IR 05000334/1993012
| ML20149D294 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/10/1993 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sieber J DUQUESNE LIGHT CO. |
| References | |
| NUDOCS 9309210002 | |
| Download: ML20149D294 (3) | |
Text
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I '* SEP l 01993 , i Docket Nos. 50-334 50-412 i
Mr. J. i Senior Vice President l Nuclear Power Division i Duquesne Light Company
Post Office Box 4
Shippingport, Pennsylvania 15077 !
Dear Mr. Sieber:
l SUBJECT: COMBINED INSPECTION 50-334/93-12; 50-412/93-13 ! This letter refers to your August 10,1993 correspondence, in response to our July 2,1993 ' letter, concerning your failure to update an operator aid for a new operating heat-up curve
for Unit 1, and to meet your commitment to perform periodic testing of Unit 2 AMSAC.
, ! Thank you for informing us of the corrective and preventive actions documented in your i letter. These actions will be eumined during a future inspection of your licensed program.
. I Your cooperation with us is appreciated.
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Sincerely, ! hene blly i ORIG!NAL SinNFO AY: l James C. Linville, Chief Projects Branch No. 3 . Division of Reactor Projects cc: G. S. Thomas, Vice President, Nuclear Services
D. E. Spoetry, Vice President, Nuclear Operations ! L. R. Freeland, General Manager, Nuclear Operations Unit . K. D. Grada, Manager, Quality Services Unit l N. R. Tonet, Manager, Nuclear Safety Department
H. R. Caldwell, General Superintendent, Nuclear Opentions . t -{ , ! g oI l
/ ) 9309210002 93091 OFFICIAL RECORD COPY PDR ADOCK 05000334
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. . > ,.. t . Mr. J. cc ve/cy of Licensee's Response Letter: K. Abraham, PAO, (2 copies) ' Public Document Room (PDR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident inspector Commonwealth of Pennsylvania State of Ohio ,
1 i OFFICIAL RECORD COPY i
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- l Mr. J. bec w/cy of Licensee's Response Letter:
Region I Docket Room (with concurrences) W. Lazarus, DRP J. Linville, DRP W. Butler, NRR G. Edison, NRR V. McCree, OEDO .' J. Nick, DRSS (see Section 3) T. Kenny, DRS (see Section 4.1) ' J. Laughlin, DRSS (see Section 5) W. Ruland, DRS (see Section 7.1) M. Evans, SRI-TMI ,
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! RI:DRP RI:DRP RI:DRP Rossbach/meo La Li ille 919/93 g)q)
, i OFFICIAL RECORD COPY l .A:RP931213.MEO , l ' L i
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, ', M g sea <e va ev Power stanon Shipp ngport PA 153*7-0004 August 10, 1993 JOHN O SsEBER r412; 39M255 Senior Vice Presdent and Fan 4412l 643-6069 Chief Nuclear Officer Naciear Power D: vision U.
S.
Nuclear Regulatory Commission Attn: Document Control Desk washington, DC 20555 Subject: Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 i Combined Inspection Report 50-334/93-12 and 50-412/93-13 Reply to Notice of Violation and Notice of Deviation In response to NRC correspondence dated July 2, 1993, and in accordance with
CFR 2.201 and
CFR Pa.-t 2, Appendix C, the attached replies addresses the Notice of Violation and the Notice of Deviation transmitted with the subject inspection report.
This reply is being submitted within
days of our receipt of the Notice of Violation and the Notice of Deviation as previously agreed to by the site Resident Inspector.
If there are any questions concerning this response, please contact Mr.
N.
R. Tonet at (412) 393-5210.
Sincerely, ' i. Attachment t cc: Mr.
L. W.
Rossbach, Sr. Resident Inspector .
Mr. T. T. Martin, NRC Region.I Administrator Mr.
J.
C.
Linville, Chief, Project Branch No. 3 i Division of Reactor Projects, Region I Mr.
G.
E.
Edison, Project Manager Mr. M.
L.
Bowling (VEPCO) l
u
outdated acceptance criteria.
Reason for Violatio_D
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A revision to the Unit 1 Operating Manual was necessary as a result of a
new operating cycle heat-up curve.
This revision was performed using an Operating Manual Change Notice (OMCN).
The distribution of the OMCN requires changing any affected operator aids.
