ML20248A989
| ML20248A989 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/27/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908090086 | |
| Download: ML20248A989 (11) | |
Text
{{#Wiki_filter:.. ~ l Dmm POWER Go3WANY 1*.O. HOK 33189 CHARLOTTE. N.C. 28242 HALU.TUCKEH Trn.r.rvioxe vus enemment (704) 373-4531 otumanemonwmon July 27, 1989 U. S. Nuclear Regulatory Comission Washington, D.C. 20555 i Attention: Document Control Desk
Subject:
Catawba Nuclear Station Docket Nos. 50-413 and 50-414 NRC Inspection Report Ncs. 50-413, 414/89-13 Reply to Notice of Violation Gentlemen: Enclosed is the response for the Notice of Violation 50-413/89-13-04 and 50-414/89-13-01 issued June 27, 1989 by Alan R. Herdt. The violations were for inadequate drawing control and failure to follow procedures. Very truly yours, /f( k i Ir Hal B. Tucker WRC63/lcs xc: S. D. Ebneter, Regional Administrator U. S. Nuclear Regulatory Comission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 W. T. Orders NRC Resident Inspector Catawba Nuclear Station O, GlDR908090086 890727 / [I i F ADOCK 05000413 l l O PDC i L______-.
r DUKE F0WER 00MPANY REPLY 10 A NUlTCE OF VIOLATION 414/89-13-01 Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in i Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Item #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 Exchanger 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. Item #2 - Pr/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 2W-26, Refueling Cavity Drain Valve, af ter the temperature detector cable has been removed from the seat of 2 W-26.
OP/2/A/6200/13, Filling, Draining and Purification of the Refueling
- Cevity, enclosure 4.13, step 2.1
- require, two operators to independently visually inspect the valve seat f.
2W-26 and remove any debris, then unlock and close 2W-26. Contrary to the above, on March 23,1989, Pr/2/A/4200/01A was not followed in that the R&R Tag on 2W-26 was cleared although the temperature detector cable had not been removed from the seat of 2W-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 2W-26 prior to closing the valve. These failures contributed to 2W-26 being closed with the cable running through the valve and to a subsequent leak of refueling water causing a resulting radiological hazard during refueling operations.
Item #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 a l
1 gravity fill of the refueling cavity from the Fueling Water Storage Tank. ( Centrary to the above, on March 28, 1989, the licensee failed to establish j 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 the refueling cavity and a spill of approximately 25,000 gallons of refueling water. l l
r RESBONSE: 1. Admission or Denial of Violation Duke Power Company admits the violation. 2. Reasons for Violation if Admitted Item #1 - Operator error, the velve was not recognized to be in the open position nor was the Removal and Restoration Sheet (R&R) checked to see if the valve was positioned from its normal alignment (closed). The operators were draining this line penetration to perform a periodic test. This valve is normally closed but had been opened by an R&R sheet when 2NV-18 (Letdown Heat Exchanger Control Valve) was isolated to repair a bonnet leak. The valve had been backseated open to stop a packing leak. Iko operators attempted to close 2NV-20 by applying pressure to the handt.e in the closed direction. No motion was obtained so both operators concluded the valve was closed. Shortly thereaf ter, the Control Room Operator initiated letdown flow after checking that 2NV-20 was closed. This action pressurized the penetration and approximately 40 gallons of reactor coolant spilled out open vent and drain valves. Item #2 - Operator error, the valve was closed withc,a visually checking for obstructions at the valve seat. The procedure requires two operators to visually inspect the valve seat, remove any debris, unlcck and close the valve. Two operators independently performed this step but did not consider the valve opening to be accessible, therefore the visual verification was not completed. Subsequently, 2W-26 could not seat properly and leaked significantly when the refueling cavity was filled. The leak was reduced to acceptable limits by using an inflatable plug. Item #3 - Operator error, the refueling cavity fill was commenced without anyone assigned to visually monitor the actual level at the cavity. The fill was secured at 93% level due to problems with the containment purge system. After the problems were fixed, the Control Operator resumed the cavity fill to 97%. The Shift Supervisor nor the Unit Supervisor were informed that the fill was restarted. Shift turnover occurred at this time and the fill continued for the turnover time period and beyond but the relieving shift supervision was not aware the fill was in progress. The fill was secured when the Control Room was informed the refueling cavity was werflowing into lower containment. 3. Corrective Actions Taken and Results Achieved Item #1 - A. 2NV-15B was closed to isolate the leak. 2NV-20 was closed and the penetration test completed. i I B. The operators involved were counselled on recognizing valve positions and methods of determining position when in doubt. 1 l 1 ) i 1
