ML20206G177
| ML20206G177 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/16/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8811220120 | |
| Download: ML20206G177 (8) | |
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Duke Ptwt Company flu B Ta w PO Bax.DI9S sice treude:tt Charlotte, N C 28242 Nuctrar 1%J: ction (704Xfi34511 DUKEPOWER 3
November 16, 1988 U. S. Nuclear Regulatory Comission Washington, D. C.
20555 Attention: Document Control Desk
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report Nos. 50-413, -414/88-33 Replay to a Notice of Violation Gentlemen:
Picase find attached Duke Power Company's reply to Severity Level IV Violation Nos. 50-413. -414/88-33-01 which were transmitted per V. L. Brownlee's (NRC) letter dated October 17, 1988. These violations were caused by the failute to follow procedures for post maintenance testing.
Very truly yours.
K
- 11. B. Tucker JGT/1/VIO88-33 Attachment xc Mr. H. L. Ernest Acting Regional Administrator, Region 11 U. S. Nuclear Regulatory Comission 101 Marietta St., NW, Suite 2900 Atlanta, GA 30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station G311220120 G81116 PDR ADOCK 05000413 J
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PDC i
a CATAWBA NUCLEAR STATION DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413, 414/88-33-01 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.
1.
Station Directive 3.2.2, Development and Conduct of the Periodic Testing Program, Section 9.0 requires a retest on a battery following cell replacement.
Maletenance Manual Procedure 1.0, Work Request Preparation, Section 4.3.2 requires the group responsible for the retest to be entered in the retest block of the work request.
IP/0/B/3710/09, Alcad battery Periodic Inspection, requires a float voltage of 1.40 to 1.47 volts per cell.
Contrary to the above, Vork Requests 9397IAE and 9398I AE were written to replace cells on the Standby Shutdown System diesel 24 volt starting battery end failed to specify a group responsible for the retest. This resulted in the failure to specify a group responsible for the retest.
This resulted in the failure to perform an equalize charge and the failure to detect 3 cells with a voltage less than 1.40 prior to returning the battery to service on August 12, 1988.
2.
Station Directive 3.2.2, Development and Conduct of the Periodic Testing Program Section 9.0, requires that after a valve or its control tystem has either been replaced, repa. red or has undergone maintenance that could affect its performance, and prior to the time it is returned to service, it shall be tested a.s necessary to demonstrate that the performance parameters which could be affected by the replacement, repair or maintenance are within acceptable limits.
Contrary to the above, the air regulator for valve ICF-89 was replaced and returned to service on July 21, 1988, without being tested to 1
demonstrate that the parameters affected were within acceptable limits.
Response
1.
Admission or Donial of Violation i
Duke Power Company admits the violation.
2.
Reasons for Violation if Admitted Item 1. SSF Battery Replacement:
On June 3, 1988, the IAE Staff Engineer initiated Work Requests 9397IAE and 9398IAE to replace both the SSF D/G starter battery b'nks because of cell age and degradation. The replacement cells ve a ordered and the work requests were put on hold while awaiting parts.
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Pags 2 On June 24, 1988, Planning personnel planned the work requests and discussed the activities with the IAE Staff Enginear. As a result, the IAE Staff Engineer requested to be contacted for additional details.
On August 9, 1988, the work requests were issued and at 0910 hours0.0105 days <br />0.253 hours <br />0.0015 weeks <br />3.46255e-4 months <br />, the SSF diesel was declared inoperable for the battery replacement. Nuclear Support Services (NSS) personnel began the changeout of the battery banks per procedure IP/0/A/3710/02, Battery Removat and Repla ement.
Discussions occurred several times between the IAE S'.ff Engineer and NSS personnel regarding replacing the cells, and specifically about "equalize" charging of the cells. The IAE Staff Engineer stated he informed NSS i
personnel to contact Operations about placing the cells on "eo,aalize" charge and to notify him if any further help was needed. However, NSS persoinel stated they asked the IAE Staf f Engineer if the cells were to be equalized and they were told "no" because it ras to be done later.