The operator aid in this case was the copy of the heat-up curve which is located on the reactor operator's portion of the main control board.
While the change to the heat-up curve was properly made in the Operating Manual, the individual performing the distribution inadvertently omitted changing the reactor operator's control board copy.
Thus the reason for the existence of the incorrect heat-up curve revision was personnel error.
Corrective Actions Taken The correct revision of the Ur.it 1 heat-up curve was immediately placed on the reactor operator's console.
Reactor Coolant System pressure and temperature were within the acceptable range of
<
operation when this deficiency was identified.
The remaining operators aids at the Unit 1 operator's console were checked to ensure the proper revisions were in place.
It was discovered that the corresponding cooldown curve was also of the incorrect revision, and that curve was also immediately replaced with the correct revision.
Data from the Unit 1 cooldown on March 27, i
1993 was reviewed and determined to be in the range of acceptable operation for the correct cooldown curve.
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Reply to Notice of Violation Combined Inspection Report.50-334/93-12 and 50-412/93-13
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Page 2 Corrective Actions Taken. (Continued)
All remaining Unit
curves were verified to be the proper revisions.
The corresponding curves located at the Unit 2 reactor operator's console were verified to be the correct revision.
q Actions Taken to Prevent Recurrence The preliminary investigation could not identify the individual who placed the specific OMCNs into the Unit 1 manual.
It was determined that numerous individuals could have potentially distributed the heat-up curve changes.
Operation's clerks, procedure writers,
,
administrative assistants, and program engineers had previously
'
distributed OMCNs depending on the nature and timeliness of the change.
A lack of understanding of the distribution requirements is believed to be the cause for the failure to place a copy of the revised curve on the operator's console.
To preclude recurrence, two letters were issued by the Unit 1 Operations Manager.
One letter defined and limited the number of individuals who distribute OMCNs.
This action limits the individuals distributing OMCNs to a
small group having accountability for
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maintaining the Operating Manual and operator aids.
The second letter clarified the method by which OMCNs are processed, since the preliminary investigation identified the need to simplify and clarify this process.
This letter outlines the OMCN distribution process in detail and focuses on the importance of correctly changing the Operating Manual and the operator aids.
i In order to further investigate this event and enhance the process of incorporating OMCNs into the Operating Manual, a human performance evaluation will be performed for this event.
Additional process improvements will be implemented as necessary to ensure operator aids are the current revision.
Date When Full Compliance will be Achieved
,
The station is in full compliance at this time.
The human performance evaluation will be completed by November 12, 1993.
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- . , J DUQUESNE LIGHT COMPANY Nuclear Power Division
Beaver Valley Power Station, Unit Nos. 1 and 2 ! Reply to Notice of Deviation Combined Inspection Report 50-334/93-12 and 50-412/93-13 Letter dated July 2,.1993 Description of Deviation (50-412/93-13-02) , Duquesne Light Company letter, J. to U.
S.
NRC, "10 CFR 50.62, ATWS Rule Implementation," December 2, 1987, states that periodic testing of AMSAC will include a " functional test of the logic, time delays, and setpoints."
Contrary to the above, periodic testing of Unit 2 AMSAC, including a l functional test of the time delays and setpoints, has not been
accomplished since original AMSAC installation in 1989.
Reason for Deviation Operational Surveillance Tests (OSTs) were issued for both Unit 1 and Unit
to perform part of the required functional checks.
A maintenance procedure to test AMSAC logic, time delays and setpoints was issued to perform the remainder of the functional tests for Unit 1.
However, the equivalent procedure for Unit 2 has not yet been developed.
. C9rrective Actions Taken A Plant Problem Report (2-93-027) and associated Basis for Continued Operation were written to document and evaluate the deviation.
A task has been initiated on the maintenance tracking system to develop and issue a test procedure for Unit 2 AMSAC.
The procedure will be issued and the testing performed during the fourth Unit 2 l refueling outage, scheduled to begin in September 1993, i . Action Taken to Prevent Recurrence With the development of this maintenance procedure to test AMSAC logic, time delays, and setpoints, all procedures necessary to perform detailed testing of the Unit 2 AMSAC will be available and will be implemented on an 18 month frequency.
Date When Corrective Actions will be Completed The procedures to fully test Unit
AMSAC will be developed and testing will be completed prior to restart from the fourth Unit 2 { refueling outage, scheduled to begin in September 1993.
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