ML20215G693
| ML20215G693 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/11/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8706230355 | |
| Download: ML20215G693 (6) | |
Text
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j Dunn POWER Gomuy 1
P,0. DOX 33100 CHARLOTTE, N.C. 28242 HALB.TUGKEH TELEPHONE 1
vmn eneminent (704) 373-4531 nmma vuesnescrum I
June 11, 1987 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 i
Subject:
RII/PKV/MSL Catawba Nuclear Station Docket Nos. 50-413 and 50-414 IR 413/87-06; 414/87-06 IR 414/87-08; 414/87-08
Dear Sir:
Please find attached responses to the Violations identified in your Notice of j
Violation dated May 15, 1987. These violations were initially identified in'the j
subject Inspection reports, dated March 12, 1987 and April 10, 1987, respectively.
i Very truly yours, j
.t.4 /h, t O
.w Hal B. Tucker LTP/58/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 DR O
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DUKE POWER COMPANY RESPONSE TO VIOLATION A 413/87-08-01, 413/87-06-01, 414/87-06-01 i
10 CFR Part 50, Appendix B, Criterion III, requires that measures be established to assure that applicable regulatory requirements and the design basis, as deffned in 10 CFR Part 50.2 and as specified in the License application, for those structures, systems, and components to which this Appendix applies, are correctly translated
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into specifications, drawings, procedures, and instruction.
Contrary to the above, measures had not been established to assure that regulatory-requirements and the design bases were correctly translated into specifications, drawings, procedures, and instructions in that:
(a) The containment design drawings did not indicate a means for maintaining i
the Containment Air Return Fan Subsystem operable during a design basis l
Loss of Coolant Accident in that measures, such as curbing, were not i
identified on the drawings for prevention of flooding of the fans.
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both fans were placed in a degraded condition.
J (b) The design drawings for installation of air lines to the Pressurizer
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Power Operated Relief Valves (PORV) were unclear and did not ensure that
-i the two instrument air lines with backup nitrogen capability were l
connected to the correct PORVs.
This resulted in one of two required PORVs not being connected to the backup nitrogen system as required by design.
RESPONSE
(1) Admission or Denial of Violation Duke power Company admits the violation.
(2) Reason for Violations if Admitted (a) The violation occurred because the civil design drawings did not detail the curbs required to divert water from the Containment Air Return Fan Subsystems area.
The need for the curbs was identified in the design phase of the plant and a commitment to complete the design was made.
However, the commitment was never fully implemented.
(b) The violation occurred because insufficient information was provided on the mechanical piping layout drawing interface with the instrument loop drawing. The three continuations shown on these drawings failed to uniquely identify, on either drawing, sufficient information to ensure proper field installation. The mechanical flow diagram did correctly detail all necessary information for proper installation. However, this drawing is not required for use in the installation process.
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, (3) Corrective Action Taken and Results Achieved-(a)' The curbs have been installed to protect the Containment Air Return Fan
--Subsystem area from flooding. The necessary design drawings have been revised to' detail' the curbs. All modifications were completed prior to res tart. - In addition, the correspondence files were reviewed, within a six month time period, to onsureithat all requested changes or additions were implemented. A11'other-changes or additions were found to have been completely implemented on the drawings.
(b) The air supply lines have been modified to match their assured nitrogen backup supplies to their proper Pressurizer Power Operated Relief Valve (PORV)..All affected design drawings have been upgraded to show suffledent continuation information to correctly connect each air line to its proper PORV. A review was made to assure that no other train-related, assured air / nitrogen sources could be similarly affected by luedequate design information on routing drawings. No other instances were identified. All modifications were completed prior to restart of Unit.
(4) Corrective AcEion Taken t'o Avoid Further Violations Design Engineering has implemented an extensive progi'm'of enhancements'to its station modification program which are collectively known as TOPFORM. These chunEen were affected to remedy deficiencies in the design control process.
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(5) Date of Full Compliance Duke Power Company is now in full compliance.
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DUKE POWER COMPANY RESPONSE TO VIOLATION 413/87-08-02 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, February, 1978.
Appendix A of Regulatory Guide 1.33, states that procedures are required covering the surveillance testing of safety-related equipment.
Coatrary to the above, on November 6, 1986, operators failed to properly implement surveillance testing procedure PT/1/A/4600/03c in that the vent valve in the normal 1
air supply line was closed at the wrong point. in the procedure.
In addition, the i
procedure was inadequate to establish the test of the PROV's utilizing the nitrogen
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backup supply in that air trapped between a check valve and the pressurizer PORV's was capable of stroking the PORV more than one complete cycle.
RESPONSE
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(1) Admission or Denial of Violation Duke Power Company admits th violation.
(2) Reasons for Violation if Admitted Personnel error and procedure inadequacy.
The personnel error included not having a copy of the procedure in-hand and operating a vent valve out of sequence. The operator closed the instrument air isolation valve and opened q
the vent valve on the air supply header. The vent valve should have remained j
opened during the test but was closed when the operator vented the header down j
to a " whisper". The operator did not consider that this affected the intent j
of the procedure. The closing of the vent valvo and'a leaking check valve allowed gas to leak by and provide enough pream.re build-up to operate, the i
PORV's, which was not the intent of the procedure.. The procedural inadequacy 2
included not operating the PORV's on instrument air alone until they would no longer open prior to valving in the nitrogen supply. This method would have ensured that the instrument air was depleted between the associated check valve and the PORV.
(3) Corrective Actions Taken g d Results Achievg (a) Subsequent testing of the PORV's revealed the problem.
(b) An investigation revealed piping problems, procedural problems, and operator procedure-use problems.
(c) The piping arrangement was corrected, the procedure vau. rewritten to ensure the procedure objective was met, and the operator. involved was counseled on the proper use of procedures.
(d) The procedure was then used to test'the PORV's entisfactorily.
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RESPONSE TO VIOLATION PAGE 2 (4). Corrective Actions to be Taken to Avoid Further Violations.
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(a) The incident was covered in' detail'at a Shift Supervisor's meeting held on April 17,-1987.
(b)' The' operator involved was counseled.on the proper use of procedures..
(c) The procedure was rewritten and used to ratest' satisfactorily.
(5).- Date 'of Full Compliance Duke Power Company is now in full' compliance.
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DUKE POWER COMPANY RESPONSE TO VIOLATION 414/87-06-02 10 CFR 50, Appendix B, Criterion riI, requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, on January 2, 1987, the licensee did not establish measures to assure that conditions adverse to quality were promptly identified and corrected when test data indicated possible fouling of. Containment Spray System Heat Exchanger 2A.
This information was not brought to the attention of appropriate personnel until February 17, 1987.
Response
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation if Admitted Personnel error with poor communication with Design Engineering as a contributing factor. Test engineers did not pursue data analysis with Design Engineering in a timely manner.
(3) Corrective Actions Taken and Results (a) Engineers were sensitized to the importance of accurate data analysis in a timely manner.
(b) Direct communications were opened with Design Engineering as opposed to going through a third party.
(c) Software has been provided on site to analyze similar situations within hours.
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(4) Corrective Actions to be Taken to Avoid Further Violations Actions taken in Section 3 above will avoid further violations.
(5) Date of Full Compliance j
Duke Power Company is now in full compliance.
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