ML20209G980

From kanterella
Revision as of 04:40, 5 December 2021 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Responds to Violations Noted in Insp Repts 50-413/86-24 & 50-414/86-26.Corrective Actions:Set of Drawings for Both Units Assembled & Marked for Penetration Identification & Procedure IP/0/A/3240/11 Rewritten & Revised
ML20209G980
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/20/1986
From: Tucker H
DUKE POWER CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8609150125
Download: ML20209G980 (7)


Text

f .

. 1 . f)lf w

DUKE POWER CsOMPANY P.O. HO X 3 3180 CitAMLOTTE, N.C. 28242 HALH.WC =

p

  • 10

. c,WuT L.

BBSEP August 20, 1986 Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Subject:

Catawba Nuclear Station RII:PKV/PHS/MSL 50-413/86-24, 50-414/86-26

Dear Dr. Grace:

Att.iched are our responses to Violation No. 413/86-24-01; 414/86-26-01 and Violation 413/86-24-02; 414/86-26-02, as identified in the subject Inspection

. Report.

Very truly yours.

Hal B. Tucker LPT/14/slb Attachment xc: NRC Resident Inspector Catawba Nuclear Station 1

! 8609150125 86082e PDR ADOCK 05000413 ,3 g G PDR p, q L

,' 'i Duke Power Company Response to Violation 413/86-24-02, 414/86-26-02 A. 10 CFR 50 Appendix B, Criterion V as implemented by Duke Power Company Topical Report Quality Assurance Program, Amendment 9, section 17.2.5 requires that activities affecting quality shall be prescribed by and accomplished with documented instructions, procedures, or drawings and that these procedures  !

include appropriate quantitative acceptance criteria. i

1. Contrary to the above, activities affecting quality were not prescribed by documented procedures including appropriate quantitative acceptance criteria, in that, Performance Test (PT) 2/A/4200/02A, Monthly Outside Containment Integrity Verification, performed monthly on Unit 2 to insure that containment penetration integrity is being maintained, did not include approximately twenty-five (25) vales on various penetrations which were required to be included. This inadequate procedure resulted in a violation of Technical Specification (TS) 4.6.1.1.a for Unit 2 which requires these penetrations to be checked at a thirty-one (31) day frequency.
2. Contrary to the above, activities affecting quality were not prescribed by documented procedures, including appropriate quantitative acceptance criteria in that, PT/2/A/4200/02B, Cold shutdown Inside Containment Integrity Verification, performed to insure the required conditions of penetrations inside containment on Unit 2 were being maintained in their prescribed positions, did not include twelve (12) valves which were required to be included. This inadequate procedure resulted in a violation of TS 4.6.1.1.a for Unit 2 which requires these penetrations to be verified closed during each Cold Shutdown except that such verification need not be performed more often than once every ninety-two (92) days.
3. Contrary to the above, activities affecting quality were not prescribed by documented procedures, including appropriate quantitative acceptance criteria in that, PT/1/4200/02A, Monthly Outside Containment Integrity Verification performed monthly on Unit 2 to insure that containment penetration integrity is being maintained, did not include one (1) valve which was required to be
included. This inadequacy resulted in a violation of TS 4.6.1.1.a for Unit 1.

l

Response

l

1. Admission of Denial of Violation Duke Power Company admits the violation.
2. Reasons for Violation if Admitted Procedure Deficiency. PT/2/A/4200/02A " Monthly outside Containment Integrity Verification" did not include 2BW-26, 2NV-862 and 2NI-3, manually operated isolation valves, in the valve checklist. Omission of these valves resulted in a failure to verify containment integrity per Technical Specification 4.6.1.1.a.

E

,' Y

3. Corrective Actions Taken and Results Achieved 2BW-26, 2NV-862 and 2NI-3 have been added to PT/2/A/4200/02A valve checklist and verified to be in their required position.

The remainder of the valves mentioned in the notification of violation are either vent or drain valves, and are not classified as containment isolations (Reference ANS/ ANSI-56.2-1984). Technical Specifications do not specifically require vent and drain valve position verification to ensure containment integrity but we feel it is prudent to have administrative controls to verify vent / drain valve position. PT/1(2)/A/4200/02A " Monthly Outside Containment Integrity Verification" and PT/1(2)/A/4200/02B " Cold Shutdown Inside Containment Integrity Verification" have been reviewed and the vents / drains associated with penetrations that isolate after an accident have been* included.

4. Corrective Actions A set of drawings for both units have been assembled and marked so that each penetration may be identified with the associated isolation boundaries delineated.
5. Date of Full Compliance Duke Powcr Company is now in full compliance.

l i

i e

I__ __ _ _. . , _ - _ . _ - _ . - - . . _ _ _ _ _ _ - . . _ _ _ _ _ , , . _ _ _ _ _ _ _ - - _ _ _ _ _ . . . , , _ . ~ . _ . _ _ _ _ _ _ . _ .

Duke Power Company Response to Violation 413/86-24-01, 414/86-26-01 B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Revision 2.

1. Instrumentation Procedure (IP) 0/A/3240/11, Excore Nuclear Instrumentation System, step 10.1.6 requires the instrument (IAE) technician to request the Operator at the Controls (OATC) to turn the S/G Program Level Setpoint Indicator Switch to a channel other than the one being adjusted.

Contrary to the above, on June 12, 1986, this step was not performed by the IAE technician while aligning nuclear instrumentation. The failure to perform this i step resulted in a reduction of feedwater to the steam generators causing a low-low level in the IB steam generator and a resultant reactor trip.

