ML20043G072

Responds to NRC 900510 Ltr Re Violations Noted in Insp Repts 50-413/90-09 & 50-414/90-09.Corrective Actions:Vc/Yc Train a Returned to Svc W/Supply Power from 2ETA.Terminal Box 1TB0X0346 Inspected & Insured Operable

ML20043G072
Person / Time
Site:	Catawba
Issue date:	06/07/1990
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006190022
Download: ML20043G072 (7)

Text

i

% .4

~*

' Duke Ibuer Company Hu R han

. PO Bat 33198 ike President

- Ctaniotte, N C 28242 Nuclear 1%Juction (701)373 1531 ,

DUKE POWER June 7, 1990 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,.D.C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report Nos. 50-413 and 50-414/90-09 Reply to a Notice of Violation Gentlemen:

Enclosed is the response to the Notice of Violation issued May 10, 1990 by Alan R. Herdt concerning inadequate procedures and failure to follow procedures.

Very truly yours, e

W N / /$ ' f llal B. Tucker WRC/161/lcs Attachment xc: Mr. Stewart D. Ebneter Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta St., NW, Suite 2900 Atlanta, Georgia -30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station i

9006190022 900607 PDR ADOCK 05000413' Q PDC O

'\\

t I

DUKE POWER COMPANY REPLY TO A NOTICE pF VIOLATION 413/90-09-01 i

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.

Implicit in this is the stipulation that the procedure be adequate for the task being performed.

Station Directive 3.1.14, Operability Determination, requires that if responsible personnel believe a component operable but have concerns relative to its continued operation, necessary actions shall be taken expeditiously to resolve the concerns and confirm operability. These actions include the performance of an engineering evaluation.  ;

contrary to the above: j A) On March 23 1990, an operator failed to follow procedural requirements while performing OP/0/A/6450 '11, Control Room Area Ventilation / Chilled ,

Water System, Enclosure 4.8, Shifting Power Supplies on i control Room Area Chiller's, item 2.2.4, in that he lifted the power lead to the running chiller which placed the Unit in T/S 3.0.3.

4 B) Test procedure IP/1/A/3231/01, Incore Thermocouple and RTD Cross Calibration, was inadequate in that on April 9,: 1990, performance of the test resulted in the ,d licensee rendering all four channels of ESF instrumentation required for Mode 3 operation inoperable.

C) Surveillance procedure PT/1/A/4200/09, Engineering Safeguards Features Actuatio.' Periodic Test, was inadequate in_that it failed to provide the necessary.

steps to ensure that the resulting injection flow through 1NI-9, Centrifugal Charging Pump Cold Leg i Injection Isolation Valve, did not result in excessive temperature changes to the pressurizer. As a result of the procedure inadequacy, on March 25 and 26, 1990, the pressurizer was subjected to two cooldown transients which exceeded 200 degrees F in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and two subsequent heatups which exceeded 100 degrees F in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

D) On March 25, 1990, following a rapid cooldown and heatup of the pressurizer, which exceeded T/S allowable limits, the Shift Supervisor failed to take action to initiate an engineering evaluation to determine the effects on the structural integrity and' acceptability for continued operation of the pressurizer. This l

n

~ .

e O' Page 2 contributed to a decision _to continue with testing in progress which resulted in a second similar pressurizer transient on March 26, 1990, which again exceeded the '

cooldown and heatup limits.

RESPONSE

1. Admission or Denial of Violation Duke Power admits the violation.

2. Reasons for Violation if Admitted Item A. This incident was attributed to Inappropriate Action for entering the incorrect terminal box due to a lack of attention to detail. Also, this event was attributed to a Deficient. Procedure in that an independent verification was not required to insure the proper equipment was being affected.

Item B. The procedure was inadequate in that it did not provide' sufficient guidance to the test coordinator to mitigate the consequences of a-test equipment failure, or to provide adequate cautions-concerning inadvertent actuations of the P-12 interluck. This deficiency led up to the event where a test equipment failure caused a P-12 actuation while the test was in progress.

At the time the procedure was originally prepared in 1983, using Westinghouse Start-up documents as a reference, it was written such that all four channels of T-AVG instrumentation were tested simultaneously. The station review-committee concurred with this-method, recognizing that such a test configuration-did not meet the minimum channels operable requirement, but did allow continued operation under the ACTION statement for the instrumentation. The procedure was NOT inadequate in that it allowed all four channels to be removed from service concurrently.

This procedure did NOT cause the licensee to unknowingly enter T/S 3.0.3. The procedure was written such that the ACTION statement for T/S

-Table 3.3-3, Item 18e would be entered during the brief (15-minute) test duration.

OQ

+ .

. : +

. f Page 3 Item C. This ir.cident was attributed'to a Management

& Deficiency; a revision of the test procedure was-Item D. not prepared to address the potential impact of the injection on pressurizer temperature.. A second injection occurred as a result of an Inappropriate Action in not performing an appropriate engineering evaluation after the first  !

injection.

