ML20064F199
| ML20064F199 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/03/1994 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9403150209 | |
| Download: ML20064F199 (8) | |
Text
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Duke r%r Company D L Rt.nv.
Cafada Nudear Generation Department nce Eyesident 4800 ConcordRoad (803)MI3205 0llite York,3C29743 (803)S313I26 Fat
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DUKEPOWER March 03, 1994 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.
C.
20555
Subject:
Catawba Nuclear Station Docket Nos.
50-413 and 50-414 Reply to Notice of Violation Inspection Report 50-413,414/93-34 Attached is Duke Power Company's response to the two (2) Level IV violations cited in the Notice of Violation of Inspection Report 50-413,414/93-34.
One of the violations ' involved mode change with turbine driven auxiliary feedwater pump steam supply isolated.
The other involved delayed corrective actions for high residual heat removal pump vibration.
Very truly yours, kf['
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L. Rehn
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Ebneter Regional Administrator, Region II R.
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Martin, ONRR R. J.
Freudenberger, SRI l
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Duke Power Company Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-01 Notice of Violation Technical Specification 3.7.1.2 requires a steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system in OPERATIONAL MODES 1,
2, and 3.
Technical Specification 3.0.4 requires that entry into an OPERATIONAL MODE shall not be made when the conditions for the Limiting condition for Operation are not met and the associated ACTION requires a shutdown if they are not met in a specified time interval.
Contrary to the above, on December 25 at 3:46 p.m.,
Unit l' entered OPERATIONAL MODE 3,
Hot Standby, with the steam supply to the r
turbine-driven auxiliary feedwater pump isolated by valves 1 sal and ISA4.
This is a Severity Level IV violation.
Page 1 of 7
Duke Power Company.
Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-01
RESPONSE
1.
Reason For Violation On 12/23/93, Unit I was in Mode 5, Cold Shutdown.
ISA1 (Main Steam 1B to CA Pump Number 1 Isolation Valve),.ISA4 (Main Steam 1C to CA Pump Number 1 Maintenance Isolation Valve), and ISA89 (Auxiliary Steam to CA Pump Number 1) were tagged out for CAPT overspeed trip testing under work order number 93055813-01.
The CAPT overspeed trip was completed on 12/23/93.
Mechanical Maintenance (MNT) signed and returned the stubs for red tags 13696, 13697, and 13698 to Operations (OPS) so that 1SA1 and ISA4 could be reopened.
ISA89 was to remain closed in ' its normal position.
OPS did not remove the red tags in the event isolation was needed for additional work on valve ISAIS (CA Pump Turbine Stop Valve).
On 12/25/93, prior to entering Mode 3, the Work Control Center (WCC) Senior Reactor Operator (SRO) performed the review of the open Removal and Restorations (R&Rs) and temporary Station Modification logs in order to determine if outstanding work affected entry into Mode 3.
Noting that the open red tags for R&R 13-2980 affected the CAPT, the WCC SRO and the Unit 1 Supervisor referenced Catawba .echnical Specification (TS) 3/4.7.1.2, TS 4.0.4, TS Interpre tation (TSI) 4.7.1.2.la.2 and TSI 4.0.4 to determine if Unit I could enter Mode 3.
After determining that R&R 13-2980 would not affect entering Mode 3,
the WCC SRO communicated to the Shift Supervisor who was performing the Mode 3
checklist for OP/1/A/6100/01 (Controlling Procedure for Unit Startup), that no outstanding work or R&Rs prevented entry into Mode 3.
At 1546 hours0.0179 days <br />0.429 hours <br />0.00256 weeks <br />5.88253e-4 months <br /> on 12/25/93, Unit 1 entered Mode 3 with the CAPT inoperable because ISA1 and 1SA4 were closed which isolated the steam supply to the CAPT.
This event has been attributed to the TS documents not being followed completely.
TS 3.7.1.2 requires that three auxiliary feedwater pumps and associated flow paths be operable in Modes 1,
2, and 3.
