ML19262A678

Responds to NRC 791001 Ltr Re Violations Noted in IE Insp Rept 50-334/79-17.Corrective Actions:Startup Forms Reviewed, Evaluation Rept Issued & Vibration Instrument Shipped to Vendor for Recalibr

ML19262A678
Person / Time
Site:	Beaver Valley
Issue date:	10/29/1979
From:	Dunn C DUQUESNE LIGHT CO.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19262A674	List: ML19262A678
References
NUDOCS 7912100224
Download: ML19262A678 (7)

Text

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'Af Mb s u) 456-6000 435 Sistn Avenue en on. Pe.

October 29, 1979 United States Nuclear Regulatory Commission Attention: Boyce H. Grier, Director Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 79-17

Dear Mr. Grier:

In response to you letter of October 1, 1979 and in accordance with 10 CFR 2.401, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violations included: (1) the failure to implement procedures, (2) the performance of operating and maintenance activities without a properly approved procedure, and (3) the use of measuring and test equipment which has passed its calibration date.

Duquesne Light Company shares your concerns about the implementation of the management control systems that permitted these violations to occur. In addition to the actions noted in the attached reply, a letter has been issued to the plant staff expressing management's concern about the occurrance and handling of situations which have resulted in recent noncompliances.

If you have any questions concerning this response, please contact my office.

Very truly yours,

.. u..

C. N. Dunn Vice President, Operations Attachment 1527 154 i

7912100 a 3.u j

DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-17 Letter Dated October 1, 1979 INFRACTION A Description Of Infraction (79-17-01)

Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below: (a) The applicable procedures .ecommended in Appendix "A" of Regulatory Guide 1.33, November, 1972...," and "(c) Surveillance and test activities of safety related equipment..." Regulatory Guide 1.33, Quality Assurance Requirements (Operation), November, 1972, recommends that the following typical safety related activities be covered by written procedures: "...A.3 Equipment Control (e.g. locking and tagging)... B.2 Nuclear Startup to Minimum Load..."

The BVPS Operating Manual, Section 1.50.3, scu lup Checklist D, Revision 7, requires, in part, verification that "...(3) An estimated critical position and boron concentration has been calculated in accordance with Procedure F, " Estimated Critical Position Calculations" of this chapter and associated data sheets..."

The BVPS Operating Manual, Section 1.55A.1, Periodic Checks - Operating Surveillance, Subsection 1, Revision 3, states, in part, "...The Shift Supervisor will, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, review the test for proper performe.nce and documentatio-and record any evaluation required..." The BVPS Operating Manual, Section 1.48.5.C.2, Use of Padlocks on Opet_cing Equipment, Revision 3, states, in part,

". . . (b) BVPS Operations Padlocks may be used to lock valves. . . that are infrequently operated or, if improperly operated could cause equipment damage or upset which might require considerable time and expense to recover from...

These padlocks will only be removed by permission of the St& tion Operating Foreman or Shif t R_gervisor. . ." The Cperating Valve Lists of the BVPS Operatin; Manual, Sections .7.3, Revision 7; 1.24.3, Revision 6; and 1.30.3, Revision 5, require that vals s 1-CH-26, 1-RW-98, and 1-FW-57 be locked as part of the normal system alignment. The official Padlock Log also lists these valves as being locked open.

Contrary to the above requirements:

The estimated critical position calculations performed on August 17 and August 19, 1979 were not properly completed in that Operating Manual Section 1.50.4.F, Item D - Rod Limits, Item E - Shutdown Margin Verification, Item F - Estimated Critical Position by Count Doubling, and the preparer's and reviewer's signature blocks, were incomplete on both secs of the procedure's data forms.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Reply To Notice Of Violation Inspection No. 79-17 Page 2 INFRACTION A (continued)

Operating Surveillance Test 1.49.2, Shutdown Margin Calculation, was performed on August 19, 1979, as required by Technical Specification 4.1.1.1.1, but had not yet been reviewed and signed by the Shift Supervisor on August 24, 1979.

On August 21 and 22, 1979, Valves 1-CH-26, 1-FW-27, and 1-RW-98 were found to be properly positioned but unlocked. No reason or authorization for unlocking the valves could be established.