In addition, NSS personnel stated they did not place the cells on an "equalize" charge because of the procedure. A step in the procedure l
directed that the battery banks be placed on an "equalize" charge, if necessary. NSS personnel interpreted that equalizing was not necessary since acceptable values were noted in the previous steps.
If i
l the equalizing charge had been performed per IP/0/A/3710/05, Equalizing 1
Charging Procedure, either as a result of proper interpretation of the step in IP/0/A/3710/02 or if an IAE retest would have been specified in planning, t'an a Quarterly Inspection would have been performed as the IAE Staff Engineer had originally expected. As a result, by 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, t
on August 11, 1988, NSS personnel had replaced both battery banks, 4
recorded the new cell data on data sheets, and placed the new cells on a "float" charge per the procadure.
On the morning of August 12, 1988, following the overnight "float" charge, NSS personnel verified the battery banks were in good condition.
At 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br />, the SSF D/G was returned to service and declared operable.
2 On August 23, 1988, per a routine monthly SSF D/G test, the diesel was successfully started. The personnel performing the test could not have been aware of the potential SSF D/G degrade.
However, since the SSF D/G 4
successfully started, it provides additional support that the SSF D/G was operable throughout this event.
On August 30, 1988, the IAE Staff Engineer reviewed the Replacement Cell Data Sheets and noticed the battery banks had not been "equalize" charged and a Quarterly Inspe; tion had not been performed following call replacement.
Following a discussion with tbs IAE Engineer, the IAE Staff l
Engineer determined the SSF D/G batteries kere in a degraded condition and filled out a Technical Specification Operabili+y Notification Sheet (TSONS) declaring the SSF D/G batteries inoperable and delivered it to the Operations Unit 1 Coordinator for review and approval.
The SSF D/G i
was determined to be inoperable at 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br />, on August 30, 1988, but due to misinterpretation of Station Directive 3.1.15, the Unit
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Coordinator did not no'iify the Shif t Supervisor. Usually the Se:urity 1
Plan would be implemented immedictely at this time as a result of the inoperable SSF D/G.
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The IAE Staff Engineer initiated a work request at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, to "equalize" the battery banks. The IAE Staff Engineer submitted two PIRs (0-C88-2i7 and 268) to Compliance to resolve the issues found during his review of the cell replacement and Quarterly Inspection data sheets.
The Shift Supervisor was unaware of the SSF D/G being declared inoparable until 1345 hours0.0156 days <br />0.374 hours <br />0.00222 weeks <br />5.117725e-4 months <br />, on Auguut 30,.1988, when an I AE Technician, with a copy' of the TSONS, contacted him about placing the battery banks on "equalize i
charge. At 1355 hours0.0157 days <br />0.376 hours <br />0.00224 weeks <br />5.155775e-4 months <br />, *.he Shif t Supervisor notified Security of the inoperable SSF D/G.
It was not made clear that the diesel had been i
inoperable since 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br />.
Se'curity immediately implemented the Security Plan. At 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, in a later discussion with the Shift Supervisor, Security was informed the SSF D/G had been inoperable since 1
1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br />. As a result of this misunderstanding, a violation of the Security plan would have occurred and the NRC 1 Hour Notification would i
not have been made in tice (had the SSF Diesel not been subsequently determined operable).
With input from Security, the Shift tjupervisor notified the NRC of the degraded SSF D/G and the late notification of Station Security at 1621 hours0.0188 days <br />0.45 hours <br />0.00268 weeks <br />6.167905e-4 months <br />, on August 30, 1988, per RP/0/B/5000/13, h1C Notification Requirements. Additional details are outlined in the Security Report of August 30, 1988.
