ML20024H762

Responds to Violations Noted in Insp Repts 50-413/91-09, 50-414/91-09,50-413/91-11 & 50-414/91-11.Corrective Actions: Operators Will Be Trained on New Procedures Re Operations Involving Shared Essential Switchgear by 911031

ML20024H762
Person / Time
Site:	Catawba
Issue date:	06/05/1991
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9106100424
Download: ML20024H762 (6)

Text

-J Il I in , , Il d ll }t,r+>

I D li < l a s  % *5..a l? , it

. v,.,c. i1 - +

' lob l 1 a ll ouxe rowen June 5,1991 U. S. Nuclear Regulatory Cornmission A'ITN: Document Control Desk Washington, D.C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413, 414 NRC Inspection Report Nos. 50-413,414/91-09 and 50-413,414/91-11 Violations 50-413/91-09-01,50 414/91-09-02, and 30-413/91-11-01 Reply to a Notice of Violation Enclosed is the response to the Notice of Violation issued May 6,1991 concerning the failure to correctly perform electrical alignment resulting in the RN system being inoperable and inadequate work request instructions resulting in personnel potentially degrading the safety related function of the 2B Ni purnp room's ventilation system. The response to Violation 413/91-09 01 also addresses a similar violation (413/91-1101) issued May 21,1991 concerning failure to realign essential power supplies when removing the IB Diesel Generator from service. (See item B of the 413/91-09-01 response.)

Very truly yours, M PA L Hal B. Tucker RES/91-09 Attachment xc: Mr. S. D. Ebneter Regional Administrator, Region 11 Mr. W. T. Orders Senior Resident Inspector l

Mr. R. E. Martin, ONRR 9106100424 910605 PDR AItOC K 05000413 O PDR Y$0/

sp

DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION l 413/91-09-01 Technical Specification 3.7.4 requires that two indopondent nuclear servico water (RN) loops be operablo with cach loop containing two operablo RN pumps and associated emorgency i diesel generators (D/G), two essential supply and roturn headers, and a flow path capable of being aligned to the Standby Nuclear Servico Water Pond (SNSWP) when both Units 1 '

and 2 are abovo Mode 5, cold Shutdown. With only one Unit above Modo 5, the two independent RN loops are required to be operablo with each loop containing one operable RN pump and the before montioned equipment associated with the operating Unit. If the Limited Condition for Operation (LCO) cannot be mot, operability is to be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or the unit (s) must be placed in Mode 3, Hot Standby, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in-Mode 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering in part the operation of the cmorgency olcctrical I power sources and the service water system. Operating l Procedure OP/1/A/6350/02, Diesel Generator Operation, l Enclosure 4.13, Stop 2.7.1 states, " Ensure motor control conter (MCU) 1EXMG is being fed from 2ELXA".

Contrary to the abovos A. On March 23, 1991, a Catawba non-licensed operator, when diosol generator lA was being removed from service, failed to ensure that motor control centor MCC lEMXG was being fed from Unit 2 load conter 2EXLA in order to supply power to critical RN valves shared betwoon both units. Failing to perform this electrical alignment resulted in the A train of RN being inoperable on both Units 1 and 2 in excess of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement.

B. On April 18, 1991, while re*urning 1B D/G to service, the operator failed to align the system according to OP/1/A/6350/02. 2EMXH poWor supply was being supplied from Unit 1 in which 1B D/G was inoperable. 2EMXH should have been on a Unit 2 power supply.

l

RESPONSE

1. Reasons for Violation if Admitted Item A.

This incident was attributed to Inappropriate

Action in that the Non-Licensed Operator (NLO) and-( Operator at the Controls (OATC) misread the Operator l

Aid Computer.(OAC) graphics while verifying the alignment.of IEMXG to 2ELXA.

Page 2 Item B.

The operators involved determined that the D/G in question was not inoperable per Technical Specifications, therefore it was decided that there was no need to swap 2EMXH power supply to another D/G.

However, the procedure flow path will be enhanced.

3. Corrective Actions Taken to Avoid Further Violations Item A.

Operations personnel aligr'.ed lEMXG to 2ELXA.

Operations personnel initiated W/R 482550PS to investigate and OAC graphics.

Operations personnel initiated W/R 491670PS to investigate and repair 1.47 aypass Panel.

A damaged 1.47 Bypass terminal was discovered and repaired by the Instrument and Control section.

Operations emphasized through an operator update that the OAC graphics should not be used for procedure sign-offs.

OMP 2-33 was revised to specify that procedures should not be completed by determining a breaker's position from the OAC indication or graphics unless the procedure specifics.

Item B.

This incident was discussed by management with individuals involved.

3. Corrective Actions to be Taken to Avoid Further violations Item A.

Evaluate the OAC graphics accuracy and establish a schedule to implement appropriate enhancements to include control of OAC changes and logic verification, if needed, by 3/1/92.

Evaluate and provide enhanced training on the OAC policy, use, indications, and limits of the OAC by 9/30/91.

Item B.