3. Corrective Actions Taken to Avoid Further Violations and the Results Achieved item A. VC/YC-Train A was returned to service with supply power from 2 ETA.

Work Request 463850PS inspected terminal box 1TBOX0346, and insured it was operational.

Work Request 463840PS replaced the 2ETB-17 breaker with a spare.

VC/YC Trains A and B were swapped to their Unit 1 supply power to support ESF testing.

Additional tags were placed on terminal boxes 1TBOX0345 and 1TBOX0346 front panels to. insure the i related equipment and train can be identified.  !

The procedure-for manipulation of VC/YC chiller power supplies has been revised to require an independent verification that the correct terminal box is being entered.

Testimonial presentations to each operations shift were made by one of the involved individuals.

These talks covered the circumstances of the event, the corrective actions taken, and the lessons learned.

Item B. The test procedure and the associated incident were reviewed to determine the root cause of the incident. It was determined that a procedure revision allowing testing of only one temperature .

channel ~at a time would have prevented the inadvertent actuation of the P-12 interlock when the test equipment problem occurred.  ;

It was also recognized that a revised test method which would require verification of test inputs as  !

they are injected would have prevenced this incident.

1

, ;i Page 4 j Item C. CR0s closed 1NI-9A to terminate injection flow.

Item D. PIR 1-C90-0099 was initiated to request Design Engineering evaluation of the recorded pressurizer temperature data.

Westinghouse initiated an evaluation of the data and concluded that the design life and the pressurizer structural integrity were not compromised. Design Engineering' concurred that continued operation was acceptable.

The ESF test procedure was revised'to remove power from NI-9A or NI-10B-to' preclude their opening during testing of their respective train. The valves are now tested outside of the main LOCA or Blackout test to preclude further injections.

Operations shift personnel reviewed this event with emphasis on:

- The need to request appropriate support for evaluation of plant transients;

- The need to keep Performance Test Coordinators informed of abnormalities; i

- Limitations on the cooldown of pressurized vessels: with respect to thermal shock and stress -!

minimization.

i

4. Corrective Actions to be Taken to Avoid Further Violations Item A. The locks on terminal boxes 1TBOX0345 and '

1TBOX0346Lwill be used such that different keys will'be required for each box to prevent inadvertent entry into the incorrect box.

(Operations)

Operating procedures will be reviewed for similar activities where electrical leads are being disconnected or swapped. Procedures will be revised.to include independent verifications to ensure the proper equipment is being entered.

This evnluation will identify additional safety measures that could be applied to prevent the cause and consequences of pulling an energized electrical lead when all administrative controls fall.

(Operations)

s t Page 5 -;

Item B. Test-procedures IP/1/A/3231/01 and IP/2/A/3231/01 will be revised to

a. Take only one channel of ESF instrumentation out of service at a time,

b. Provide explicit. cautions associated with-the P-12 interlock. The procedure already contains cautions associated-with the Lo-Tavg interlock with feedwater isolation. Cautions-about the P-12 interlock would increase the awareness of the test coordinators and the control room operators.

c. Provide a method to verify test inputs as they are. injected. The procedure will specify that the temperature indication must be observed on control board meters as each test signal is injected to ensure that the test equipment is functioning properly. The procedure will include a' method to remove RTD's from service one channel at a time,

d. Provide information to the Operators ,

regarding operability of affected instrumentation in a readily understood format. While the existing procedure did specify the appropriate T/S associated with the P-12 interlock, it could have been better '

clarified. In the. revision to be made, a description of the T/S will be added and1the format will be changed to specify affected T/S's individually, rather than in a list.

(MES)

Item C. Westinghouse will complete and send to Duke Power

& more detailed engineering evaluation including Item D. i.tigue and fracture analyses to determine the ap,wific effect of this type of pressurizer. 1 g :coldown on the design life of the plant.

(Design / Westinghouse)

The revised ESF test procedures will be reviewed with Operations personnel in a tailgate session-prior to using this procedure in the upcoming Unit 2 outage.

L (Performance)

Performance personnel with the assistance of -!

Operations will incorporate this event into the 2 year review cycle of test procedures. The.special

Page 6 measures / actions needed to control-plant conditions, including test termination criteria and actions will be incorporated at that time.

(Performance)

Other procedures for tests' involving the potential for water injection to the primary coolant system in modes 1-4 or where there is the potential for a hot pressurizer will be reviewed to ensure adequate precautions and-guidance are given to-control plant conditions and modes.

(Performance)

5. Date of Full Compliance Duke Power will be in full compliance by 10/31/90 except for the corrective action of Performance personnel with the assistance of Operations incorporating this event into the_2 year review cycle of test procedures. The special' measures / actions needed to control plant conditions, including test termination criteria and actions will be incorporated.

by 4/29/92.

The procedures revisions will be completed prior to the next performance of the Incore Thermocouple and RTD Cross Calibration Test, which is scheduled for August.

4, 1990'during the Unit 2 refueling outage.

N

.