TSI 4.7.1.2.la.2 provides guidance to allow entry into Mode 3 without performing an expired surveillance that is required by TS 4.7.1.2.la.2, Head Curve Performance Test.
The CAPT test requires that the unit be in Mode 3 with secondary side steam pressure of at least 600 psig.
The TSI states that the CAPT must be declared inoperable and the applicable action statement must be entered when the secondary steam pressure reaches 600 psig and there is an expired surveillance.
The WCC Page 2 of 7
Duke Power Compaay Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-01 SRO and the Unit 1 Supervisor determined that entry into Mode 3 would not be affected by the inoperable CAPT since entry into Mode 3 was allowed by the TSI with an expired CAPT surveillance test.
The TSI further states that when entering Mode 3 from Mode 4 with an expired surveillance interval for the CAPT, the
-j CAPT shall be operable in the sense that it is ready to be surveillance tested and CNS management has confidence in the ability of the CAPT to pass the surveillance test.
The TSI also requires that CAPT steam supply valves ISA2 and ISAS be operable.
The Unit 1 CAPT was actually inoperable at the time of Mode 3 entry because 1SA1 and 1SA4 were red tagged closed which would render the CAPT steam supply line inoperable.
ISA1, 1SA4, and ISA89 had been red tagged closed so that MNT could perform the CAPT overspeed trip test which is a required surveillance.
Work that required ISA1, ISA4, and ISA89 to be closed had been completed and the red tag stubs had been signed by MNT and given to OPS.
Red Tag R&R 13-2980 remained in the tagout book and the red tag stubs remained in the Unit 1 Supervisor's office.
OPS shift personnel were aware that the e
tagout was still open.
2.
Corrective Actions Taken and Results Achieved
{
Upon discovery that 1SA1 and ISA4 were required to be open prior to entering Mode 3,
the red tags were cleared and the valves were opened.
The CAPT was successfully surveillance tested and declared operable.
This event was investigated by the Catawba Safety Review Group and documented in Licensee Event Report (LER) 413-93-012, Unit 1 Entered Mode 3 With Inoperable Auxiliary Feedwater Pump, submitted to the NRC on 01/24/94.
Operations shift personnel were informed about this event through an operator update issued on 02/03/94.
Operations managment evaluated appropriate procedures in order to identif y potential hold points for discussion of condition changes.
It was determined that the hold points currently contained in existing procedures at key conditional changes, such as mode changes and system conditional changes are adequate and no additional changes to procedures will be required. This evaluation was completed on 02/16/94.
Page 3 of 7
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Duke Power Company Catawba Nuclear Station Reply to Notice of Violation S0-413,414/93-34-01 3.
Corrective Actions To Be Taken To Avoid Further Violations TSI 4.7.1.2.la.2 and TSI 4.0.4 will be reviewed and revised by 06/23/94, if necessary for clarity.
[ Assigned to RGC) 4.
Date Of Full Compliance Duke Power Company is now in full compliance.
Page 4 of 7 l
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s Duke Power Company Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-02 Notice of Violation 10 CRF 50 Appendix B,
Criterion XVI, Corrective Action, requires measure be established to assure that conditions adverse to quality, such as deviations, are promptly identified and corrected.
Contrary to the above, on December 12,
- 1993, Unit I was in operational mode 5 with reactor coolant loops not filled.
Measured vibration of the 1A Residual Heat Removal Pump (RHR) motor upper bearing casing was in excess of 0.7 inches per second.
This deviation with the Required Action Range established by the Pump and Valve Inservice Testing Program was not promptly identified as a condition adverse to quality.
As a result, actions to assess the operability of the pump were not promptly implemented and the pump was not declared inoperable until 2:00 p.m. on December 14, 1993.
This is a Severity Level IV violation.
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s Duke Power Company Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-02
RESPONSE
1.
Reason For Violation Catawba Unit I was taken off-line on 10/29/93, for a scheduled refueling outage.
Preplanned outage work included replacement of Residual Heat Removal (ND) Pump 1A due to a seal leak.