Discussion Of Infrsction Regarding the sections which were not filled out completely: Item D, Rod Limits was not filled out since the maximum allowable rod height was well in excess of 228 steps, the maximum possible. Item E, Shutdown Margin, information was included on a different form (the OST). Item F, ECP by Count Doubling, information was not required by procedure or technical specification and will be deleted.

Regarding the missed signatures, a check with the personnel involved revealed that the procedure had been thoroughly reviewed and the missed signatures were an overs:.ght .

Corrective Action The s art-up forms wece reviewed and it was determined the missing information as described above did not constitute an unsafe condition.

The unlocked valves in question have been locked. It should be noted, however, that the valves were in their correct position but were found unlocked.

Action Taken To Prevent Recurrence The Shift Supervisors and operators have been directed to fill out all blanks on the vc.rious start-up forms, even if it involves just noting where else the data is recorded. The ECP form will be edited to eliminate unnecessary recording.

A review of administrative procedures will be conducted with regard to controls over padlocked valves and any necessary changes will be made during *.he upcoming refueling outage. The Charging Pump Suction / Isolation valves will be locked from inside the pump cubicles and signs will be posted at the location of the remote reach rods denoting this fact.

Several key in-line safety related valve position checks have been incorporated into the logs and are checked each shift. Other ESF valves are checked during the performance of the surveillance test related to the particular ESF component.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Reply To Notice Of Violation Inspection No. 79-17 Page 3 INFRACTION A (centinued)

An in-depth management review of controls over safety related equipment will be made during the refueling outage in an effort to improve the effectiveness of existing controls following a check of previously identified QA and NRC audit findings.

Date On Which Full Compliance Will 2E Achieved Full compliance has been achieved at this time.

INFRACTION B Description Of Infraction (79-17-07) 10 CFR 50, Appendix B, Criterion V, states, in part, " Activities 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..." The BVPS FSAR, Appendix A, Quality Assurance, Section A.2.2.5, Instructions, Procedures, and Drawings, states, in part, "... The Manual of Operating Procedures is implemented, enforced, and maintained by the Station Superintendent and his staff...

Maintenance, repair, modification, testing, and refueling activities which affect the quality or safety of Category I items are prescribed by documented instructions, procedures, or drawings. These instructions, procedures, or drawings, include, as appropriate, the requirements of special tools, test equipment, processes, controls or skills in order to attain the required level of quality..." Station Administrative Directive No. 8, Instructions, Procedures, and Drawings, Issue 2, states, in part, ". . . (1) All station employees shall conduct operating maintenance, tests,... activities which affect the QA Category I systems,... and components in accordance with the required approved procedures.

Contrary to the above, on August 11, 1979, an approved procedure, conforming to the above Quality Assurance Program requirements, was neither available nor used to free a stuck disc in QA Category I Valva 1-SI-29, Low Head Safety Injection Pump Minimum Flow Line Check Valve. Actions taken to free the valve disc included heating the valve with an oxy-acetylene torch and striking the valve with a hammer.

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Reply To Notice Of Violation Inspection No. 79-17 Page 4 INFRACTION B (continued)

Discussion Of Infraction The Shift Supervisor was attempting to troubleshoot the cause of the low recirculation flow of the 1A Low Head Safety Injection Pump. He had assumed that there may have been some boric acid preventing the check valve from traveling to its full open position. No procedure was used because he felt that he was troubleshooting a piece of equipment prior to taking that equipment out of service. He considered the work done to be within the capabilities of the personnel involved. He also felt that by holding the weld joint with his bare hands there would be no stress due to over-heating.

Corrective Action As noted in the Inspection Report, an Engineering Memorandum was immediately issued to evaluate the circumstances and possible effects of this event. The evaluation report states that the valve and connected piping had not incurred any damage of immediate concern. However, a decision was made to replace the valve at this time.

Action Taken To Prevent Recurrence This event was discussed with the Shift Supervisors and responsible maintenance personnel to preclude operations of this type on safety-related equipment in the future.

Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.

