ML20044G505

Responds to NRC 930503 Ltr Re Violations Noted in Insp Repts 50-413/93-09 & 50414/93-09.C/As:training to Emphasize Requirements of Employee Training Standards Will Be Provided to Iae Supervisors & Lead Technicians by 931231

ML20044G505
Person / Time
Site:	Catawba
Issue date:	05/27/1993
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9306030219
Download: ML20044G505 (7)

Text

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. . II 1 l Duke 1%xr Company . MS TucwN Catmtba Nudeur Generatwn Department Vice l' resident 4390 Concord &>ad - (8RT)831J203 Office '

nrk, SC 29:45 . (803)S11d426 Fsx

DUKE POWER May 27,1993 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 NRC Inspection Report 50-413/93-09 and 50-414/93-09 ,

Attached is Duke Power's response to the Level IV violation cned in tne Notice of Violation by subject inspection Report dated May 3,1993.

The violation involved inadequate supervision of non-qualified personnel working on safety-related equipment.

Very truly yours, kD yy M.S. Tuckman JLL/

1 Attachment 02008b 7 9306030219 930527

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I U.S. Nuclear Regulatory Commission May 27,1993 Page 2 xc: S.D. Ebneter Regional Administrator, Region II R.E. Martin, ONRR R.J. Freudenberger ,

Senior Resident inspector I

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l DUKE POWER COMPANY ,

CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION i VIOLATION 414/93-09-02 Notice of Violation Technical Specification 6.8.1, Procedures and Programs, requires in part that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes the maintenance on motors to safety related equipment.

p Employee Training and Qualification System (ETOS) Manual, Standard No. 902.0, Employee Qualifications Component, Section 5.1.7, requires that when an individual is required to perform a task for which he/she is not qualified to, that individual will be directed / supervised by a qualified individual to ensure that the task is performed correctly.

Contrary to the above requirements, on March 6,1993, a qualified maintenance technician failed to follow the requirements of ETQS Standard 902.0, in that he allowed a non-qualified individualto reassemble the inboard motor bearing on the 2A Safety injection pump without adequately supervising the individual's activities. The non-qualified individual failed to properly reassemble the bearing which resulted in extensive damage to the motor when the pump was operated on March 23,1993.

This is a Severity LevelIV Violation and applies to Unit 2 only.

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1 DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION  !

VIOLATION 414/93-09-02 l

RESPONSE

1. Reason For Violation There were several contributing factors which collectively led to the failure of the Safety injection System (NI) Pump 2A motor inboard bearing following preventative maintenance activities to the bearing assemblies. They are discussed individually below:

The technician performing the inboard bearing reassembly was on loan from another department and was not qualified to the task, via the Employee Training and Qualification System (ETOS). The technician re-installing the outboard bearing was qualified, however proper ,

direction / supervision was not provided to the non-qualified technician, as required by ETOS Standard 902.0 (Employee Qualifications Component), Section 5.1.7.

The procedure used to provide guidance for the disassembly / reassembly  ;

of the motor bearings (MP/0/A/2002/01 - Motor inspection and

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Maintenance) was inadequate due to a lack of detail for reassembly. The guidance provided was to reassemble the bearing in the reverse order of disassembly. Because of the lack of detail, there was no sign-off for self-checking or a mechanism for double verification to ensure correct installation of the bearing assembly. Also, there were no pump motor graphics in the procedure to use as a reference for proper reassembly of the bearing.

A new, upgraded procedure (IP/0/A/4974/13 - Horizonal Split-Sleeve Bearing Motor Inspection and Maintenance) was approved for use and field validation on motors of this type on December 30,1992, to be used in place of the original procedure (MP/0/A/2002/01). However, the

" pre-defined" work order, established for this preventative maintenance activity, was not updated to require the use of this new procedure. Also, the new procedure (IP/0/A/4974/13) was reviewed to verify evidence of sufficient detail for bearing re-assembly. This review concluded that additional enhancements could be made to improve the level of detail.

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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 414/93-09-02 During the pump run (fill of the Cold Leg Accumulators), the Control Room did not receive a high inboard bearing temperature alarm when the bearing failed. It was determined that the tip of the inboard thermocouple may not have been in contact with the bearing and was therefore measuring the temperature of the air near the bearing, rather than that of the bearing itself. It was determined that the spring mechanism, which is designed to maintain thermocouple contact to the bearing, may have been jamrned during the installation process.

The functional verification of proper thermocouple operation upon re-installation included an ambient temperature check (motor not running) using the Operator Aid Computer (OAC) for temperature indication.

Maintenance Management Procedure (MMP) 1.12 (Post Maintenance Testing Program) provides guidance for performing functional verifications upon completion of preventative or corrective maintenance activities, however review of this procedure indicates that the guidance provided is for relatively small motors (600VAC and below). Also, a sight glass was available for observing proper lubrication to the bearing via the sling ring on this particular motor. Neither the original procedure (MP/0/A/2002/01) nor the new procedure (IP/0/A/4974/13) provided guidance to verify proper bearing lubrication using the sight glass. '

2. Corrective Actions Taken And Results Achieved i Prior to the Mode 4 (mode requiring pump operability), the NI Pump 2A Motor inboard bearing was replaced and successfully retested.

l A team was established to investigate / identify the cause of the bearing l failure and to recommend appropriate corrective actions so as to prevent future, similar events. A thorough investigation was conducted by the team and a comprehensive list of appropriate corrective actions were identified and initiated (refer to " Corrective Actions To Be Taken To Avoid Further Violations"). 1 3

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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 414/93-09-02 The " pre-defined" work orders associated with this event have been up-graded to reference the correct procedure for this task. A study was also initiated to review the process for updating procedure numbers '

referenced in work orders when new procedures are approved. As a result of this study, a computer program was developed for use by the procedure group to list all work orders associated for any given procedure. When a new procedure replaces an original procedure, all associated work orders are now identified for upgrade to the new procedure number.

A check preliminary for proper operation of thermocouples in other safety related motors was performed. This check warranted further investigation (refer to " Corrective Actions To Be Taken To Avoid Further Violation").

3. Corrective Actions To Be Taken To Avoid Further Violations Training to emphasize the requirements of ETOS Standard 902.0 will be provided to Instrumentation and Electrical (IAE) supervisors and lead technicians by December 31, 1993. ETOS Standard 902.0 includes requirements for direction / supervision to non-qualified technicians by qualified technicians / supervisors. Also, a communication will be issued outlining responsibility to direct and monitor work of non-task qualified individuals for those technicians that do not have lead / temporary supervisor responsibilities.

Procedure MP/0/A/2002/01, as well as other procedures involving motor maintenance activities, will be upgraded to " Nuclear Generation Department Procedure Development Guide" standards, to include the necessary guidance / graphics required for proper reassembly of bearing  ;

assemblies, and revised to provide a more positive means of verifying i proper bearing lubrication during subsequent testing by January 31, i 1994.

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DUKE POWER COMPANY CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION VIOLATION 414/93-09-02 Procedure IP/0/A/4974/13 will be revised to provide additional detail required for proper reassembly of bearing assemblies and to provide a more positive means of verifying proper bearing lubrication during subsequent testing by July 21,1993. ,

A review to determine the adequacy of the functional verification requirements for large motors (larger than 600 VAC) in MMP 1.12 will  ;

be performed by October 1,1993.

An investigation to determine the most likely cause of the thermocouple failure and identification of corrective actions for any suspect thermocouples in other motor locations will be completed by October 1, 1993.

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4. Date Of Full Comoliance.

Duke Power is now in full compliance.

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