Response

1. Admission or Denial of Violation Catawba admits this example of the stated violation.
2. Reasons for Violation if Admitted Personnel Error - The violation occurred when a technician performing IP/0/A/3240/11 failed to perform steps 10.1.6 and 10.1.7 of IP/0/A/3240/11.
3. Corrective Actions Taken and Results Achieved IP/0/A/3240/11 has been rewritten and reissued requiring individual sign-offs for those steps that could result in unplanned plant transients.
4. Corrective Actions to be Taken to avoid further violations The technicians involved in this incident have been counseled in adherence to written procedures.
5. Date of Full Compliance Duke Power Company is now in full compliance.

r

's Duke Power Company Response to Violation 413/86-24-01, 414/86-26-01 B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Revision 2.

2. Station Directive 3.2.2, Development and Conduct of the Periodic Testing Program, Section 8.0 requires that after a valve has undergone maintenance and prior to its return to service, it shall be tested as necessary to demonstrate that the parameters affected by the maintenance are within acceptable limits.

Contrary to the above, 2CF-33, 2CF-60, and 2CF-87 were repaired and returned to service on May 17, 1986, without being tested to demonstrate that the parameters affected were within acceptable limits.

Response

1. Admission or Denial of Violation Duke Power admits this example of the stated violation.
2. Reason for the Violation, if Admitted Personnel Error - The job supervisor mistakenly signed off the work request as being complete without ensuring that the retest requirement indicated on the work request had been met.
3. Corrective Steps Taken and Results Achieved Valves in question were successfully retested on June 3,1986.
4. Corrective Actions Nuclear Production Department M/M Job Supervisors are being retrained in the use of MMP 1.0, which outlines the requirements for retest as set forth in S.D. 3.2.2.
5. Date of Full Compliance Duke Power Company will be in full compliance by September 1, 1986.

l l

E

( .

Duke Power Company Response to Violation 413/86-24-01, 414/86-26-01 B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Revision 2.

3. Operations Management Procedure (OMP) 2-29, Technical Specifications Logbook Section 3.3.B requires inoperable equipment that causes operation in an ACTION statement for the existing mode shall be logged in the Technical Specification Action Item Logbook (TSAIL).

Contrary to the above, inoperable equipment was not logged in the TSAIL, in that, work requests 31838 OPS, 31841 OPS, 32033 OPS, end 32046 OPS were processed on May 14, 1986 and no log entry made. This contributed to the valves associated with these work requests being returned to service without required functional testing being performed.

Response

1. Admission of Denial of Violation Duke Power Company admits this example of the stated violation.
2. Reasons for Violation if Admitted Personnel Error - The Unit Supervisor that approved the work to begin failed to note that the work request indicated that functional retesting was required and therefore did not make the proper TSAIL entries. Also, the Unit Supervisor that approved the work failed to note the lack of retesting, and in effect, placed the valves in service without insuring the parameters affected were within acceptable limits.
3. Corrective Actions Taken and Results Achieved i
a. Systems placed in condition to perform the required retests.

! b. Retests of applicable valves performed.

! c. Retest satisfactory for each valve.

d. Discussed, in detail, evolution of problems encountered with Unit Supervisors involved.
e. Discussed violations with all Shift Supervisors at Shift Supervisor's
Meeting on May 30, 1986.
4. Corrective Actions l Actions taken in Section 3 should ensure avoidance of further violations.
5. Date of Full Compliance Duke Power Company is now in full compliance.

i

r 3' et*

Duke Power Company Response to Violation 413/86-24-01, 414/86-26-01 B. Technical Specification 6.8.1 requires that written procedure shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory guide 1.33, Revision 2. Mechanical Maintenance Procedure (MNP) 1.0, Work Request Preparation, paragraph 4.3.10 states that the section of the work request entitled " Procedure Numbers" shall reflect a complete listing of procedures used as it serves as reference in the history file.

4. Contrary to the above, the " Procedure Numbers" section of the work request identified did not contain a complete listing of procedures, in that the required procedures for testing af ter maintenance were not identified. This failure to follow MMP 1.0 contributed to returning the above listed valves to service without the required functional testing being performed.

Response

1. Admission or Denial of Violation Duke Power denies this example of the stated violation.
2. Reason for denial The Planner met the requirements identified in Station Directive 3.3.2 Section 2.3. Section 4.3 of MMP 1.0 was used by the Planner to outline pre-maintenance requirements for above listed valves that included procedures needed to perform necessary repair / maintenance. Additionally, the Planner identified the group responsible for performing the testing l and/or functional verification. The group that is identified is responsible for confirming that the retesting is required and for identifying procedures necessary to satisfy the retest and/or functional verification requirement.
3. Corrective Actions Taken and Results Achieved The Planner identified the requirements for testing and/or functional verification, and the responsible group, in Section II of the work request.
4. Corrective Actions MMP 1.0 Section 4.3 will be reviewed and evaluated, Paragraph 4.3.10 will be clarified to establish that the Procedures listed in Section II of the work request under " Procedure Numbers" are for maintenance / repairs, and l

that any retest procedures will be listed by the responsible group in I Section VIII, "Other Procedures".

I l 5. Date of Full Compliance Duke Power Company is now in full compliance. The clarification of Paragraph 4.3.10 will be completed by September 30, 1986.

.-