ML20212N441

Responds to Violations & Deviation Noted in Insp Repts 50-413/86-51 & 50-414/86-54.Corrective Actions:Shutdown Request Program No Longer Used for Work on Operating Plant & Mgt of Shutdown Requests Deleted

ML20212N441
Person / Time
Site:	Catawba
Issue date:	03/06/1987
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8703130026
Download: ML20212N441 (5)

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Durs POWER GOMPANY P.O.190X 33180 CHAMLOTTE,N.C.28942 HALB. TUCKER Tzt.mpnown v m reseinant (704) OW834 wima. man reonamon March 6, 1987

- U. S. Nuclear Regulatory Comunissio*

Attention: Document Control Desk Washington, D. C. 20555

Subject:

RII PKY, PHS, ML Catawba Nuclear Station IER 50-413/86-51, 50-414/86-54 Violation Response Centlemen:

Attached are responses to Violation No. 413/86-51-01, 414/86-54-01; Violation No.

413/86-51-02,414/86-54-02; Violation No. 413/86-51-04 and Deviation No.

414/86-54-04, which were identified 1.n the subject Inspection Report.

Very truly yours, lfg Hal B. Tucker LTP/18/sbn Attachment L xe: Dr. J. Nelcon Grace, Regional Administration U. S. Nucleae Regulatory Comunission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l

! Mr. P. K. Van Doorn I NRC Resident Inspector Catawba Nuclear Station

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0733130026 DR 070306 ADOCK 05000413 PDR

t DUKE POWER COMPANY RESPONSE TO VIOLATION 413/86-51-01 AND 414/86-54-01 Technical Specification 6.8.1 requires that written procedures shall be r established, implemented, and maintained covering the applicable procedures

, recosmonded in Appendix A to Regulatory Guide 1.33. Revision 2. Licensee procedure Station Directive 3.0.3, Revision 8 requires appropriate personnel to assign the

! responsible group for releasing a system to be worked on. Technical Specification , 4.11.2.1.1 requires dose rates to be determined for gaseous effluent releases. l contrary to the above, a procedure was not followed in that work on the Gaseous  ;

i Weste System was assigned to be released by Operations group; instead of the responsible group which was Radweste Chemistry. This failure to follow procedures caused the inadvertent gas release of January 5, 1987. Also, the dose rate was not determined prior to this release on January 5,1987.  ;

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RESPONSE

l j -(1) Admission or Denial of Violation  ;

i i Duke Power Company admits the violation.

l (2) Reasons for Violation if Admitted 4

A personnel error resulted in the assignment of operational system control to i the incorrect group.

l' (3) Corrective Actions Taken and Results Achieved 1 l

{ Currently, all work on systems, components, and structures at Catawba Nuclear i j Station is controlled by the "CNS Station Directives Manual" and the "CNS  !

Maintenance Manual". The shutdown request (F13A) program is no longer used j

for work on the operating plant. (It is still used for new construction at <

d the site). Concurrently, Station Directive 3.0.3, " Management of Shutdown  !

j Requests" has been deleted. This directive detailed Nuclear Production's t responsibility for shutdown requests.

l All work at the station is now governed by Maintenance Procedure 1.0, " Work Request Preparation". This procedure details all aspects of the work request i

, process including designating the appropriate station group which has operational control. Specifically, section 4.3.13 describes the planner's responsibility to indicate the appropriate group with operational control  ;

in Section II of the work request.

l Additionally, Station Directive 3.10.1, " Operational Control of Systens" is i

available to the Planner to assist him in his decision. This directive

! details the methods for identifying and controlling the boundaries of a system

assigned to a station group for operational control.

j (4) Corrective Actions to be Taken to Avoid Further Violations 4

l Actions taken in Section 3 above should ensure avoidance of further i

l violations. i

} (5) Date of Full Cospliance ,

i l Duke Power Company is now in full complit.nce. .

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DUKE POWER COMPANY RESPONSE TO VIOLATION 413/86-51-02 AND 414/86-54-02 Technical Specification 6.8.1 requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Revision 2. Operations Procedure OP/1/B/6100/101 requires operator actions upon receiving the alarm for the

. Auxiliary Building Ventilation High Radiation Monitor, EMF-41.

i Contrary to the above, on January 5, 1987, operators did not take actions after j receiving the EMF-41 alarm and failed to follow the procedure.

RESPONSE

l (1) Admission or Denial of Violation

) Duke Power Company admits the violation.

(2) Reasons for Violation if Admitted 1 It has been determined that the annunciator alarm for ENF-41 was functional at the time of the incident. The Alarm was either acknowledged by the Control i Room Operator who did not recognize the alarm as that of EMF-41, or by unauthorized persons. Therefore, the the annunciator response procedure was not initiated.

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(3) Corrective Actions Taken and Results Achieved .

