ML20012B796

Responds to NRC Re Violations Noted in Insp Repts 50-413/90-01 & 50-414/90-01.Corrective Actions:Relief Request Submitted & Yearly Calender Prepared to Identify When Notice of Violation Received & Responses Due

ML20012B796
Person / Time
Site:	Catawba
Issue date:	03/09/1990
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003160297
Download: ML20012B796 (12)

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DUKEPOWER March 9, 1990 U..S. Nuclear Regulatory Commission

' ATTN: ' Document' Control Desk Washington,'D.C.

20555' s

. Subjects Catawba Nuclear Station,. Units I and 2 Docket Nos. 50-413 and 50-414 4

-NRC Inspection Report Nos. 50-413 and-50-414/90-01 Reply'to a Notice of Violation and a Notice of Deviation

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~ Gentlemen:

.e Enclosed is t.he response to the Notice of Violation and Notice of Deviation u.,

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-issued February B, 1990 by Thomas A. Peebles.concerni~ng failure to request relief from meeting ASME Section IX Standards and failure to complete corrective actions in a timely manner.

Very truly yours, M-I' tHa1 B.' Tucker WRC134/lcs Attachment

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xc: Mr. Stewart D. Ebneter

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?U.;SU Nuclear-Regulatory Commission

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101 Marietta St...NW, Suite 2900

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' Mr. : W. T.' Orders is

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l DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 50-413/90 01 01 Technical Specification Section 4.0.5 required the Licensee to follow Section 21 of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section.50.55a(g),

F except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(1). The l

licensee further clarified their commitment in the Intervica Testing t

Program for Pumps and Valves by stating that this program is based upon the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWP and IWV,1983 Edition including addenda through the summer 1983 addenda.

Contrary to the above, from approximately November 1, 1987, until July 25, 1989, the licensee conducted Performance Test Procedures PT/1/A/4200/04B, C and PT/2/A/4200/04B, C which contained Enclosure 13.1, Test Equipment Information.

This enclosure listed vibration meter accuracies that did not meet ASME Section XI standards.

The licensee failed to request relief from meeting the vibration meter accuracy value contained in ASME Section XI Article IWP 4110, Table IWP 4110 1.

RESPONSE

1.

Admission or Denial of Violation Duke Power Company admits the violation. While it is true that relief was not requested for vibration meter accuracy since the original relief i

request was denied, it was not until the first quarter of 1989 that our ability to meet the code was brought into question.

Although not all I

procedures reflected the use of 5% accuracy, IWP testing conducted since approval of the SER used the B&K 2511 instrument which was believed to meet the 5% criteria until 1989.

A search for suitable equipment and justification for relief has been underway as discussed below.

2.

Reasons for Violation f

The following is taken from a memo dated January 15, 1990 documenting the history of the IWP Vibration Monitoring Program at Catawba Nuclear Station along with the proposed future direction of the program.

Meeting the requirements of IUP 4500 has been a problem since the beginning of our program.

The original Inservice Testing Program submitted in 1984 contained a relief request to require 11% accuracy for vibration equipment rather than the 5% called for in IWP 4110.

This was requested due to the stated accuracy of the IRD equipment we were using at that time.

In 1986 we purchased new B&K 2511 instruments and began using these for IWP testing. These instruments were believed to meet the

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i 5% requirement so therefore when the requested relief was denied in January 1987 we felt we were in compliance.

OM 6 was believed to be in final form and ready for approval in 1989.

This requires monitoring of velocity rather than displacement.

At the same time the station was implementing the PM2 program.

PM2 is an advanced vibration monitoring program using state of the art digital vibration instrumentation.

This data is taken during IWP testing for i

predictive maintenance purposes, Rather than using two sets of equipment during IWP testing (B6X for IWP g

data and CSI for PM2 data) we requested that the Standards Lab (Duke J

Power's in house calibration facility) provide us with documentation that the CSI instrument meets the accuracy requirements of IWP.

This request was made during the first qaarter of 1989. In the second quarter of 1989, we were, told that the CSI will not meet IWP (or OM 6) requirements and nothing on the market for field monitoring will.

Up until this time we felt we were in compliance with IWP. The decision was made to ask for a j

relief request to be drafted allowing use of the CSI it.strument aad at the 1

same time adept the better testirg requirer.'ents of OM 6.

This would j

provide for the best possible equipment monitoring and get away from taking the rather meaningless IWP data.

