ML19354E111

Forwards Supplemental Response to Violations Noted in Insp Repts 50-413/89-14 & 50-414/89-14.Corrective Action:Station Directives 3.11.1 & 3.11.3 Revised to Provide Guidance to Station Workers to Identify & Protect Components

ML19354E111
Person / Time
Site:	Catawba
Issue date:	01/11/1990
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9001250405
Download: ML19354E111 (5)

Text

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DukeIbuer 0;mpany PO Box 33198 .

Ha B han Vice President

-. . Charlotte, NC 28242 Nuclear Production (704)373 4531

.. DUKE POWER.

January:11, 1990

- U..S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

~ Catawba Nuclear Station Docket Nos. 50-413 and-50-414 NRC' Inspection Report Nos. 50-413 414/89-14 ~

Submittal of Supplemental Response and Request for Extension ~of Full Compliance Date Gentlemen:-

Enclosed is a supplemental response for the Notice of Violation 50-413, 414/89-14-02 issued June 21 1989'by C. A. Julian. ~The violation'was for-failure to provide procedural instructions regarding protection of. permanent plant. equipment. The original response to Violation:89-14-02 dated July 21, 1989 conunitted to full- compliance by October 31, 1989.

It has been determined that additional-time is-neededito complete station

-- employee and vendor. training on recent changes in Station Directive 3.11~.1 and 3.11.3 concerning the protection of station equipment..:This training.

will be incorporated into the annual' Health ~ Physics. training program and,.

based on-current training schedules, all station'einployees and. vendors will receive training by December 31,-1990 In addition,~ effective January 27,:1990,- actions.will'hava,been;taken to identify, control.and monitor..high traffic areas and:special' activities-during outage periods:to assure adequate protection of station equipment.- A baseline listinF of components requiring protection during outage' activities will be developed during a containment walk-through inspection at-the:

beginning of the'U1EOC4 outage scheduled:for January 26, 1990 and.the U2EOC3 outage' scheduled for. June 1 15, 1990. ,

An extension of the full compliance date to December 31, 1990 is requested.

Very truly yours,

" g:t h,^ O e -

Hal B. Tucker WRC108/lcs 1 f 01 2 9001250405 900111~ ' il* .,

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L. .1 = Page ' 2 : ' 1 lxet- Mr. S. D.' Ebneter, Regional Administrator

.U.? S. , Nuclear Regulatory Commission '

• Region' II -

4 101 Marietta. Street, NW, Suite 2900 .

Atlanta.LGeorgin' 30323-i,

'Mr.-W.~,T.-Orders NRC Resident'. Inspect r *

-Catawba Nuclear Station 1.,

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~.: 4 DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION-413, 414/89-14-02' VIOLATION:

Section 6.8 of the Catawba Units 1 and 2 Technical Specifications requires that written procedures shall.be established and maintained covering the procedures recommended in Regulatory Guide 1.33 Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2 endorses ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power-Plants," which states, in part, the " Areas of activity'shall be. adequately lighted, ventilated,

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protected, and accessible as appropriate for the work being performed"; and that " Adequate working space shall be provided where possible utilizing proper work stages and platforms having accessibility by stairs or ladders."

Further,10 CFR 50, Appendix B, Criterion II states, in part "The Quality Assurance program shall provide control over activities affecting the quality of the identified structures, systems and components to an extent consistent with their importance to safety." The above encompasses the requirement'that installed equipment vital to safety be protected against damage from personnel climbing or walking on this equipment. This equipment-includes small-bore piping, instrument air lines, electrical cable, and the like.

Contrary to the above, specific procedural instructions regarding protection of permanent plant equipment were not adequately addressed by Catawba quality assurance procedures. This was evident when NRC inspectors witnessed personnel in the Unit 2 containment walking and-climbing on  ;

safety-related equipment, during inspections conducted March 13-31, and; April 24-28, 1989. This equipment included small bore piping, instrument lines, small-bore pipe supports, small valves, and cable trays. Damage to .l some of these systems, if related to operation of safety-related equipment  !

could pose a significant safety hazard. l l

This is a Severity Level IV violation (Supplement I). j i

RESPONSE

1. Admission or Denial of the Violation:

Duke Power Company admits the violation.

2. Reason for Violation i i

The reason for the violation is specific written guidance has not been . y provided to personnel for accessing equipment in congested areas of the plant. Guidance has been provided personnel in safety meetings and' '

training classes warning personnel to ensure that care and caution ,

should be used when accessing equipment in congested areas of the plant.

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DUKE POWER COMPANY'

j. .. REPLY TO A NOTICE OF VIOLATION

! 413, 414/89-14-02

3. Corrective Actions Taken and Results Achieved:

Station Directives 3.11.1 and'3.11.3 have been revised to provide' '

. guidance to station workers to identify and' protect-components in their work area and in their travel paths as well-'as to provide for identification and repair of any damage to components during normal- :r housekeeping inspectious.-

4. Corrective Actions to Be Taken to Avoid Further Deviations:

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l a. Station Training Programs will be revised as follows:

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I 1. Initial Training will be given to all station employees by l December 31, 1990 detailing each individual's responsibility for I

the protection of station equipment including the recent changes in Station Directive =3.11.1 and 3.11.3. -This training will l become a part of the annual Health Physics training program.

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2. Training will be repeated on an annual bases for all staticn employees and shall be a part of the annual Health Physica training program.

3. Training for all new. employees will-be a part of their initial Health Physics training.

4.

l Prior to the beginning of the U1E004 outage, scheduled for l- January 26, 1990, training will be given.to necessary outage i support personnel concerning each individual's resoonsibility to protect station equipment during outage activities.

b. Prior to the beginning of the U1E004 outage, scheduled to, start January 26, 1990, actions will be taken that willLidentify, control, ,

and monitor high traffic areas and special' activities during outage periods to assure adequate protection of small bore' tubing / piping, snubbers, instruments, and electrical' trays. These actions will include:

1. Establishing a baseline listing of components that need to be protected each outage due to their location (high traffic area) and updating that listing as new situations arise.

(Responsibility: Integrated Scheduling) '

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2. Assigning job sponsors-the responsibility for determining the '!

need for equipment protection as a part of their pre-outage.

praparations and providing that input for scheduling of the activity. (Responsibility: Maintenance Engineering Services)

3. Assigning responsibility for the erection of temporary

[. . shielding, scaffolding or platforms within the Maintenance group.

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DUKE POWER' COMPANY'  ;

. - REPLY TO A NOTICE OF VIOLATION 413,.414/89-14-02 q 1

'4. The initial' baseline listing will be developed from a H containment walk-through inspection at the beginning of U1E004-and U2EOC3 outages.' The walk-through inspection will be; .

coordinated by the Compliance Group and will inc'lude ,

representatives from the-following station groups: Maintenance j Engineering Services, Integrated Scheduling, Instrument and Electrical, Mechanical Maintenance. Construction and Maintenance Department,- Operations, Projects, Safety, and Radiation Protection. I

5. Components identified as requiring protection by outage support personnel during U1E004 and U2EOC3 outages will be1 evaluated by 1 the Maintenance Engineering Services Section and appropriate.

equipment protective measures will be implemented. -;

5. Date of Full Compliance:

Duke Power will be in full compliance by December 31, 1990. *I

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