/ 4 C. This' incident, and others, were discussed in detail' at a Shift Supervisor's Meating on 5-12-89. The Superintendent of 7 Operations. attended this meeting and discussed methods to ensure procedures were followed. Item #2 - A. An inflatable plug was installed in the valve piping to reduce the leak until the Reactor Vessel head was installed and cavity-drained. B.- The operators involved were. counselled to ensure understanding of visually verifying valve seat inspection. l C. Procedures were enhanced to state specifically which refueling I cavity drain valve seats were capable of being visually inspected. D. This incident, and others, were discussed in detail at a Shift Supervisor's Meeting on 5-12-89. The Superintendent of Operations attended this meeting to specifically discuss 4 adherance to procedures. Item #3 - A. The refueling cavity fill was secured and the cavity drained to below the control rod drive ventilation windows. B. An extensive decontamination cleanup was completed in lower containment. C. A special meeting was held the evening after the spil1L with both shifts involved and station management. This meeting accentuated events leading to the spill, reasons why the spill occurred, and corrective measures to ensure this event did not reoccur. i D. Procedures were enhanced to ensure a person was in the refueling cavity area when the fill was in progress and cavity level was greater than 90%. A level drawing was added to the procedure to correlate level instruments to control rod drive ventilation window height. i E. This incident, and others, were discussed in detail at a Shift Supervisor's Meeting on 5-12-89. The Superintendent of Operations attended this meeting to specifically discuss adherence to procedures. 4. Corrective Actions to be Taken to Avoid Further Violations Actions taken in Section 3. above ensure avoidance of further violatiens. 5. Date of Full Compliance Duke Power Company is now in full compliance, l i
j A ? -l l DUKE POWER COMPANY -REPLY TO A NOTICE OF VIOLATION 413/89-13-04 I 10CFR Part 50, Appendix B. Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a typa appropriate to the circumstances and that these instructions,. procedures, instructions or drawings include appropriate, quantitative or qualitative acceptance criteria for determing 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 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. Item 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 effect, that they have been superseded, yet the modifications are not depicted on the drawings. Further, t the support documents necessary to discern the scope of the modifications are not available in the control room. Contrary to the above, changes to selected control room drawings Item 2 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 "See Interim As-Built" denoting that yet another print reflects the actual plant configuration; b) Selected drawings were stamped "See Interim As-Built" yet there were no applicable Interim As-Built drawings. Contrary to the above, control room drawings do not reflect Item 4 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 control system does not issue drawings to the control room until a modification is complete.
3 6 i< "4'. q g
RESPONSE
1 !1. Admission or denial of Deviation -{ Duke' Power Company admits the violation with res y t to Items'1,'2 L and 4. 2. Reason for Deviation if Admitted l Procedure inadequacy with contributory personnel error. Operations Management Procedure. OMP 1-12 " Operations NSM Implementation Process" was inadequate in that it did not provide: a.. A user friendly method tor.the identification of modifications on Control Room drawings.
- b. -Sufficient guidance on the implementation process and drawing issue for partially completed modifications.
c. Proper guidece fa the stamping and updating of as-built and L interim as bu11r drawings. Personnel error contributed to the deviation in that staff personnel did not consistently provide modification drawings for all of tne Control Room drawings required to be updated per OMP 1-12. 3. Corrective Actions Taken and Results Achieved A plan has been formulated to perform a complete audit and replacement of all Control Room drawings deemed to'be " Vital To Operations'? (VIO). VIO drawings consist of the mechanical flow diagrams, the instrument detail drawings, the electrical oneline diagrams and the electrical elementary diagrams. Modifications to these drawings will be either depicted on the as-built drawing or distinctly referenced to a supplemental drawing file maintained in close proximity to the Control Room drawing set. 4. Corrective Actions to be Taken to Avoid Further Deviations OMP 1-12 " Operations NSM Implementation Process will be Item 1 revised to establish a user friendly method of identifying modifications on Control Room VIO drawings. All changes to the VIO drawings will either be red marked on the current as-built drawing or referenced to a supplemental drawing file, by stamping (SEE INTERIM AS-BUILT) the as-built drawing. Criteria for determining which method to use will be specified in OMP 1-12. The supplemental file will contain only VID drawings. Modification scope documents will not be filed in the Control Room since operator training and procedure changes are made as applicable to provide the operator with required knowledge.