Throughcut 1988 and 1989, the search for available equipment to acet the requirements of IWP vibration monitoring hu involved general office, station and standards lab personn?1 at Duke Power.

The General Of fice has queried other utilities as to whether they are meeting the code and what equipment they use.

In most cases, they are using the same or j

equivalent equipment as we are using.

Most send equipment back to the 1

manufacturer for calibration.

At Duke Power, we have our own standards i

lab to calibrate equipment using NIST standards.

We believe that performing our own calibrations is more likely to provide reliable results than going through the manufacturer.

Personnel from Duke Power Company have presented the vibration issue at the EPRI Inservice Inspection Workshop in November 1989, have been j

involved with the 06M Pump and Valve Working Group Vibration Task Group in an attempt to change OM 6, and have otherwise taken a lead in resolving the issue of vibration monitoring accuracy.

In September 1989, a relief request was drafted which contained accuracy numbers.we felt we could meet with available equipment.

A copy of this relief request is included as Attachment 1.

A majority of the IWP procedures were changed to include these numbers. Before we could submit the new relief request, six new Wilcoxon 793 accelerometers came back from our standards lab "Out of Calibration".

At the lower frequencies, accuracy requirements were not being met.

The relief request was put on hold for CNS in October 1989 until we were able to find out what numbers we could meet.

After a number of discussions between our standards lab, the manufacturer l

and station personnel, it was found that the standards lab had made a l

mistake in the calibration of the affected accelerometers.

In light of j

this finding, the September relief request will be submitted for approval.

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We at Catawba believe that our vibration monitoring pro 6 ram (IWP complemented by PM2) is sound.

The program has fulfilled its intended function of indicating potential degradation in pumps.

T1e unrealistic accuracy requirements of IWP and OM 6 have not been taken lightly.

We have been constantly striving to resolve the issue and will continue to do so in the future.

3.

Corrective Actions Taken and Results Achieved a)

The September Relief Request referred to above was sent to the-Catawba Regulatory Compliance Group on January 24, 1990 and was submitted on March 7,1990 to the NRC-A request was also made for interim relief for the current Catawba IWP Vibration program until the full relief is granted, b)

A meeting was held (February 8,1990) to review the present Catawba IWP Vibratian program and to begin plans for implenenting the prograr as will be required when the relief requeut is approved.

4.

Corrective Actions to be Taken to Avgid Further violations a)

All IWP procedures will be reviewed and any necessary changes made j

when the Relief Request referred to above is approved.

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l 5.

Date of Full Comoliance a)

Catawba will be in compliance once interim relief is granted.

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Catawba will be in full compliance within the required time after the relief request is granted.

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}VMPS:

All pumps included in the IST progran.

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TEST REQUIREMENTS:

IWP-3100 and IVP-3300 require vibration amplitude to be measured.

IWP-3210 specifies the allowable ranges of vibration amplitude measurements.

IWP-4110 requires the accuracy of vibration amplitude.

i measurements to be +/- 5% of full scale.

l IWP-4120 requires the full-scale range of vibration instrumentation to be three times j

the reference value or less.

IWP-4510 requires displacement vibration amplitude to j

L be read at one specific location during each test.

IWP4520(b) requires the frequency response range of vibration instrumentation to be f rom one-half minimum speed to at least maximum pump shaf t speed.

BASIS FOR REL1Er:

Experience has shown that-measuring i

vibration as required by IWP is not the most effective way to determine the mechanical condition of a pump.

In order to better determine the mechanical condition of purops, multiple vibration velocity measurements will be obtained/ evaluated and supplemented, when necessary, with acceleration / disp 1ccoment measurements and spectral analysis.

In order to facti!. tate this testing, digital vibration instrutnentation will be used.

IWP does not provide adequate guidance / requirements f or performing-the better/ alternate testing.

ALTERNATIVE TESTING: In lieu of the vibration requirements of IWP-3100 and IWP-3300, peak vibration velocity will be measured.

In most cases, vibration velocity gives the best indication of machine mechanical condition.

In lieu of IWP-4520(b) vibration instrumentation will be calibrated and vibration velocity will be measured over a range of 10 to 1000 Hz.

(Measuz ements at other frequencies will be taken as necessary.)

This-is the range that the state of the ar t instrumentation used can be adequately calibrated over.

This range will encompass most potential noise cont ributors.

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In lieu of the vibration inst rument. accuracy requir ement s of IWP-4110, vibration instrument accuracies will be within the limits specified below.