In ;he following hours between 1700 and 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />, on August 30, 1988, the Shift Supervisor notified Station Management personnel and the Resident NRC Inspector of the apparent Tech Spec Violation.
l Following an "equalize" charge, the SSF D/G was returned to service and declared operable at 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br />, on August 31, 1988.
j On September 16, 1988, following a review of the SSF D/G starting requirements versus the battery bank capabiliti's, and based on discussions with the battery manufacturer, Design Engineering personnel were able to show the SSF D/G was operable and capable of starting the diesel as required, throughout this incident.
I Presently, Tech Spec 4.7.13.2.b requires the cell specific gravity be verified to be appropriate for continued service at least once every 92 days. However, per Enclosure 1, this requirement is expected to be
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deleted and cell voltage values, which are a better indicator of cell status, are to be substituted.
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It has been determined the SSF D/G was capable of being started, as required, and was operable throughout this incident. Therefore, it was j
not in violation of Tech Specs and is not reportable.
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Page 4 Item #2:
ICF-89 Air Regulator Replacement On February 17, 1988, Operations personnel initiated a low p.rictity work request to repair the air regulator which supplied air o 1CF89, Steam Generator.1B Feedwater Containment Isolation Bypass Control valve. The regulator was leaking an excessive amount of air. The work request was assigned to a Planner who was responsible for making the retest determination.
Because ICF89 is safety related and requires a retest af ter maintenance, the Planner discussed with other Planners whether working on the regulator for the air supply constituted working on the valvo.
The valve was determined to be a fail closed valve which closes on toss of air pressure.
Its safety related position is closed. They determined that in this situation, the retest would not be required based on the valve type and that the regulator was merely an extension of the air supply system, which is nea-safety related.
Because of its low priority, the work request was not sent to a crew for work until July 10, 1988. At this time, it was assigned to a Construction and Maintenance Department (CMD) Instrumentation and Electrical crew. A CMD Nuclear IAE Specialist evaluated the regulator and determined that it had been set to its maximum output of 60 psig in an attempt to achieve the required output pressure to the valve actuator of 75 to 125 psig.
Because of the damaged regulator, the valve was not actuating through its full stroke.
The CMD Specialist contacted the NPD IAE Engineering Support Group for resolution of the issue of the undersized regulator for the job. The responsible NPD IAE Staff Technical Specialist contacted the appropriate Projects Services Staf f Engineer to discuss the method for replacement of all similar Feedwater valve regulators.
Subsequently, the Technical Specialist wrote a Station Problem Report (SPR) to describe the problem, and recommended a solution.
The SPR was then routed for approval. On July 19, 1988, approval had been obtained to initiate a Variation Notico (VN) and the SPR number was assigned. This number was provided to the CMD crew by the NPD IAE Staff Technical Specialist.
The CMD crew interpreted the assignment of the SPR number as authorization to replace the regulator. The Specialist installed a 35 to 1C0 psig regulator, increased the regulator output from 60 to 75 psig, cycled the valve to verify that it now fully stroked, and signed of f the wor'A request. The CMD Supervisor reviewed and signed the work request as completed on July 20, 1988.
Since the work request indicated that no rotest was required, no stroke timing of the valve was performed.
The work request was completed and Operations personnel accepted operational control on July 21, 1988, at which time the Technical Specification violation started.
On July 22, 1988, the Projects Services Staff Engineer initiated a VN to authorize eight Feedwater valve regulators to be insta11eo.
After the VN was ready to be routed for approval, the Engineer contacted the CMD Specialist to inform him of the VN status.
At this time, the CMD Specialist informed the Engineer that a new regulator had already been installed which was slightly different from the one specified in the VN.
Pago S The Engineer modified the VN to match what was installed and routed the paperwork for review and approval. At this time, the Projects Services l
Engineer believed that the work request to replace the regulator was still outstanding and the valve was not in service.
Performance personnel successfully conducted PT/1/A/4200/18A, CF Valve Monthly In-Service Test, on August 4, 1988, in which ICF89 was stroke time tested which ended the Technical Specification violation. No change in the stroke time occurred from the previous test.
i On August 7,1988, the Unit was ' brought to Mode 5, Cold Shutdown, for S/G tube repairs.
