ML20206J582

Notice of Violation from Insp on 880926-1025.Violations Noted:Two Instrument & Electrical Technicians Working W/O Procedures & Procedures AP-0-A-5500-34 & Omp 2-29 Inadequate

ML20206J582
Person / Time
Site:	Catawba
Issue date:	11/16/1988
From:	Brownlee V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206J564	List: ML20206J560 ML20206J582 ML20206J596
References
50-413-88-34, 50-414-88-34, NUDOCS 8811290043
Download: ML20206J582 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION h

Duke Power Company Docket Nos. 50-413 and 50-414 Catawba 1 and 2 License Nos. NPF-35 and NPF-52 During the Nuclear Regulatory Commission (NRC) inspection conducted on L.ptember 26 through October 25, 1988, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. Tochnical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained covering the activities referecced in Appendix A of Regulatory Guide 1,33, Revision 2, February 1978 which includes plant operation and maintenance. Implicit in those requirements is the requisite that the procedures be accurate, and appropriate to the circumstances.

1. Contrary to the above, on the af ternoon of October 11,19d8, two instrument and electrical (IAE) technicians were observed working without the benefit of a procedure as they were replacing the Unit one protection channel two protection back-up power supply.

2. Abnormal Procedure AP-0-A-5500-34, Secondary Chemistry Out Of Specification, requires that the affected unit's power level be reduced to less than 2 per cent power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the identi-fication that the unit is in Action Level 3 as defined therein.

Contrary to the above, procedure AP-0-A-5500-34 is inadequate. On October 15, 1988, unit two power level was not reduced to less thin 2 per cent power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the notification that the unit was in Action Level 3. The licensee made a decisicq to violate the procedural requirement based on operating experience which indicated that unit 2 can not be shut down in a controlled manner in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The procedure, therefoi ., is inadequate and considered inappropriate to the circumstances.

3. Operations Precedure OMP 2-29, Technical Specification Action Item Logbook, specifies support systems which are required for the operabilhy of Technical Specification required equipment as well as the compensatory actions to be taken if those support systems are inoperable. OMP 2-29 specifies in part that in order for a diesel generator to be operable, one diesel generator starting air compressor and one air resevoir are required. If these support components are not operable, the procedure states that another source of starting air should be found, or the diesel generator should be declared inoperable.

0811290043 001116 PDR ADOCK 05000413 0 PNV

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Duke Power Company 2 Docket Nos. 50-413 and 50-414 Catawba 1 and 2 License Nos. NPF-33 ai d NPF-52 ,

Contrary to the above OMP 2-29 is inadequate. On the morning of October 17, 1988, the operating staff removed both 2B diesel generator starting air compressors from service and did not declare the diesel generator inoperable. The operations staff made a decision to remove t 6e compressors from service without Considering the diesel to be maded based on an ambiguous reference in the ,

procedure regardi: r.e support syttem being needed for long tern, >

operability only. 1his reference is inappropriate, in that a system is either operable and capable of performing it's intended safety function or it is not. The procedure is inappropriate to the circumstances and is considered inadequate. l

4. Station Directive 3.1.14, Operability Determination, specifies the actions to be taken when compensatory measures are taken to compensate for the loss of the function of a component or system.

Contrary to the above, on October 17, 1988, when both 2B diesel

, generator starting air compressors were removed from service the requirements of the Station Directive were not performed.

This is a Severity Level IV Violation (Supplement I).

B. 10 CFR 50, Appendix B, Criteriun XVI requires in part that measures be established to assure that conditions adverse to quality such as failures or malfunctions are promptly identified and corrected.

Contrary to the above, measures were inadequate to assure prompt action to correct a condition adverse to quality, ir, that on March 28, 1988 the licensee determined that 2CA-62A, Auxiliary Feedwater pump 2A Discharge Isolation Valve to 2A Steam Generator, faile1 to close during an event on March 9,1988 and failed to take action to :orrect the condition until April 27, 1988 duritig which time the valve was required to be operable.

This is a Severity Level IV Violation (Suppleaent I) applicable to unit 2 only.

Pursuant to the provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region '.I. and a copy to the NRC Resident Inspector within thirty (30) days of the date of the letter transmitting this Notice.

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the j

f Duke Power Company 3 Docket Nos. 50-413 and 50-414 Catawba 1 and 2 License Nos. NPF-35 and NPF-52 time specified in this Notice, an order may be issued to snow cause why the license should not be modified, suspended, or revoked or why such other action as may oe proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION

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Virgil L. Brownlee, Chief Reactor Projects Branch 3

! Division of Reactor Projects Dated at ftlanta, Georgia this /f'Ottay of Mrv. 1988

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