These accuracies will be ut ad because IWP does not specify accuracies for vibration velocity.

These accuracies are the best that can reasonably t

be-obtained from the state of the art instrumentation used.

(The requirements of t-IWP allow vibration inaccuracies of greater than +/- 15% of reading.)

j Accelerometer:

+/-5% of reading.

l (Due to the 4:1 rule, a lab uncertainty of +/-2.3% has to be added to the accelerometer uncertainty for a total / absolute l

accuracy statement of +/-7.3% of reading.)

pata Collector:

+/-5% of full scale (full scale is 1 volt) or +/-6% of velocity readings.

(These are total / absolute accuracies.)

In lieu of the rang 6 requirementt ifoposed on vibration instrumentation by IWP-4120, there will be no vibration instrument ation range requirement (digital vibratior.

instrumentation is auto-tanging).

It is tot necessary to have a range require. ment because the accuracies stated above and the readability of a digitti gauge are r.ot dependent upon instrument range.

p In lieu of the vibration ranges specliied in IwP-3210, the following ranges shall be L

used.

These ranges will be used because IWP i

l does not specify ranges for vibration TheseLranger are based on current velocity.

vibration standards (vibration severity charts).

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Fange Fa? se Action Fan;e ror All Ntts 0 to 0.19

>0.19 to 0.45

>0.45 kT.en V

</30.075 in/see in/see in/see I

in/sec ror Centrifugal

</=2.5V

>2.5V to 6V

>6V or Peps When V or >0!325 tor

>0.70 in/see

>0.075 in/se5 0.70 in/see In lieu of IWP-4510, peak vibration volccity.

n.casurements shall be taken during each test.on centrifugal purps, r,casurer:,onts shall be t.aken in a plane api >rox!nately perpendicular to the totating shaf t its tve c a thogonal directicas.

These incasurements saall be taken on ench accessible pwp bearing housing.

If no pumf, M aring housings are accessible, these ii<esuren.cnts shall be taken at the accessible 1ccation that gives gives the ben indication of lateral p op vibration, inic Iccation shall 3'

be one of the folic.ing.

Tap casing Motor beating housing Measure nents also shall be taken in the axial direction.

This v.casur ement shall be taken on cach accessible pump thrust bearing housing.

If no pump thrust bearing housings are accessible, this c.casur cn.ent s shall bc

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taken at the accessible location that.;ives the Lost indication of axial punp vibr at ion.

This location shall be one of the f olicwing, trp caring F 'at o r thrust t ra t i r. ; bri;s i ng Motor casin; l

DUKE POWER COMPANY REPLY TO A NOTICE OF DEVIATION 413/90-01-01 By letter dated August 10, 1989, in response to the Operational Safety Team Inspection (OSTI) findings, the licensee informed the NRC that corrective actions shall be accomplished by September 1, 1989, for item number (1) of Notice of Violation 50-413/89-09-01 (failure to lock valve 1-KC-9 as required by site procedure).

Additionally, by letter dated October 10, 1989, the licensee committed to correct Inspector Follow-up Items identified during the OSTI:

A) correct the Maintenance Management Procedure concerning control of the Standing Work Request Program by December 1, 1989 D) correct the Performance Test Procedures for the Containment Spray Pumps by January 1. 1990 C) prepare a proposal by December 31, 1989, for corrective actions based on design engineering studios for control room noise problems.

contrary to the above, the licensee s corrective actions for i

the violation ".. place a stem bolt and washer on each.of the Ccmponent Cocling Water System pumps suction and discharge valves on Unit 1", was completed on January 2, 1990, a period of approximately 120 days beyoitd the committad date.

Additionally, items A), B) and C) above had not been implemented as of' January 11, 1990.

RESPONSE

1.

Admission or Denial of Deviation Duke Power admits the deviation to the violation, items A and B, but denies the deviation to item C.

Item C.

Item C is in response to failure to complete resolution of control room noise problems.

This item was on the Commitment List stating that a design study was to be initiated to review the problem with excessive noise in the control room and a resolution proposed to management.

It had a due-dato of December 31, 1989 which operations assumed was the completion date.for the. design study.

Since the design study concluded that the noiso level was acceptable, Operations considered the item complete.

A Station Problem Report (SPR) was submitted January 11, 1990 to evaluate installation of sound attenuation devices in the ductwork.

Also, a memo to file was issued

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Page 2 February 7, 1990 summarizing our actions con:crning this IFI.

