that each auxiliary feedwater pump be demonstrated operable at least once per 31 days by verifying that each automatic valve in the flow path is in the fully open position when above 10%
Rated Thermal Power.
Contrary to the above, the licensee failed to maintain automatic valves in thu flow path in the fully open position when above 10% Rated Thermal Power constituting inoperability of the associated auxiliary feedwater pump in that enclosures 4.9 and 4.10 of procedure OP/1/(2)/A/6250/02, Auxiliary Feedwater System, required the automatic flow control valves to be fully closed or throttled during operations to cool auxiliary feedwater piping. The enclosures were implemented routinely on both units, including one instance where the Unit 2 "A" train automatic valves were fully closed or throttled continuously from November 10 to November 23, 1987 and the licensee did not maintain the units in an Operational Mode in wLich the Technical Specification did not apply.
RESPONSE
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation if Admitted This violation was caused by Duke Power Company personnel incorrectly assuming that the existing Technical Specification only required administrative clarification of the wording in the surveillance description.
The needed Technical 3pecification change request was therefore handled in a non-urgent manner that delayed its submittal to the NRC.
It was an accepted understanding (misunderstanding) that since the auxiliary feedwater flow control valves receive automatic open signals on all pump auto start signals, that their operation above 10% Rated Thermal Power no more degraded the operability of the system than would their operation at any other time.
It was thus perceived that this surveillance item was misworded in that the surveillance did not truly affect operability. An internal technical specification change request was underway in 1986 but due to the above mentioned misunderstanding it was not properly prioritized and expedited.
(3) Corrective Actions Taken and Results Achieved (a) Procedures will be changed to clarify the need to consider auxiliary feedwater inoperable anytime the flow control valves are not fully open i
l above 10% Rated Thermal Power.
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LTB/1476/sbn NOTICE OF VIOLATION PAGE 2 (b) A Technical Specification change to clarify the operability requirement was submitted on February 15, 1988.
(c) An integrated listing of proposed Technical Specification changes is being developed to help user organizations to assure proper priorities have been assigned by licensing personnel.
(4) Corrective Actions to be Taken to Avoid Further Violations (See above)
(5) Date of Full Compliance Duke Power Company will be in full compliance April 1, 1988.
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