ML20246C076

Notice of Violation from Insp on 890326-0429.Violations Noted:Selected Control Room Drawings Do Not Reflect as-built Conditions & Support Documents Necessary to Discern Scope of Mods Not Available in Control Room

ML20246C076
Person / Time
Site:	Catawba
Issue date:	06/27/1989
From:	Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246C069	List: IR 05000413/1983013 IR 05000413/1989013 ML20246C076
References
50-413-89-13, 50-414-89-13, NUDOCS 8907100233
Download: ML20246C076 (4)

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i ENCLOSURE 1 I

NOTICE OF VIOLATION 4 l

q Duke Power Company Docket Nos. 50-413, 50-414 j Catawba Units 1 and 2 License Nos. NPF-35, NPF-52 During the Nuclear Regulatory Commission (NRC) inspection conducted on l March 26, 1989 through April 29, 1989, violations of NRC requirements were l identified. in accordance with the " General Statement of Policy and Procedure i for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1989), the violations l are listed below: l A. 10 CFR Part 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and that these instructions, procedures, instructions or drawings include appropriate quantitative or qualitative acceptance criteria for deter-mining that important activities are satisfactorily accomplished.

Implicit in these requirements are the requisites that these procedures, ,

instructions or drawings be current, accurate and reflect actual as-built conditions.

10 CFR Part 50, Appendix B, Criterion VI, requires in part that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto. Further, it is i required that these measures assure that these documents, including changes thereto are reviewed for accuracy, approved, and distributed for use to the appropriate locations. Implicit in these requirements are the '

requisites that changes to these documents be accurate, timely and performed such that the revised document is appropriate to the circumstances.

1. Contrary to the above, selected control room drawings do no reflect as-built conditions. The applicable systems have been modified but the drawings have not been revised to reflect the modifications.

These drawings are marked " Revised By NSM (Number)" denoting, in i effect, that they have been superseded, yet the modifications are not depicted on the drawings. Further, the support documents necessary 1 to discern the scope of the modifications are not available in the control room.

2 ., Contrary to the above, changes to selected control room drawings were not accurate in that: a) the drawings were mislabeled, stamped both '

" Interim As Built" denoting that the drawing represents the actual plant configuration after a modification has been implemented, and l "See Interim as Built" denoting that yet another print reflects the i actual plant configuration; b) Selected drawings were stamped "See  !

Interim As-Built" yet there were no applicable Interim As-Built drawings.

8907100233 890627 PDR ADOCK 05000413 Q PDC

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Duke Power Company 2 Docket Nos. 50-413, 50-414 Catawba Units 1 and 2 License Nos. NPF-35, NPF-52

3. Contrary to the above, selected Technical Support Center (TSC) drawings do not reflect as built plant configuration. The TSC is not on distribution for Interim As Built Prints, which are the prints j which depict the actual plant configuration after a modification has been implemented until " Final As-Built Drawings" are generated. This period was observed to be as much as 15 months.

4. Contrary to the above, control . room drawings do not reflect actual  !

as-built conditions for those systems on which part of a modification has been completed. Systems with partially completed modifications have been, and are returned to service without drawings in the control room which depict as-built configurations. The licensee's current document control system does not issue drawings to the control room until a modification is complete.

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5. Contrary to the above, selected Crisis Management Center (CMC) drawings do not reflect current As Built conditions.

a. CMC drawings do not reflect Temporary Station Modifications (TSMs), nor are the drawings marked to indicate that a TSM .

exists.  !

b. CMC drawings are not updated to reflect partially completed station modifications, even though the plant may return to service. Some partially completed modifications are over 2 i years old. l

c. CMC drawings are not kept updated in a timely manner to reflect completed NSMs. CMC drawings are updated ' through issuance of Final As-Builts.

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

l B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities l referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

1. OP/2/A/6200/20, Drain and Fill of Penetration M347, enclosure 4.67, step 2.3 requires the operator to ensure that 2NV-20, Letdown Reheat Heat Exchanges Back Pressure Control Bypass Valve, is closed.

Contrary to the above, on March 14, 1989 while performing the above procedure, the operator failed to ensure 2NV-20 was closed. This resulted in a spill of approximately 40 gallons of reactor coolant and a personnel contamination when independent activities pressurized associated piping in the belief that 2NV-20 was closed.

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Duke Power Company 3 Occket Nos. 50-413, 50-414 Catawba Units 1 and 2 License Nos. NPF-35, NPF-52 1 1

l l 2. PT/2/A/4200/01A, Containment Integrated Leak Rate Test, step 12.2.26.18.A requires the Removal and Restoration (R&R) Tag to be  !

cleared on 2FW-26, Refueling Cavity Drain Valve after the temperature  !

detector cable has been removed from the seat of 2FW-26.

OP/2/A/6200/13, Filling, Draining and Purification of the Refueling l Cavity, enclosure 4.13, step 2.1 requires two operators to indepen-dently visually inspect the valve seat for 2FW-26 and remove any i debris then unlock and close 2FW-26. i i Contrary to the above, on March 23, 1989, PT/2/A/4200/01A was not

' followed in that the R&R Te 3 on 2FW-26 was cleared although the temperature detector cable tad not been removed from the seat of 2FW-26, and on March 28, 1989 OP/2/A/6200/13 was not followed in that two operators failed to visually inspect the valve seat of 2FW-26 prior to closing the valve. These failures contributed to 2FW-26 being closed with the cable running through the valve and to a ,

subsequent leak of refueling water causing a resulting radiological i hazard during refueling operations.

3. OP/2/A/6200/13, Filling, Draining and Purification of the Refueling Cavity, enclosure 4.3, step 1.5 requires communications to be ,

established between the control room and the refueling cavity during l a gravity fill of the refueling cavity from the Fueling Water Storage '

l Tank.

Contrary to the above, on March 28, 1989, the licensee failed to  !

establish communications between the control room and the refueling cavity when gravity fill of the refueling cavity commenced from 93%

level at 6:27 p.m. This contributed to an overfill of tho refueling cavity and a spill of approximately 25,000 gallons of refueling  !

water.

This is a Severity Level IV Violation (Supplement 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 II, and a copy to the NRC Resident Inspector 1 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 t

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Duke Power Company 4 Docket Nos. 50-413, 50-414 Catawba tinits 1 and 2 License Nos. NPF-35, NPF extending the response time. If an adequate reply is not received within the time specified in this Notice., an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper.should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION W,

Alan R. Herdt, Chief f

Reactor Projects Branch 3 Division of Reactor Projects Dated at Atlanta, becr;ie .

this 27th day of June 1989 I 4

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