05000334/LER-1988-013, Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued

Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued

ML20154H712
Person / Time
Site:	Beaver Valley
Issue date:	09/12/1988
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8809220099
Download: ML20154H712 (4)

LER-2088-013, Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued

Event date:
Report date:
3342088013R00 - NRC Website

text

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September 12, 1988 l

U. S. Nuclear Regulatory Commission Attn Document Control Desk <

Washington, DC 20555 ,

Reference:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Doch*at No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/88-22 and 50-412/88-16 Gentlemen:

In response to NRC correspondence dated August 12, 1988 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice  !

of Violation included with the referenced inspection report. ,

Your letter also asked that we describe our evaluation, including .

root causes and final corrective actions of a licensee identified ,

violation involving the failure to verify diesel generator '

operability. This item is also addressed in our reply.  !

If there are any questions concerning this response, please ('

contact my office.

Very truly yours, [

W l//f'b b Group Vice President i Nuclear i Attachment f cci Mr. J. Boall, Sr. Resident Inspector  !

Mr. W. T. Russell, NRC Region I Administrator  !

Mr. J. T. Wiggins, Chief Reactor ProjectJ Branch No. 3, (

Division of Reactor Projects, Region I j Director, Safety Evaluation & Control (VEPCO) ,

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', DUQUESNE LIGHT COMPANY Nuclcor Group BanvOr Volloy Powar Station, Unito No. 1 cnd No. 2 i

REPLY TO NOTICE OF VIOLATION Combined Inspection No. 50-334/88-22 and'50-412/88-16 Letter dated August 12, 1988 VIOLATION (Soverity Lovel IV, Supplement I)

Description of Violation (50-334/88-22-03; 50-412/88-16-02)

Titic 10 CFR Part 50, Appendix B, requires that activitics affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

specification document BVS-3001 and Unit 2 specification Unit 1

document 2BV-931 impicment the applicable cable installation and separation requirements.

The following examples of inadequate cabic separation were identified:

A. Unit 1

1. BVS-3001, Section 1 (General), requires that where exposed cables of redundant circuits leave trays to enter s1 coves, they shall be grouped by each color and each group shall have at least six inches minimum betwcon outer periphery of the group of exposed cables.

Contrary to the above, the outer periphery of the cabic group in tray 1TC545 was not separated by at least six inches minimum from the outer periphery of the redundant cable group in tray 1TC306B where the exposed cables entered cabic sleeves.

2. BVS-3001, Section 1 (General), requires that all horizontal cable trays shall have solid covers.

I contrary to the above, in several locations, horizontal cable tray covers were not maintained or were missing such that the required separation was not maintained.

B. Unit 2 2BV-931, Appendix M (Electrical Color Separation of Cables and Raceways) requires that the minimum separation distance betwoon redundant Class 1E cables / raceways and non-Class lE cabics/ raceways in the Cable Spreading Arcas be three feet vertically.

. Reply to Notice of Violation Combin';d In:pecticn No. 50-334/88-22 cnd 50-412/88-16 Lottor dotcd Auguct 12, 1988 Page 2 Description of Violation (cont.)

Contrary to the above, redundant Class 1E cables in conduit lino 2CC94000M and tray 2TC403P did not meet the three foot niinimum separation distance from non-Class lE cable 2NNSANC457.

Corrective Action Taken Walkdowns woro conducted by Engincoring and Construction personnel of those areas identified by the Inspector as having examples of inadequate cable separation. As a result of those walkdowns, various tray covers and conduit fitting covers were observed to have bocn removed, thereby reducing the cable separation criteria to below minimums as established within the BVS-3000 and 2BV-931 installation specifications. These covers were immediately replaced to rostore an acceptabic separation.

An action plan was established to walkdown all raceways in accessibic safety related areas in both Unit 1 and Unit 2 to identify and correct any similar situations. Presently, this action plan is still in progress due to the magnitude of effort involved.

l Action Taken To Prevent Recurrence As an interim measure, the Construction Department has revised their procedure NCAP 5.6 "Identification of Temporary Installation and Temporary Removals" to specifically address the removal and reinstallation of tray covers for modification work.

j Engineering will establish a practice to use fire blankets, which will permit tray covers to remain off during cable installation, and still maintain the separation criteria during unattended periods of l work on cable trays.

Date of Full Compliance r The expected completion date for the action plan described above is December 16, 1988. Following internal review of the results of these walkdowns, a supplemental report will be issued to address the actions to prevent recurrence.

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, ,7 , Reply to Notice of Violation Combin d Inspection No. 50-334/88-22 cnd 50-412/88-16 Lottor dotcd August 12, 1988 Page 3 Licensco Identified Violation Involving Failure to Verify Diosal Generator Operability At 1156 hours0.0134 days <br />0.321 hours <br />0.00191 weeks <br />4.39858e-4 months <br /> on 7/7/88, with Unit 1 at 100% reactor power, Emergency

< Dioscl Generator Number 1 (EE-DG-1) was removed from service for air lino cleaning. In accordance with ACTION Statomont A of Technical Specification (TS) 3.8.1.1, the operability of the other emergency AC power supplica snould be verified within one hour by starting EE-DG-2 from ambient and performing an offsite to onsite breaker alignment check. However, these actions woro not performed within the required time frame, as was discovered at 1438 hours0.0166 days <br />0.399 hours <br />0.00238 weeks <br />5.47159e-4 months <br /> after questioning by the relieving shifts foreman. Upon recognition of the omission, EE-DG-2

, was immediately started while the breaker verification was performed

! by 1450 hours0.0168 days <br />0.403 hours <br />0.0024 weeks <br />5.51725e-4 months <br /> 7/7/88. No safety implications resulted from the evant 4

since the redundant emergency AC power sources were always physically available to supply any required loads. This event was caused by a

cognitivo error on the part of Senior Reactor Operators, who did not

! properly recall or verify all required Technical Specification

actions associated with removing an Emergency Diesel Generator from service.

Corrective Actions i

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LER 88-013 was issued.

l Disciplinary action was taken for those licensed Control Room personnel involved in this event.

- This event will be reviewed by all licensed operating personnel.

l -

The Emergency Safety Features (ESF) Checklist will be revised to explicitly mention that, if an Emergency Dioscl Generator is

removed form service, the redundant train dicsci is started and l the appropriate offsite-to-onsite breaker alignment verification (cither OST 1.36.7 or 1.36.8) is performed within the diesel generator one-hour timo limit of TS 3.8.1.1.a.

Tts procedure for removing a Diesel Generator from service has boon revised in order to require verification of the other DG's operability as an initial condit.on. 4 The ESF Checklist will be revised to require a verification of the actions necessary for compliance to the Technical Specifications. This will provido a more positive assurance that supervision is not making errant assumptions regarding compliance to the Technical Specifications.