The EMF-41 annunciator circuit was tested successfully several times to ensure it was functional. It was also ensured that the EMF-41 Trip 2 alarm performed its function of automatically placing Auxiliary Building Ventilation system (VA) in the filter mode of operation.

(4) Corrective Actions to be Taken to Avoid Further Violations (A) Operations Management Procedure (OMP) 2-16. " Control Room Conduct" was changed to ensure all Control Room Operators assigned to the applicable l unit are informed of all activated computer / annunciator alarms while on duty. In the case of shared systems alarms, the Control Room Operators l on the other unit shall also be informed.

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I (B) This incident was discussed in detail at a Shift Supervisor's Meeting on January 9, 1987, where it was emphasized that non-control room personnel l

are not authorised to respond to annunciator alarms without permission of '

the Control Room Operator.

(C) An operator "up-date" was initiated to inform all licensed personnel of the above OMP change and to explain its intent. l (D) Other station group heads were instructed to discuss the importance of not having non-control room personnel acknowledra control room alarms I without prior approval of the Control Room Operator.

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] (5) Date of Full Compliance  ;

Duke Power Company will complete corrective actions by March 23, 1987.

DUKE POWER COMPANY RESPONSE TO VIOLATION 413/86-51-04 Technical Specification 3.3.2 requires the licensee to have Engineered Safety Features Actuation System instrumentation channels operable as shown in Table 3.3-3. The table identifies the Containment Pressure - High and Containment Pressure - High-High actuation instrumentation as a requirement for Operational Modes 1, 2 and 3. Three total channels of Containment Pressure - High are a required condition of operability and the action statement requires the licensee to place an inoperable channel in the tripped condition within one hour. Four total channels of Containment Pressure - High-High are a required condition of operability and the action statement requires an inoperable channel to be placed in the bypassed condition.

Contrary to the above, from November 19, 1986, to December 6, 1986, while the unit vss in Operational Modes 1 and 2 and one channel of containment pressure inoperable due to its transmitter being isolated, the licensee did not place the inoperable Containment Pressure - High-High channel in the bypassed condition.

RESPONSE

(1) Admission or Denial of Violation Duke Power Company admits the violation.

(2) Reasona for Violation if Admitted The operator involved entered the malfunction of the Containment Pressure -

High-High Control Room gauge into the Technical Specification Log for purposes of tracking work on the gauge, but mistakenly thought that the safety functions of the corresponding pressure transmitter were operable.

(3) Corrective Actions Taken and Results Achieved (A) The operator involved has been counseled concerning his actions with regard to this situation.

(B) All Shift Technical Advisors have been made aware of this violation.

(4) Corrective Actions to be Taken to Avoid Further Violations (A) This specific incident will be discussed at the next Shift Supervisor's Heating. This discussion will include investigating all gauge inputs and applicable transmitter outputs.

(B) Operations Management Procedure (OMP) 2-29, " Technical Specification Action Items Logbook". will be amended to include guidance on declaring control room instrumentation inoperable.

(5) Date of Full Compliance Duke Power company will be in full compliance by May 1, 1987.

DUKE POWER COMPANY RESPONSE TO DEVIATION

414/86-54-04

The licensee informed the NRC, in its November 18, 1986 response to a Notice of

Violation dated October 20, 1986, that training would be completed on i IP/0/A/2890/01 (General Troubleshooting Procedure) by November 30, 1986 and that Section 4.3.10 of M Pl.0 (Work Request Preparation) would be revised by December 31, 1986 to include additional guidance for planners to list appropriate component procedures when applicable.

l Contrary to the above, training of all applicable personnel was not completed by November 39, 1986 and Section 4.3.10 of MMP1.0 was not revised by December 31, 1986.

, RESPONSE:

Corrective Actions Taken and Results Achieved 4

! During the time frame of the Violation Response, extensive changes were being l implemented to MPl.0, including additional groups / sections being assigned work l requests and changing of account and work order numbers, all of which resulted in l delays to revising the documents committed.

, An identical problem had been identified previously on the proper use of trouble shooting procedures, which was also under review and evaluation. In the interim, a i letter dated March 6, 1986 from Quality Assurance had been used for' guidance.

Since then, WPl.0 has been revised with all changes as noted above, as Revision ,

i 21. Planning personnel have been informed of these changes and have been given a copy or have access to a copy to MMP1.0, Revision 21. Training on all Planning

, Administrative Procedures is ongoing to ensure compliance.

Training on IP/0/A/3890/01 was well underway at the time of the finding but training persoanel were not aware of the deadline. Since that time all training has been completed. This deviation has been discussed among the station groups involved and it was agreed that the implementing groups would be notified in a more direct manner of commitment deadlines, and that the implementing groups would be more proactive in expediting corrective action prior to getting the official l commitment letter.

Corrective Actions to be Taken to Avoid Further Deviations Actions described above should ensure avoidance of further deviations.

Date of Full Compliance Duke Power Company is now in full compliance.

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