ML19257C569

Rept on Review & Establishment of Administrative Procedures to Provide Redundant Independent Verification of Operability of Engineered Safety Features.

ML19257C569
Person / Time
Site:	Beaver Valley
Issue date:	01/10/1980
From:	Moore G, Sieber J DUQUESNE LIGHT CO.
To:
Shared Package
ML19257C564	List: ML19257C563 ML19257C569
References
PROC-800110, NUDOCS 8001290411
Download: ML19257C569 (5)

Text

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DUQUESNE LIGHT COMPANY Power Stations Department REPORT ON THE REVIEW AND ESTABLISHMENT OF ADMINISTRATIVE PROCEDURES TO PROVIDE REDUNDANT, INDEPENDENT VERIFICATION OF OPERABILITY OF ENGINEERED SAFETY FEATURES Prepared By: .I

t. of Licensing and Compliance Reviewed By / ' '

Co-Chai an, Jffsite Review Committee l'h [h Approved By: d General Superintendent, Power Stations Department 8001290 -

YM

I. PURPOSE The purpose of this report is to describe:

A. The administrative procedures which have been adopted at Beaver Valley Power Station to require redundant, independent verification of the operability of the remaining engineered safety features required by the Limiting Condition of Operation whenever any safety system, or subpart thereof, is intentionally removed from service.

B. The review of existing procedures which has been performed to assure that Limiting Conditions for Operation are not defeated by maintenance or other activities.

II. BACKGROUND On November 27, 1979, an incident at Beaver Valley Power Station occurred which would have rendered both ECCS subsystems inoperable for a period of time had a total loss of offsite power occurred. The occurrence of this incident was promptly reported to the NRC Resident Inspector and reported to the NRC regional office of Inspection and Enforcement (LER's 79-46/0lP and 79-46/0lT dated November 28, 1979 and December 11, 1979 respectively).

On December 5,1979, NRC issued a notice of violation which stated inter alia:

" Technical Specification 3.5.2 states that with the plant in Mode 1 (Power Operation), two separate and independent ECCS subsystems shall be operable, and further states in section 3.5.2.c that each subsystem shall include an operable flow path capable of taking suction from the refueling water storage tank upon initiation of a safety injection signal.

" Technical Specification 1.6 defines " operable" to include the assumption that all necessary attendant instrumentation, controls, electric power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing theire related safety function (s) .

" Contrary to the above, on November 27, 1979, from approximately 8:30 a.m. to 10:30 a.m. , maintenance activities rendered both ECCS subsystems inoperable in that a) the refueling water storage tank isolation valve MOV-CH-115D was closed and incapable of automatic opening in response to a safety injection signal, and b) the refueling water storage tank isolation valve MOV-CH-ll5B, in the redundant subsystem, was closed, had no emergency power available, and thus was incapable of automatic opening in response to a safety injection signal if there had been a condition of loss of offsite power."

Upon discovery of the violation of Technical Specifications, the Shift Supervisor took immediate action to restore an ECCS subsystem to the OPERABLE condition.

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Station supervision, the Onsite Safety Committee, the Offsite Review Cocmittee and its Special Investigating Team and Department Management have reviewed the various aspects of this incident within their respective areas of responsibility and initiated or approved actions which are designed to prevent the occurrence of incidents of this type in the future. These reviews have resulted in a number of changes to the BVPS Administrative Procedures to provide redundant, independent verification of the operability of Engineered Safety Features (ESF) as defined by Appendix A of the Technical Specifications. Both the Onsite Safety Committee (OSC) and the Offsite Review Committee (ORC) have investigated the incident in detail and recommendations emanating from these investigations have been implemented as reported herein.

II

I. PROCEDURE

REVIEW Beaver Valley Power Station Administrative Procedures have been reviewed and modified as necessary to establish controls providing assurance that the occurrence of the complete unavailability of an ECCS or ESF system function caused by improperly removing from service or otherwise disabling the last remaining component, flowpath or power source or by reducing the number of operable initiating devices to less than the minimum number of channels specified in r.he Technical Specifications will not occur in the future. These new controls rely on redundant, independent verifications of the operability of the remaining ESF systems whenever any safety system or subpart thereof is intentionally removed from service.

The following Administrative Procedures were reviewed by station personnel:

A. Radiological Control (Appendix 1)

B. Chemistry (Administrative Controls)

C. Testing (Test Program Administration)

D. Operations (Chapter 48, Administrative Controls)

E. Maintenance (Chapter 1)

In addition, work procedures involved in Radiation Control and Maintenance were reviewed.

This review of procedures resulted in the following changes:

A. Administrative Procedure Chapter 48 Added definition of Engineered Safety Features (ESF) to Chapter 48, Section 1.

Section 1 - Organization of shif t personnel - Made change to state a clear line of authority of licensed personnel in the Control Room.

Section 2 - Part 4.a.1 - Removed the responsibility for on-the-job training from the Shift Supervisor.

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Section 2 - Part 4.a.4 - Revised procedure to state who may relieve a Shif t Supervisor.

Section 2 - Part 4.2.5 - On Page 4, specified that SR0 must remain in the Control Room du.ing an accident condition.

Section 2B - Made changes to require a Turnover Check Sheet be completed by Nuclear Control Operators (R0 license) and Nuclear Shif t Operating Foreman and Shif t Supervisor (SRO licensed) which addresses equipment that is out of service.

Section 2C - On Page 9, added section entitled " Station Authority" which requires the Shif t Supervisor to stop all Control Room activity which is not immediately required for the safe operation of the station.

Section 5 - System Level Status Board - Change was made to require the Nuclear Control Operator to light the entire train on the Status Board when a component is removed from service which would render that train inoperable.

Section 6 - A priority for returning cleared ESF equipment to service was established.

Section 6 - Clearance procedures were changed to require the use of an Emergency Safeguards Equipment Clearance Checklist, which includes provisions for independent, redundant verification.

B. Maintenance Surveillance Procedures (FGP's)

The initial conditions for each instrument surveillance procedure will be modified to provide for independent verification of redundant channel operability prior to proceeding with the performance of the procedure.

IV.

SUMMARY

Duquesne Light Company's investigation of this incident revealed t at the incident could have been prevented had the existing administrative controls involving the ESF status board been properly implemented. Administrative controls, which describe the use of the system level status board, have been revised to clearly describe the manner in which the panel is to be maintained to properly display the current operating status of ESF equipment.

The additional administrative controis established as a corrective action to the incident principally involve establishment of the use of the " Emergency Safeguards Equipment Clearance Checklist". This Checklist provides an additional administrative control to prevent the removal of required ESF equipment from service when the Technical Specifications require this equipment to be OPERABLE. This Checklist, as well as the modifications to the Maintenance Surveillance Procedures, require redundant, independent verification of the adequacy of the remaining inservice ESF equipment.

The "Shif t Turnover Checklist" establishes another administrative control which assures that all licensed members of the re'lieving operating crew are fully informed of the plant status including ESF equipment. As a result of i825L29i

the overall review, other administrative controls, not specific to this problem, were established or modified to aid responsible shif t personnel in the proper performance of their duties. Duquesne Light Company believes that these additional administrative controls described herein, as well as the detailed revieu of existing administrative procedures and controls, satisfy the modifications to License DPR-66 ordered by the December 5,1979 Order Modifying License.

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