Since we feel we did not violate the intent of our commitment we are not proposing any corrective i

actions.

However, we will strive to formally document our actions pertaining to any commitments e

made by the date indicated.

2.

Reasons for Deviation if Admitted 1

1. 1.

Inattention to detail in entering and tracking Regulatory Commitment Items in the CNS Regulatory Commitment List.

In the case of the violation, the response was not entered into the computer to be tracked due to an oversight.

During the time the violation response was received, the engineer was writing up the pape* work for the 20 weaktusses c

(IFIs) from the same report.

The engineer assumed the violation responsa was wrPnen up along with,

the IFIs, but it wasn't.

Theretore, the gecup to complete the corrective action was unawa)E of a committed completion date.

Item A.

The revision of the Maintenance Management Procedure (MMP) wac in process at the tire of a personnel changeover in the Planning /Mr.L2 rials Support Staff.

The positloa in which the personnel change occurred is responsible for the administration of this procedure.

The commitment date was inadvertently overlooked in the turnover of duties between these persons.

Additionally,

't was not realized that an IFI committed date held the same weight as a violation committed date.

Item B.

The Performance Test Procedures for the Containment Spray Pumps (PT/1/A/4200/04B,C and PT/2/A/4200/04B,C) were sont for retyping during 1989.

Approval of the retyped procedures was mistakenly not pursued in a timely manner.

The Compliance group failed to properly prompt Performance for a response due to the item being an IFI and the fact that IFI completion dates are-normally not " committed" dates.

3.

Corrective Actions Taken to Avoid Further Deviations

1. 1.

A yearly calendar has been prepared to help identify when Notice of Violations are received, responses to the violations or other specific commitments are due to the NRC, and the date(s) of full compliance for each corrective action.

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Page 3 Approximately 2 weeks before each corrective action is to be completed, compliance contacts the t -

appropriate group (s) to confirm their date of compliance.

This will allow time to request an cxtension from the NRC if the commitment cannot be met. Once a violation response or other i

specific commitments has been approved by the l

Station Manager, the paperwork is immediately l

initiated to enter the actions on the commitment list.

r Item A.

MMP 3.5 revision 7 was approved January 30, 1990.

l Item B.

The Performance Test Procedures for the Containment Spray Pumps (PT/A/4200/04B,C and PT/2/A/4200/049,C) have been rotyped to incorporate all outstanding changes.

The reissued procedures include the changes called for in the NRC Inspection Repo::t 50-413,414/90-01.

The

• ,pproval date for All four procedures was February 4,

1990.

All.tWP procedures with 'nore than three ( 3) ottEtanding changes have been retyped with all changes incorporated as of March 6, 1990.

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'4.

Corrective Actions to be Taken to Avoid Further-l Deviations

1. 1 An audit is being conducted to verify that all actions items portaining to Notice of Violations and are ready "For NRC Review" have adequate documentation.

t Documentation is being collected for each i

corrective action pertaining to a Notice of Violation or other specific commitments which are ready "For NRC review".

An action item will not be removed from the commitment list without appropriate documentation being provided by the responsibic group.

A monthly audit will be conducted by the Compliance group to independently verify corrective actions taken by the responsible groups to close an item.

The Notice of Violation report will no picked at random.

A request for an extension of time will be submitted to the NRC for all corrective actions that are not complete and the date of full compliance has expired.

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l Page 4 station Directive 3.0.9, Catawba Action List File (CALF) and Commitment Index; the existing program for tracking commitments, will be revised in that i

o the corrective actions which have been taken to complete an item will be written in a memo or J

letter form describing resolution of the problem.

The changes to Station Directive 3.0.9 will be l

complete and approved by the Station Manager by

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May_l,1990.

Item A.

We feel this is an isolated incident caused solely

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by the changeover of personnel in the position j

responsible for this procedure.

It is not a recurring problem and we feel it warrants no i

programmatic changes.

8 Item B.

A semi-annual review of IWP/IWV procedures will be conducted to ensure that no procedure has more than three (3) outstanding changes.

5.

Date of_guJl Copplinna

1. 1, Duke Power will be in full compliance by May 3, 1990. 'TNa e.udit of existing items will be d.

4 complete by that date to well.

d leem A.

Duke Power is in full compliance.

Item b.

Duko Pover is in full compliance..

Mie inJ.tjal i

semi-annual review of all IWP/IWV procedures we.c-

't completed during January 1990.

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