ML20248J463
| ML20248J463 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/31/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904140435 | |
| Download: ML20248J463 (4) | |
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lDSeItwer Company J
- flit a Tucker
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. Vice President PO Bar33198.
Charlotte, N.C 28242 Nuclear Production J'
(704)373 4531--
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-March 31, 1989 U. - S.' Nuclear Regulatory Commission Washington,: D. -.C.
20555 Attention: Document Control-Desk
Subject:
Catawba Nuclear' Station, Units 1 and 2 Docket Nos.-:50-413 and 50-414.
- NRC Inspection Report No.-50-413, -414/88-38 Reply to a Notice ~of' Violation.
Ge' ntlemen:
Please find: attached a. reply'to violation No. 413/88-38-02 and 413, 414/88-38-05.
transmitted per Malcolm L. Ernst's, NRC Region II, Notice of Violation.-dated March: 2,1989. These Severity Level IV violations. involved' inadequate
- administrative measures.to. ensure acceptable levels 'of cleanliness for the VX fan a
pit' drain and failure to perform a 50.59 safety evaluation on IRN-244,-Control
- Room area chiller condenser "A" Automatic Flow Control' Valve.
Very truly.yours, af y l'
H. B. Tucker-IERPT-7/lcs.
Attachment xc: Mr. S. D. Ebneter Regional Administrator, Region II U.
S.' Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr.'.W. T. Orders NRC Resident Inspector Catawba Nuclear Station fk gI
'8904140435 890331 PDR ADOCK 05000413 Q
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I DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/88-38-02 l
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.
Station Directive 3.11.1, Housekeeping and Cleanliness Levels in Safety and Non Safety Related Areas, requires Level IV cleanliness in the Reactor Building and that Level IV cleanliness be obtained by removal of all dirt and debris from the area.
Contrary to the above, administrative measures in effect were inadequate to ensure acceptable levels of cleanliness in the vicinity of the Containment Air Return Fan (VX) pit drain in that on January 26, 1989, the Unit 1 pit drain was observed by NRC inspectors to be partially obstructed with debris.
An obstructed drain would render both VX fans inoperable in that following a loss of coolant accident (LOCA), containment spray flow into the pit would eventually flood out the fans.
This is a Severity Level IV violation (Supplement I) and applies to Unit 1.
RESPONSE
1.
Admission or Denial of Violation Duke Power Company admits the violation.
However, it should be clarified that, contrary to the implication of the Notice of Violation, at no time was the operability of the VX System challenged, nor would it have been with the existing cleanliness controls.
The design of the drain cover is such that any debris capable of entering below it would be incapable of obstructing the drain itself.
The small amount of debris (small pieces of cloth and tape) which did accumulate below the plate should be considered in light of ECCS operability (reference specification 4.5.2.C) rather than VX fan operability.
2.
Reasons for Violation if Admitted Procedures are in place which verify housekeeping in the VX fan pit, however, the need to disassemble the drain cover was not previously identified.
3.
Corrective Actions Taken and Results Achieved Drain covers were removed and inspections performed on both Unit 1 and Unit 2.
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l Response to Violation 3.413/88-38-02 Page 2 4.
Corrective Actions to be Taken to Avoid Further Violations l
The drain cover will be removed and reinstalled per a standing work request (SWR) to be initiated by the Maintenance Engineering Services group.
This SWR will be included on the Mode 4 checklist to be completed prior to entering mode 4 after refueling.
An inspection will then be performed in conjunction with' Technical Specification surveillance 4.5.2.C.1.
5.
Date of Full Compliance Duke Power Company will be in full compliance prior to Unit 2 startup from the present refueling.
The SWR for future Unit 1 outages will be initiated by July 1, 1989.
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/414/88-38-05 10 CFR 50.59 requires the licensee to perform a written safety evaluation which provides the bases for the determination that a change in the facility as described in the safety analysis report does not involve an unreviewed safety question.
Contrary to the above, on December 18, 1988, the licensee determined that 1RN-244, Control Room Area Chiller Condenser "A"
Automatic Flow Control Valve, was not functioning to automatically control flow, chose not to declare the associated equipment inoperable, and failed to perform a written safety evaluation to provide the bases for the determination that operating 1RN-244 fully open with the actuator removed, a change in the facility as described in section 9.2.1.2.3 of the Final Safety Analysis Report, did not involve an unreviewed safety question.
This is a Severity Level IV violation (Supplement I).
RESPONSE
1.
Admission or Denial of Violation Duke Power Company admits the violation.
2.
Reasons for Violation if Admitted This violation was caused by inadequate management controls of VC/YC System work.
The personnel involved had evaluated that valve 1RN-244 is designed to " fail" open thus ascertaining that this was its safe position.
The need to I
document this evuluation in accordance with 10CFR50.59 was not recognized.
3.
Corrective Actions Taken and Results Achieved Subsequent review by Design Engineering Department personnel confirmed the operability of the VC/YC System.
1RN-244 has l
since been returned to fully operable status.
4.
Corrective Actions to be Taken to avoid further Violations j
More experienced personnel have been assigned oversight responsibility for VC/YC concerns until equipment performance improves.
One of these individuals currently holds an SRO.
The Station Manager will determine a time at which this program will be returned to normal supervision.
i 5.
Date of Full Compliance Duke Power Company is in full compliance.
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