ML20197H655
| ML20197H655 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/08/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8406190104 | |
| Download: ML20197H655 (3) | |
Text
9 DUKE POWER GOMPANY P.O. DOX 33180 CHARLOTTE, N.C. 28242 som en (704 37 4531 June 8, 1984 84 JllN14 Pj2: 52
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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 30323 Re: Catawba Nuclear Station Units 1 and 2 Docket Nos. 50 A13 and 50-414
Dear Mr. O'Reilly:
Pursuant to 10 CFR 50.55e, please find attached Significant Deficiency Report No. SD 413-414/84-14.
Very truly yours, ad n
Hal B. Tucker LTP/php Attachment cc: Director INP0 Records Center Office of Inspection and Enforecment Suite 1500 U. S. Nuclear Regulatory Comission 1100 Circle 75 Parkway Washington, D. C. 20555 Atlanta, Georgia 30339 NRC Resident Inspector Mr. Robert Guild, Esq.
Catawba Nuclear Station Attorney-at-Law P. O. Box 12097 Palmetto Alliance Charleston, South Carolina.29412 21351 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 8406190104 84060s PDR ADOCK 05000413 S
()t ; lCIAL COPY der' lie
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g Catawba Nuclear Station REPORT NUMBER:
SD 413-414/84-14
' REPORT DATE:
June 8, 1984 FACILITY:
Catawb'a Nuclear Station Units 1 & 2 t
' IDENTIFICATION 0F DEFICIENCY: During Construction of air control lines for active Nuclear Safety Related pneumatic control valves 1KC82B and 1RN291A non-qualified fmanual valves were added between the 1E qualified solenoid valves and the safety related valve actuators.
This was identified as being a deficiency on 4-10-84.
INITIAL REPORT: On May 9,1984 Hugh Dance, NRC Region II, Atlanta, Georgia, was notified of the-subject deficiency.by L. M. Coggins, R. E. Hardin, R. D. Carroll and T.' L. Utterback of Duke Power Company, Charlotte,' North Carolina.
COMP 0NENT AND/0R SUPPLIER: Control air lines supplied by Duke Power Company for
- the subject valves.
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DESCRIPTION OF DEFICIENCY: ;During NRC site. inspections in relation to CDR 413, 414/83-03 the site inspector discovered manual valves in the control air lines for valves IKC828 and IP.N291A and' questioned the acceptability of these installations.
Through subsequent investigations by Duke Paver Company Design Engineering and i
Construction Departments it was determined that the valves were not installed as i
a temporary modification but were installed as a result of a misinterpretation by Construction of installation standard ICS-A-20 and inadequate qualitative inspec-
. tion requirements in the standard to preclude such misinterpretation.
Failure of the non-qualified manual valves could result in the prevention of control air venting from the process valve actuator thus preventing the process valve from moving to or failing in its safe position. This is a violation of 10CFR50, Appendix B, Criterion V, which requires appropriate qualitative acceptance criteria to assure activities affecting safety (or quality) have been satisfactorily accomplished.
-ANALYSIS OF SAFETY IMPLICATIONS: Based on Construction's inspections of other Nuclear Safety Related active pneunatic valves in re:ponse to Non C3nforming Item Report L
18345 which was generated as a result of this problem it has been determined that this is not a generic problem as manual valves were added only on the two applica-tions noted above. The mispositioning or failure of these manual valves in con;>nc-
-tion with a single active failure on the redundant trains could result in loss of L'
both trains of component cooling water flow through the residual heat removal heat exchangers-and nuclear service water flow through the component cooling heat exchang-ers respectively. Although approximately twenty minutes worst case would be avail-
.able following initiation to detect and correct the problem, this time frame is out-
. side applicable guidelines for taking credit for operator action. Although the mispositioning of these valves as postulated could have resulted in an operating situation.outside the bounds of our safety analysis, we have concluded that this situation would not have represented a significant health and safety threat to the public due to the inherent conservatism in the system and the unlikely series of events that must occur for the situation to result.
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CORRECTIVE ACTION:
ICS-A-20 will be revised to define the control air lines between the Nuclear Safety Related solenoid valves and valve actuators for active Nuclear Safety Related pneumatic valves to be Nuclear Safety Related in that the actual installation shall be made and inspected in accordance with the installation detail drawing and that the control air line and components shall be inspected for physical damage. The non-qualified manual valves have been removed from the control air lines for 1KC828 and 1RN291A and the installations re-tubed. All action as a result of this item will be completed by June 8,1984.