The pump work was conducted with the plant in No Mode (Defueled) and was completed on 11/30/93.
During post-maintenance ASME Section XI IWP testing, the vibration monitoring results were in the IWP Program Alert Range.
This prompted additional vibration monitoring which was coordinated and reviewed by the station Vibration Engineer.
As additional vibration data sets were obtained, meetings were held with station management to discuss pump status, operability, and reliability.
From 11/30/93 to 12/14/93, the plant proceeded from No Mode through Mode 6 (Refueling) and Reactor Coolant (NC) System draindown to Reduced Inventory.
Vibration monitoring, data collect. ion, and evaluations continued-throughout this time period. On 12/13/93, the IWP Program Required Action Limit was exceeded for the first time.
The Vibration Engineer continued to consider the pump operable partly due to his understanding of the IWP Program Limit.
Catawba was recently granted a Relief Request for IWP Program Testing to allow the use of velocity vibration monitoring rather than displacement vibration monitoring as specified in IWP.
As a result, OM-6 vibration acceptance criteria are used while ASME Section XI IWP paragraph requirements are used.
Upon review, it is evident that there was not a consistent understanding of which requirements from each document (IWP/OM-
- 6) apply when vibration monitoring is performed.
Throughout this period, it was generally thought that the 0.7 limit in the IWP test procedure applied only at IWP flow (miniflow) and that vibration results above the limits at higher flows were subject to Engineering evaluation.
The IWP Code allows Engineering evaluation when vibration results are in the Required Action Range; OM-6 does not.
The formal operability process was not properly entered upon exceeding the 0.7 IWP Program Limit on 12/12/93, which would have ensured formal management involvement in this decision making process and ensured interface with Operations.
From 12/13/93 to 12/14/93, vibration results began to increase from the levels previously seen.
On 12/14/93, due to an unacceptable upward trend in data, ND Pump 1A was declared inoperable, and Action a.
of TS 3.4.1.4.2 TS Action Statement was entered.
At that time, Unit 1 was in Mode 5 (Cold Shutdown) with NC level at Reduced Inventory (8.5%) and all steam generator's primary manways installed.
TSs and Catawba Page 6 of 7
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Duke Power Company Catawba Nuclear Station Reply to Notice of Violation 50-413,414/93-34-02 Shutdown Risk Management Program requires two ND Trains operable /available.
Both ECCS Trains (two NV Centrifugal Charging and two NI Safety Injection Pumps) were available for forced injection and both Emergency Diesel Generators were available.
ND Train B remained operable; there was no interruption of core cooling.
2.
Corrective Actions Taken and Results Achieved The motor assembly was removed from 1A ND Pump and shipped to Westinghouse for analysis.
This analysis concluded that the vibration problem was caused by a loose upper bearing runner.
The operability determination process and related management expectations have been reviewed with Component and Systems Engineers.
Maintenance procedure, IP/0/A/4974/15, ND Pump Motor Inspection and Maintenance, was revised on 02/22/94, to include an improved method for taking measurements when reassembling the upper bearing runner.
3.
Corrective Actions To Be Taken To Avoid Further Violations The IWP Program Vibration Monitoring Requirements will be defined and included in Site Directive 3.1.14, Operability Determination, by 06/12/94.
[ Assigned to SES]
The hard limits of the IWP Program will be reviewed for awareness by 06/12/94, with appropriate System and Component Engineering personnel.
[ Assigned to SES/CES]
The Position Specific Training Guidelines will be revised by 08/01/94, to include specific IWP Program training to personnel involved in rotating equipment to ensure that future personnel in these positions are aware of the requirements.
[ Assigned to TCT)
The requirements on the proper use of the operability determination process aad when to enter the process ' will be incorporated into continuing L. h ing for Engineering personnel by 08/01/94.
[ Assigned to TCT]
A review will be completed by 06/12/94 to determine the appropriate process to use when collecting informal data.
[ Assigned to CES]
4.
Date Of Full Compliance Duke Power Company is now in full compliance.
Page 7 of 7
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