ML20246J902
| ML20246J902 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/25/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909050296 | |
| Download: ML20246J902 (7) | |
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. NKE POWER DbMPANY h
- P.O. BOX 33189
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' OMARLOTTE, N.C. 28242 (HALETUCKER Tzi.EPHONE
. ;vsomremement
- menazam ruonneruiu.
(704)073 4 531
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- August (25,1989
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=U. S. Nuclear-Regulatory Commission Document Control Desk'
-Washington, D.C.
20555' l.[
Subject:
Catawba Nuclear' Station.
Docket Nos.'.50-413 and. 50-413 iNRC' Inspection Report Nos. 50-413,'414/89 LReply to Notice of Violation P
Gentlemen:
Enclosed-is the response for the Notice of Violation 50-413/89-16-01 Land 50-414/89-16-02 issued July-25,'1989 by Alan R. Herdt. The violations concerned the failure.to lock _a high radiation door'and an inadequate' testing' procedure to Lensure valve 2KCD5 was locked closed after use.
In addition, enclosed is the response for the Notice of Deviation 413/89-16, 414/89-16 concerning the exterior fire' protection'. functional capability test.
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Very truly yours,
_(.-
T c
g, Hal B. Tucker
'WRC74/lcs-g
.xc:: S. D. Ebneter, Regional Administrator
,U. S. Nuclear Regulatory Commission L
Region II
- 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 W. T. Orders NRC Resident T.nspector t'
Catawba Nuclear Station n
8909050296 890825
' {DR ADOCK 05000413
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/89-16-01 10 CFR 20.203(2) requires that each entrance or access point to a high radiation area be maintained locked except during periods when access to the area is required, with positive control over each entry.
Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Plant Procedure HP/0/B/1000/25, Catawba Nuclear Station High Radiation Area Access, requires each entrance to a high radiation area to be locked to prevent unauthorized entry.
The area shall remain locked except during periods of access by personnel.
Contrary to the above, on June 14, 1989, the entrance to Room 316, "B"
Recycle Holdup Tank Room, a posted high radiation area, was not maintained locked during a peciod when personnel access was not in progress, in that at approximately 2:45 p.m.,
the door was discovered by the resident inspector to be in an unlocked condition without positive entry control being established.
l This a Severity Level IV Violation (Supplement IV).
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Response
1.
Admission or Denial of Violation Duke Power Company admits the violation.
2.
Reasons for Violation if Admitted Mechanical failure of door closer and latching mechanism with contributory personnel error.
At the time of the incident, Rm 316 had recently been declared a High Radiation Area and no maintenance had been performed on the door in the recent past.
Operations personnel entered and exited the room and upon exiting, the door closer and latching raechanism failed to perform as expected.
The Operator failed to ensure that the door was closed. This resulted in the above stated violation of Technical Specification 6.11.
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3.
Corrective Actions'Taken and Results Achieved a.; Health Physics technician rent to ensure that the door. to Rm 316 was closed and '. locked.
Also, he checked door for obvious mechanical problems.
l b.
Notified Mechanical-Maintenance o f.. door problems.
Mechanical Maintenance technicians were dispatched and corrections were made to the door problems.-
Physics technicians made functional checks. of all High
- c.. Health Radiation doors. One other door had minor problems and this door was corrected:by Mechanical Maintenance.
d.
Health Physics revised procedure HP/0/B/1000/07 to do the following:-
- 1) Require investigation of unlocked Higtr Radiation doors when found-by Health Physics. during.-daily routines.
This investigation includes ' notification to Operations, Health
- Physics, and-supervision 'of involved personnel and corrective actions taken.
e.
Health Physics revised procedure HP/0/B/1000/25 to do the following:
1). High Radiation Door Key Issue Authorization Form was revised to add requirements to:
-Keep doors closed and locked except during transit
-Pull check of-the latching mechanism upon entry and' exit.
-Any door problems, notify Health Physics
- 2) ' Operations High Radiation Area Key Issue Logsheet was revised to include requirements listed in 1 above.
f..
Operations will discuss this incident in detail at a Shift Supert isor's meeting on 8/18/89 to sensitize operators to ensure high radiat on doors are properly maintained.
4.
Corrective Actions to be Taken to Avoid further Violation Maintenance Engineering Services will design and coordinate a Preventive Maintenance program for High Radiation doors.
5.
Date of Full Compliance Duke Power will be in full compliance by 11-15-89.
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Pags 1 of 2 DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 414/89-16-02 Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Implicit in this is the stipulation that the procedure be adequate for the task being performed.