As the Unit was ready to return to Mode 4, Hot Shutdown, work on 1CF88, S/G IC Containment Isolation Bypass Control valve, was required under a Performance work request to be completed before the mode charce. This work could not be completed before installation of the new 6
regulator had been completed per the VN.
The VN package initiated on July 22, 1988, could not, be found and on August 19, 1988, the VN package l
was reissued by the Projects Staff Engineer. At this time, it was suspected that an error in the installation of the 1CF89 regulator had r
occurred.
Projects personnel reviewed the ICF89 work request and determined the valve had been returned to service before the VN was issued which was a Technical Specification Violation. The Technical Specification violation occurred for 13 days, from July 22 to August 4, 1988. This event was determined to be reportable on August 19, 1988.
3.
Corrective Actions Taken And Results Achieved Item #1: SSF Batteries The SSF D/G battery banks were "equalize" charged and returned to i
service.
1 NSS site coordinator covered the incident in detail with NSS personnel placing emphasis on ovet communication with technical support personnel involving stops in procedures which are not clear.
t The Assistant Operating Engineer reviewed the late notification of l
Security with the Shift Supervisors.
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1 The Superintendent of Operations has reviewed the lat e notification of the Shift Supervisor with the Unit Coordinators.
l The Planning Engineer has reviewed this incident with Planning personnel with emphasis on reviewing the retest determination guidance identified in the Station Directive and Maintenance Management Procedures, t
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Paga 6 Item #2:
ICF-89 Air Regulator Replacement Performance personnel successfully conducted PT/1/A/4200/18A and stroke time tested 1CF89.
Projects Services personnel implemented a Variation Notice to authorize the installation of the new regulator on 1CF89 and all other CF valves in tbs same application.
All CMD and NFP sine supervision have been told the basic facts concern 1nn this incident and instructed on the proper way to handle this in the future.
The Perfo.mance group has provided the retest determination philosophy to all Station groups which determine or evaluate retests and will copy any future retest philosophy clarifications to the appropriate station groups.
All Planners have been trained on the clarified retest requirements issued by Performance.
4.
Corrective Actions To Be Taken To Avoid Further Violations Item #1:
SSF Batteries Compliance - By November 15, 1988, is to submit a Tech Spec Change Request to delete the specific gravity requirement for NiCad batteries from Tech Spec 4.7.13.2.b.
Nuclear Production Licensing - By January 15, 198V, is to submit the Tech Spec Change Request to the NRC.
Maintenance Engineering Services - Within 3 months af ter t.he NRC approves the Tech Spec Change Request, is to revise, as appropriate, the Alcad Battery Periodic Inspection (IP/0/B/3710/09) procedure for the specific gravity requirement.
Maintenance Engineering Services - By January 15, 1989, is to revise IP/0/A/3710/02, Battery Removal and Replacement, to address "equalize" charging all new cells.
Maintenance Engineering Services - By January 15, 1989, is to revise IP/0/B/3710/09, Alcad Battery Periodic Inspection, to address the action to be taken if the cell voltage is below the value necessary to insure operability.
Maintenance Engineering Services - By January 15, 1989, is to revise the data sheets to denote the specific gravity value requirements in paragraph 10.3.5 of IP/0/B/3710/09, are Tech Spec requirements.
Maintenance Engineering Services - By January 15, 1989, is to rsvise paragraph 10.3.5 of IP/0/B/3710/09 to reflect title change from L&P Engineer to Compliance Engineer.
Pago 7 l
Item #2:
ICF-89 Air Regulator Replacement By June 1, is *^ :he Performance Group will issue a Retest manual which consolidates all requirements for retesting plant equipment following maintenance or modifications.
Training will be provided to IAE and CMD on the NSM procees by January 15, 1989.
5.
Date of Full Compliance f
Duke Power Company will be in full compliance by January 15, 1989. The l
other corrective actions noted in "4" above are enhancements to our program and do not affect "full compliance".
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