n _-.. l-OMP 1-12 Operations NSM Implementation Process will be Item 2 revised to provide the proper guidance for use of the modification identification stamps and guidance on updating both modification and as-built drawings. In addition appropriate shift and staff personnel will be trained on modification drawing issue and update by completing the Control Room VIO audit and replacement. This intensive hands on task will achieve proficiency in the handling of Control Room drawings, for the personnel involved in this deviation. OMP 1-12 " Operations NSM Implementation Process" will be Item 4 revised to provide guidance to the Operations NSM Coordinator on VID drawing identification and issue based on modification work unit coupletion, rather than entire modification completion. This method ensures that VIO drawings are available in the Control Room at the time a modified system is returned to service. 5. Date of Full Compliance Duke Power Company will be in full compliance by October 1, 1989. l i 4 i 1
RESPONSE TO VIOLATION 413/89-13-04 Example 3 10 CFR Part 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instruction, 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 determining 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. 1 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 required that these measures assure that these documents, including changes.thereto are reviewed for accuracy, approved, and distributed for use to the appropriate location's. 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. 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 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. This is identified as another example of Violation 413/89-13-04: Inadequate drawing controls.
RESPONSE
1. Admission or Denial of Violation Duke Power Company admits the violation. 2. Reasons for Violation if Admitted The drawings in the Technical Support Center were originally provided as an enhancement only. Actual work would not be performed using these drawings. Constant communication is maintained with the Control Room during TSC activation. The Control Room drawings were considered the key drawings for control of activities in an emergency. 1 __.__________________._.-____._._____.__._______-.____________._________._____m_
L l l / l 1 RESPONSE TO VIOLATION 413/89-13-04 Example 3 3. Corrective, Actions Taken and Results Achieved a. An evaluation of this item has been performed. It has been decided that since the drawings are located.in~the TSC they should be updated with Interim hs Builts. b.- Information has been gathered so that the drawings in_the TSC can be updated. 4. Corrective Actions to be Taken to Avoid Further Violations a. Station Directive 2.1.5 will be revised to put the TSC on the Distribution List for Limited Edition Drawings for Code CMD-5. This is the code for the Flow Diagrams. The TSC maintains only flow diagrams rather than the full complement of defined VTO drawings (instrument detail drawings, electrical one-line diagrams and electrical elementaries). This is appropriate since a fully maintained file of these other drawings is available in the nearby document control facility. b. Training will be provided for personnel who are responsible for updating drawings in the TSC. VTO drawings that are maintained in the TSC will c. be brought up to current status with outstanding Interim As Builts. 5. Date of Full Compliance Full compliance will be achieved by 10-31-89.
A RESPONSE TO VIOLATICN 413/89-13-04 Example 5 10 CFR Part 50, Appendix B, Critorion 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 determining 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 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 appro: riate to the circumstances. 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 reficct partially-completed station modifications, even though the plant may return to service. Some partially completed modifications are over 2 years old. CMC drawings are not kept updated in a timely manner to c. reflect completed NSMs. CMC drawings are updated through issuance of Final As-Builts.
RESPONSE
1. Admission or Denial of Violation Duke Power Company admits the violation. 2. Reasons for Violation if Admitted Previously it was determined that the nature and type of drawings availabic at the CMC were appropriate for the circumstances used. This determination was made because the station retains the lead responsibility for accident assessment and plant operations; the CMC supports the station in these functions. CMC personnel do not directly supervisc reactor operations nor the manipulation of controls.
1 ,i RESPONSE TO VIOLATION 413/89-13-04 Example 5 3. Corrective Actions Taken and Results Achieved Discussions with personnel involved have been held to re-evaluate our position in regard to these drawings. It has been decided that drawings that are to be used in the CMC need to be maintained to reflect a more current as-built condition. 4. Corrective Actions to be Taken to Avoid Further Violations a. A complete re-evaluation will be performed to assess what drawings are essential in the CMC. b. Steps will be taken to develop and implement revisions to the existing drawing control program to provide.the essential drawings as "As Built" drawings in the CMC. c. Personnel who will be responsible for implementing this program will be trained. 5. Date of Full Compliance The re-evaluation will be complete by 10-31-89. Full comril&nce of all other action will be compacte by 07-G P-9 0. - _ - _ _ _ _ _}}