ML20236L556

Responds to NRC Re Violations Noted in Insp Rept 50-413/87-20.Corrective Actions:Clear Definition of Recurring & Similar Categories of Events Developed & Implemented at Plant,Supplemented W/Logic Diagram

ML20236L556
Person / Time
Site:	Catawba
Issue date:	10/27/1987
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8711100405
Download: ML20236L556 (4)

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DUKE POWER GOMPAhT

,4 P.O. BOX 33169

' CH.ARLOTTE, N.C.' 28249.

HALB. TUCKER TELEPHONE

'vios russanawv (704) 373-4531

. NUOLEAM rh0DUOTRON (t v, l

October 27,.1987

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'U. S. Nuclear Regul'atory Commission Attention: Document Control Desk 1 Washington, D. C. 20555

Subject:

Catawba Nuclear Station Docket No. 50-413 Violation 50-413/87-20-03 j

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s Dear Siri

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8 Please' find attached our response to the subject Violation as requested by your j

. letter of September 30, 1987.

Very.truly yours,-

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J L l ifal B. Tuc'ker l LTP/113/sbn Attachment xc 'Dr. J. Nelson Grace, Regional Administrator U- .U.~Si Nuclear Regulatory Commission ' Region II 3b3 a a e rg Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station &y,; ) G711100405 871027 i. PDR ADDCK 05000413 )c .G-PDR i N'Ai '

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\\_ s Q. ' DUKE POWER COMPANY- ~ RESPONSE TO VIOLATION i 50-413/87-20 ' y i 4 -Technical Specification'nL6'8.1) requires that written procedur'es shall be ~ established,1: implemented,'and maintained covering the applicable procedures recommended in Appendix;A to Regulatory Guide 1.33, Revision 2, February 1978. 1[ Duke Power Company Safety Review Group-Incident Investigation and Report' / ~ Preparation;!SRG/2, and Catawba. Nuclear Station Directive.2.8.1. Problem

Investigation-Process and Regulatory Reporting collectively require reportable l

. events;to be thoroughly investigated, the'cause determined, and the full impli. cations of-recurring' events evaluated. ~I ' Contrary to the above,-the licensee completed Incident Investigation Report i .C87-040-l'of May' 14, 1987, and did not thoroughly. investigate, determine the .cause, f and ' evaluate' the full recurring event implications for valve INSPT5040 inappropriately, remaining shut from April.7 to April 24, 1987, causing i "~" Containment Pressure. Channel'.IV'to be inoperable. g RESPONSEr 1 i e l

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Admission.or Denial of Violation ze Duke Power Company admits the alleged violation. 2; . Reasons'for' Violation if Admitted Duke Power Company Management has closely examined the details of u Incident Investigation. Report C87-040-1-of May 14, 1987 and concludes that a. reasonable' effort was. expended on the initial investigation of i this event. Further supervisory involvement could have been provided to ensure. proper-evaluation of the strip chart.. 1 l Duke Power Company Management concurs with the NRC in that the conclusion i - drawn'by the I&E Technician following evaluation of the strip chart was i ' erroneous However,, consideration must be given to the fact that (1) the changes'in transmitter output were very subtle and displayed some of the same characteristics when the transmitter was in service as when it was out of' service, and (2) the strip chart needle deflected up to 1 0.1 psig ~ about!zero when the transmitter was out of service and deflected up to _ 0.2 psig about zero when the transmitter was in service on a scale +

' range of -5 psig to +5.psig and graded in 0.1 psig increments (about the y ~.

width of the mark made by the chart pen). The I&E Technician was considered experienced and knowledgeable with respect to reading and -. interpreting' strip' charts.. The initial investigator accepted the analysis ~of the I&E Technician due to not having any other conflicting information.. .), k.' C, a NI--.

i - The initial investigation revealed that no problems had been experienced with valve manipulation. When the I&E Technicians removed and returned i

o ~ervice following calibration, including the f

the transmitte, s independent verification, no indications of problems with the valve handle or valve operation were observed. Different I&E Technicians investigating the problem of channel IV not tracking properly also did ) not indicate any problems with the valvi handle or valve operation when manipulated and independently verified. On both occasions, when they manipulated t 5 valve, which has a "T" handle, not a handwheel, they_did not believe oc incognize it to be loose because of the friction felt when j they turned ths vaive handle. Thus, reaching the conclusion that the valve was manipulated by someone unknown during another plant evolution I is a reasonable conclusion based on the initial facts that there were no apparent equipment problems and the transmitter was tracking properly. Duke Power Company Management does take recurring events very seriously. Even though we believe this case to be an isolated example, we will ensure proper attention is given to recurring events involving unknown root causes. Our formal Operating Experience Trend Program implemented in August, 1987 will aid us in this endeavor. Overall, our investigative program is concluded to be a sound program. j 3. Corrective Actions Taken and Results Achieved i The importance and need to thoroughly investigate recurring events, a. determine root causes, and develop corrective actions have been discussed and emphasized verbally to our Nuclear Production Department Management and, in particular, to our. Nuclear Station Managers and independent on-site Safety Review Groups at Catawba, McGuire and Oconee Nuclear Stations to raise their level of sensitivity and support in this activity. b. A clear definition of " recurring" and "similar" categories of events has been developed and implemented at Catawba, McGuire and Oconee Nuclear Stations. This has been supplemented with a logic diagram to aid the Safety Review Group investigators to systematically and consistently identify recurring and similar events. This will also i facilitate our Operating Experience Trend Program. ] Unit 2 Containment pressure channel calibration procedures have been c. changed to specify and require improved methods of return to service j verification. j 1 d. Employee Training and Qualification System (ETQS) documented l training will be provided by October 30, 1987 to appropriate I&E l personnel covering the topics: l (1) Incident Investigation Report C87-040-1, Rev. 1. (2) Observing the turning of Dragon valve stems when turning the valve handle to verify proper handle installation / tightening, and to ensure valve operation. 1

x 4.> ' ', N (3),How to correctlyLinstall/ tighten Dragon valve handles that are-' ' found loose or removed. ETQS documented' training will be provided by' October 31,~1987 to 'e.. appropriate Performance personnel coveringthe observation.of the turning ~of Dragon valve stems when' turning.the valve handle to. 1 verify proper. handle installation / tightening, and to ensure valve j operation, j '4. Corrective Actions to be Taken to avoid further Violations Actions taken in Section 3 above ensure avoidance of further violations. ] . 5. Date of Fu'11 Compliance { Duke Power Company.is in full compliance. i k .l i i . - _ - _ _ _ _ - _ _ _ _ _}}