INFRACTION C Description Of Infraction (79-17-08)

IL CFR 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment, stater: " Measures shall be established to assure that... instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified intervals to maintain accuracy within ne:essary limits." The BVPS FSAR, Appendix A, Quality Assurance, Section A.2.2.12, states, in part, "...The OQA Program established measures to assure that... .nstruments and other measuring and test devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods... to maintain accuracy within necessary limits... The OQA Program requires that all measuring and test equipment shall be calibrated on or before 1527 i58

Beaver Valley Power Station, Unit No. 1 Docket Mo. 50-334 Reply To Notice Of Violation Inspection No. 79-17 Page 5 INFRACTION C (continued)

.he due date..." QA Procedure OP-12, Control of Measuring and Test Equipment, levision 2, states, in part, " Station Administrative Directives... shall ba prepared to assure that measuring and test devices are properly controlled, c.tlibrated, and adjusted at specified periods... to maintain accuracy within nocessary limits..." Station Administrative Directive No. 7, Control of Measuring and Test Equipment, issued August 1, 1974, states, in part,

"...(2) No measurements shall be obtained or tests performed utilizing measuring and test equipment which has passed its calibration date. . ."

Contrary to the above requirements:

Portable Vibration Monitor No. I-D-191-2, used for testing of Category I equipment in accordance with the Inservice Testing Program of 10 CFR 50.55(a),

became overdue for calibration as of June 2, 1979.

The instrument was used for routine performance of this testing during the period June 2 - August 6, 1979, prior to licensee identification of the instrument's status.

The past due calibration status of the instrument was identified by the licensee on or before August 6. 1979, as documented on Operating Surveillance Test No. 1.30.2, lA Reactor Plant River Water Pump Test. No proposed corrective action was documented or implemented.

Subsequent to that identification, the instrument was used for the performance of the following Operating Surveillance Tests (OSTs), conducted pursuant to 10 CFR 50.55(a) and the ASME Code, Section XI:

OST No. Equipment Date of Test 1.7.4 1A Charging Pump August 16, 1979 1.7.5 IB Charging Pump August 10, 1979 1.7.9 1C Charging Pump August 8, 1979 1.7.10 1C Charging Pump August 7, 1979 1.11.1 1A Lew Head Safety Injection Pump August 11, 1979 1.11.2 IB Low Head Safety Injection Pump August 11, 1979 1.13.1 1A Quench Spray Pump August 11, 1979 1.15.1 1A RP Component Cooling Water Pump August 10, 1979 1.15.3 1C RP Component Cooling Water Pump August 13, 1979 1.24.2 3A Motor Driven Aux. Feed Pump August 7, 1979 1.24.3 3B Motor Driven Aux. Feed Pump August 18, 1979 1.30.lA 9A Aux. River Water Pump August 10, 1979 1.30.lB 9B Aux. River Water Pump August 10, 1979 1.30.6 1C Reactor Plant River Water Pump August 9, 1979 1.36.2 No. 2 Emergency Diesel Generator August 21, 1979 1.24.4 Steam Driven Aux. Feed Pump August 14, 1979

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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 Response To Notice Of Violation Inspection No. 79-17 Page 6 INFRACTION C (continued)

Discussion Of Infraction The Operating Supervisor was notified by his personnel that the group's IRD vibration meter was beyond the calibration due date. The Operating Supervisor attempted to obtain another instrument from the Test group but was informed that their equipment was also out of calibration. He then instructed the Maintenance Foreman to expedite obtaining a calibrated vibration meter from the vendor. In the interim, he directed that the out-of-calibration meter be used, believing that the meter, showing no indications of abuse, would still be reasonably accurate and at least capable of detecting deteriorating trends of equipment.

It should be noted that this meter did, in fact, detect high vibration on an otherwise acceptable pump which was then declared inoperable. The pump was disassembled and the cause of the high vibration found.

Corrective Action When the NRC inspector, during his sita inspection dated August 20-24, 1979, noted the listed infraction, the vibration instrument, I-D-191-2, was immediately shipped to the appropriate vendor after a arrent, calibrated IRD instrum.ent was found by the Maintenance department. The instrument calibration papers were received back from the vendor (IRD) dated August 30, 1979 and the affected OSTs, as noted in the infraction, were corrected per the AS FOUND/AS LEFT values on the instrument calibration sheet. The instrument in question was found to be

(-) 4 1/2% within accuracy and, when the corrected OSTs were compared to surveillance requirements, all affected OSTs were found to be still satisfactory.

Action Taken'To Prevent Recurrence The Maintenance department is revising the instrument calibration schedule to provide greater assurance that a calibrated instrument is available at the Station. The method of shipping / receiving instruments out for calibration is also being improved.

Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.

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