Plant procedures OP/0/B/6200/20 (Operating Procedure for the Component Cooling System) and OP/0/A/6200/21 (Operating Procedure for the Post Accident Liquid Sampling System) require valve 2KCD05 (Component Cooling Isolation Essential Return Header 1A), to be locked closed when the sampling system is not in use.
Contrary to the above, PT/2/A/4208/08 (Post Accident Liquid Sampling System Periodic Test) was inadequate to ensure valve 2KCD05 was locked clooed after use on June 2,- 1989 in that valve 2KCD05 was discovered open and unlocked on June 14, 1989 by NRC inspectors.
RESPONSE
1.
Admission or Denial of Violation Duke Power Company admits the violation.
2.
Reasons for Violation if Admitted a.
Valve 2KCD05 was incorrectly identified on flow diagram CN-2573-1.0 as being FC (fail-closed) rather than LC (locked-closed). Thus, during the review process of PT/2/A/4208/08, it would not be immediately apparent that the valve should be locked in the closed position.
b.
As a
contributing factor, 2KCD05 was incorrectly identified in PT/2/A/4208/08 as belonging to the Operations group.
(The valve belongs to the Chemistry group.) This led to confusion as to which group should i
operate the valve.
I c.
A procedural deficiency existed that resulted in 2KCD05 not being returned to its checklist position.
3.
Corrective Actions Taken and Results Achieved l
1 a.
Valve 2KCD05 was returned to the locked closed position.
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Corrective Actions to be Taken to Avoid Further Violations l
a.
An editorial SPR was written to change the indicated position of 2KCD05 l
from FC to LC on flow diagram CN-2573-1.0.
b.
Chemistry has assumed ownership and responsibility for operating the valve.
c.
PT/2/A/4208/08 is being revised to refer to OP/0/A/6200/21 (Operating Procedure for the Post Accident Liquid Sampling System). OP/0/A/6200/21 will be revised to specify the proper valve position, and include sign-offs on the valve checklist to ensure that this valve and all other valves are returned to proper valve position.
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Paga 2 of 2 DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION L
414/89-16-02 d.
A memo will be sent to all Chemistry personnel to clarify that any step in a procedure that directs them to contact another group for specific work action is not complete, until the work action has been verified complete.
Additionally, all Chemistry personnel will be asked to identify procedure steps for revision which do not require verification of work requested of another group.
5.
Date of Full Compliance September 20, 1989 1
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DUKE POWER COMPANY REPLY TO NOTICE OF DEVIATION 413/89-16, 414/89-16 The Catawba Nuclear Station Final Safety Analysis Report (FSAR) Section 9.5.1.3 states that a comprehensive safety evaluation of the Fire Protection System was performed in Response to Appendix A to Branch Technical Position 9.5-1.
The Catawba Nuclear Station Response to Appendix A to Branch Technical Position 9.5-1, section E.2 states that the fire pumps and fire pump power supplies are arranged in accordance with the intent of National Fire Protection Association (NFPA) 20.
NFPA 20 section 11-3.1 requires that flow tests of fire pumps shall be performed to determine their ability to attain satisfactory performance at shutoff, rated, and peak loads.
Contrary to the above, PT/0/A/4400/01A, Exterior Fire Protection Functional Capability Test, which is used to perform flow tests on the fire pumps, does not test the pumps to determine their ability to attain satisfactory performance at shutoff.
RESPONSE
1.
Admission or Denial of Deviation Duke Power admits the deviation.
2.
Reasons for Deviation if Admitted Pump shutoff head pressure is higher than the setpoint of the discharge relief valve (150 psig).
Therefore, this point cannot be tested without an adjustment of relief valve setpoint.
This is accomplished by manipulating a handwheel that is supplied with the valve.
Prior experience has shown that this manipulation is detrimental to the valve itself.
3.
gprrective Actions Taken and Results Achieved Duke Power Company Design Engineering Department has performed an analysis and determined that due to the flatness of the performance curve from shutoff to rated flow, the shutoff head point is of little value.
As a compensatory action, a new acceptance criteria data sheet for pump testing has been developed and will verify the setpoint of the discharge relief valve in lieu of testing the shutoff head point.
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Corrective Actions to be Taken to Avoid Further Deviations The acceptance criteria' data sheet specified in Section 3 will be incorporated.into PT/0/A/4400/01A, Exterior Fire Protection Functional Capability Test.. This' change:will be made as soon as the new acceptance criteria data sheet can be formally transmitted as a Design l
Engineering Document per an Exempt Variation L
Noticc.
5.
Date of Full Comoliance Duke. Power Company will be in full compliance by November 1, 1989.
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