Operations procedures which deal with inoperable Digs and RN pumps will be revised as necessary to ensure that essential power supplies are aligned to an operable D/G prior to rendering D/G inoperable. This is to be completed by 8/31/91. ,

)

Page 3 The operators will be trained on the recent proceduro changes and philosophy associated with the operations involving shared essential switchgear by 10/31/91.

4. Date of Full complianco Duke Power is now in-full complianco.

l ra-~,v.-, y---,,+wse * <w v.-wv,-.v,re-r-.-e.-ect-e- ,- ., . . , - - ,y,--+.~,,,.,-wy-r-,rw,- =cw-,v.m .--w, m-- ,,w.n--- r,y-rwy * *v4, y a

DUVE POWER COMPA!W

. Reply TO A NOTICE OF VIOLATION 413/91-09-02 10 CFR 50 Appendix B, Critorion V, as implemented by Duko power company, Topical Report, Quality Assurance Program (Duko 1-A, Amendment 11) Section 17.2.5 requirou that activities affecting quality shall bo prescribed by instructions, procedures, and drawings include appropriate quantitative or qualitet iva acceptance critoria for determining that important activities are satisf actorfly

. accomplished.

Catawba Nuclear Station Directive 3.3.7, Work Request Origination, Section 4.0, administration of Work Control System,, Step 4.2, requires personnel initiating a work request to supply complete, accurate, and legible information.

Contrary to the above. the instructions provided in Work Request No. 7466PRF, written to seal penetrations in the walls of Unit 2 ECCS pump rooms, were inadequate, in that personnel following the instructions on April 4,1990, taped the openings of the Auxiliary Ventilation exhaust ducts in the 2B Safoty injection pump room, degrading- the safety-related function of the room's ventilation system.

EESPONSEt

1. Reasons for Violation if Admitted The - flow on the VA ( Auxiliary Ventilation System) system for the LOCA (Loan of coolant Accident) alignment was lowered in order to ensure the heaters on the VA filtor units would keep the relative humidity of the incoming air below 70 percont. This was due to the heaters being undersized when the plant in in a degraded voltage condition.

At the reduced flow, it was thought that it would be difficult to verify that the ECCS (Emergency Coro Cooling System) pump rooms would be under a l-negativo pressure sinco the pump rooms have a multitudo_.of penetrations that are opened. - The method used to verify negative pressuro at each room is by using a smoke stick und verifying that the smoke flows into each room via the door grills. In order to obtain adequate results to the negative pressure test in this reduced flow condition, it was decided to seal up all the penetrations which would allow air to enter the rooms.

This would cause the air to enter the rooms only through the door grills.

To seal up all the. penetcations would tako an enormous amount of - time.  !

Because of this, the decision was made to soal up all the-rooms witti tape and then come back after the flows were reduced and seal the penetrations

- permanently. ' Af ter the rooms were taped up, the flows from the pump rooms were reduced by using a manual volume damper. To ensure that the tape was placed properly, the system was tested. The test results showed inward  ;

flow to each pump room and proper air flow through each filter unit.

After the test was complete, it was thought that the work on the penetrations would start. Because the penetrations wore _ going to be sealed up permanently under the work request, a TSM (Temporary Station

-Modification) was never installed. The work never began be:- oe of

-.-.--L.L----.--.-.___.--..--.--.-.-.-..-.---.

f*

e t

problems with obtaining td'e required manpower for the job. But in lievernbor, it was determinea that a TSM was not needed because the system was capabk of producie.g a ner.tivo pressure in the rooms while hoving a lar(t N '.e procont.

A rc. t. 3 sycom u as performed af ter the work was completed on April 5, 19s v sch showed t}.at the system could perform its cafety function.

T* sp' i ' a becn toc m3 3 titi> , rir.r to the discovery of tapo being on the ve.. '. *he 2B

( S t.. w t + lt section Systom) pump room with r.. t '.c f act< .y t si'l m . A T'. M shos ) have been put in placo to control the te.r.t vnlil ' t wat determir.ed . hat tho tspo was not needed to maintain the syn.tein oporn n . !Mtu .twer Ccenany admits the violation due to not prope. ly t -ing the To:rpot ry Otath,n Modification process.

2. Correct! ,e Actions Tak g <r.1 3esalts Achieved

a. Negative pressure was . rified in the 2B til Pump Room.

b. Tape was removed from the duct and a negative crosauro was verified in the rooms along with proper flow rate to the filter unit.

c. Tape was removed from the 2B HI pump Room walls and a negativo pressure was verifind in the rooms along with proper flow rate through the filter unit.

3. Corrective Actions to bo Taken to avoid further Violationn

a. The ECCS pump rooms will be serlod up permanently by 5/1/92.

b. Tho ' REM process will be reviewed with appropriato performanco Section personnel by 7/31/91 to ensure that the process is used correctly.

4. Date of Full Complianen Duke power Company in currently in full complianco.

_ _ _ _ _ _ _ _ _ _ . - - _ _ - - _. - _ - - . _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ - _ _ - - - _ - _ _ _ -