ML20059B658

Responds to Violation Noted in Insp Repts 50-413/90-15 & 50-414/90-15.Corrective Actions:Present Methods of Testing Operability of CO2 Fire Protection Sys Will Be Evaluated by 910201 to Determine If Addl Testing Necessary

ML20059B658
Person / Time
Site:	Catawba
Issue date:	08/17/1990
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008290214
Download: ML20059B658 (3)

Text

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• Charlotte, N C 2824: Nucleor 1% duction G, (104)373-4511 DUKE POWER August 17, 1990 U. S. Nuclear Regulatory Commission ATI'N: 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 No. 50-413, 414/90-15 Reply to a Notice of Violation Gentlemen:

Enclosed is the response to the Notice of Violation issued July 20, 1990 by the NRC concerning the improper installation of solenoids on three pilot valves associated with the Catawba Nuclear Station Unit 2 high pressure carbon dioxide fire protection system.

I Very truly yours, C,/

C $d - (W w

/llal B. Tucker MHil/58/lcs xc: Mr. Stewart D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW., Suite 2900 Atlanta, Georgia 30323 l Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station l

0*A ij 9008290214 000817 ADOCK 0500041,3 PDR F DC, O 7 l l

{

DUKE POWER COMPANY

REPLY 'tO'A NOTICE OF VIOLA? ION 413/90-15-04 10CFR50, Appendix B, Criterion XI, Test control, requires that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is ,

identified and performed in accordar.:: with written test procedures. The test program shall include, as appropriate, .;

proof tests prior to installation, pre-operational tests, and operational tests during nuclear power plant operation,

• of structures, systems, and components.

Technical Specification 3.7.10.3(b) requires that the high .

pressure carbon dioxide fire protection system be operable whenever the equipment protected by the system is required l to be operable. The protected equipment consists of the auxiliary feedwater pump rooms. Auxiliary Feedwater is_ i required to be operable in Modes 1, 2, and 3.

Technical Specification 4.7.10.3.3.b(1) requires that the high pressure system be demonstrated operable at least once l per 18 months by verifying that the system actuates manually and automatically upon receipt of a simulated actuation signal.

Contrary to the above, the solenoids on the three pilot valves associated with the Catawba Unit 2, high pressure i

fire protection system were installed backwards during -

. construction. pre-operational testing of the system failed to identify the error which prevented the components / system from operating satisfactorily in service. Routine surveillance was inadequate in that it did not demonstrate 3 that the system was operable by verifying system actuation i either manually or automatically upon the receipt of a simulated actuation signal.

RESPONSE

i 1. Admission or Denial of Violation l'

Duke power admits the violation.

2. Reaspns_fpr_V_iolation_if_Admitte_ d This incident was attributed to a Construction / Installation Deficiency in that the solenoids were installed backwards and that inspections did not identify this condition. This incident was also attributed to a Deficient procedure in that the pre-operational test procedure did not identify failed pilot valve solenoids.

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, 3.- Corrective Actions Taken to Avoid Further Violations-

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[ (A). The electrical actuation signals of_the high pressure CO's system were inspected, and found to

, be working properly (reference.W/R 464900PS)..

(B). The high pressure CO2' header was pressure' tested l}

B- using N2, and it was' observed that pressure was: '

': ' escaping from the exbrast vent of the pilot valves

7 (reference W/R 5228SWk)

• (C). The solenoid's orientation was corrected on the f three pilot valves (reference W/R 2558MES).

b (D). The Unit 1 solenoid's orientation was verified to pc installed correctly.

(Ej A post-maintenance N2 pressure-test was performed-on the high pressure CO2 header, and verified that -

the solenoids would-hold until an actuation signal is received ~(reference W/R 62285WR).

(F). Performance and Design Engineering met to discuss E improvements within the high pressure CO2 system F _ design documents. This meeting resulted in the following:

1) Design Engineering has initiated a preliminary review of as-built systems to vendor documentation.

mo 2) Performance has assigned a System Engineer to the Fire Protection System to

-improve station knowledge in this area.

4. Corrective Acti. on..s. to b..e Taken to Avoid Further--

- .- ~ - - - -

The present methods of testing the operability of CO2 fire protection systems will be evaluated by 2/1/91 to

- determine if additional tecting is necessary, to insure that the surveillance requirements of T/S are being met.

(PERFORMANCE)

Design Engineering will update system design documents or initiate replacement of the current CO2 control system by 2/1/91.

5. Date of Full.,Compli_ance Duke Power is now in full compliance. l

. . .