ML19309B454
| ML19309B454 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/27/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19309B452 | List: |
| References | |
| NUDOCS 8004040165 | |
| Download: ML19309B454 (5) | |
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7T4 (412) 456-6000 435 fixth Avenue Pittsburgh, Pennsylvania 15219 February 27, 1980 United States Nuclear Regulstory Commission Office of Inspection and Enforcement Attn: Boyce H. Grier, Regional 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 Inspection No. 79-24
Dear Mr. Grier:
In response to your letter dated February 1, 1980, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspectic._ Report. The noted violations were:
1.
Failure to use approved data during performance of a calibration procedure.
2.
Failure to properly establish and implement procedures for the start-up and operation of gaseous and particulate radiation monitors.
We have reviewed the referenced report for information subject to claim from withholding from disclosure under 10 CFR 2.790 and no such information was identified.
l If you have any questions concerning this response, please contact my l
office.
I Very truly yours, letl C. N. Dunn Vice President, Operations 8004040165
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection 79-24 Letter Dated February 1, 1980 Description of Infraction (79-24-01) 10 CFR 50, Appendix B, Criterion IV, states, in part, " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activitf is performed..."
The facility FSAR, Appendix A, Section A.2.2.6, Document Control, states, in part, "... The Operations Quality Assurance Program includes provisions for assuring that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel, and are distributed to and used at the 1co.-aion where the prescribed activicy is performed, prior to the onset of work..."
Quality Assurance Procedure No. OP-8, Administrative Controls, Revision 4, Section 3.3.4, states, in part, "The administrative procedure shall require that the documents... including any revisions or changes thereto are:
(a) reviewed for adequacy by authorized personnel, (b) approved for release by authorized personnel, (c) distributed to the personnel performing the activity, (d) used by the personnel performing the activity." The BVPS Maintenance Manual Chapter 1, Conduct of Maintenance, Section 7, Revision 6, states, in part, "... a.5. Safety related... provisions shall be reviewed by the Onsite. Safety Committee and comments resolved.
a.6. The Station Superintendent or his designated alternate shall sign for the approval of all surveillance procedures...
c.1 Any revisions necessary shall follow the same review and approval procedure as outlined above..."
The BVPS Maintenance Manual, Chapter 1, Section A, Revision 9, states, in part,
".. 7.f On-the-spot revisions to maintenance procedures that for some reason may become unworkable may be made with concurrence of a maintenance supervisor and a Shift Supervisor... provided the intent of the procedure is not changed, and a design change is not involved..."
Contrary to the above, on August 28, 1979, calibration of RCS hot leg RTD amplifier TM-RC-432H was performed utilizing data from an Instrument Cali-bration Data Sheet, Form 147, which had not been reviewed, approved, or distributed as a revision or on-the-spot change co Maintenance Surveillance Procedure No. 6.40, T-RC-432 Delta-T/Tavg Protection Instrument Channel III Calibration, Revision 2, in accordance with the above requirements.
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m Re[1ytoNoticoofVic10 tion Insp:ction 79-24 Ldtter Dated February 1,1980 Attachment - Page 2 Corrective Action As noted in the inspection report, the data used to perform the procedure was properly reviewed and approved on December 13, 1979.
Action Taken to Prevent Recurrence f
Beaver Valley Power Station Maintenance Manual, Chapter 1, Section A.7, has been revised to incorporate document control methods that insure that only current procedures and data are available for use in safety related activities.
The revision was reviewed and approved by February 19, 1980.
Date Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
Description of Infraction (79-24-04)
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 recommended in Appendix A of Regulatory Guide 1.33, November, 1972..."
Appendix A to Regulatory Guide 1.33, Quality Assurance Requirements (Operations), November, 1972, recommends that the following typical safety-related activities be covered by written procedures:
"...C. Procedures for Sta'rtup, Operation, and Shutdown of Safety-Related PWR Systems,...
- 22. Process Radiation Monitoring System..." and "...H.
Procedures for Control of Measuring and Test Equipment...
- 2. Specific procedures for... calibrations should be written:...
a(29) Process Radiation Monitoring Calibrations."
The BVPS Operating Manual, Section 1.43.4F, Revision 4, provides operating instructions for particulate and gaseous radiation monitors which state, in part, "F.2 Periodically check the local enclosure for the flow rate of each particulate or gaseous monitor.
The flows should be the same as noted in Table 43-1."
The BVPS Radiological Control Manual, Form No. RCM-F229, Revision 3, is the log sheet utilized to document the actual "as found" and "as-left" flow rate data during weekly checks performed by members of the Radiological Centrol Department.
The BVPS Operating Manual, Sections 1.43.4A and B, Radiation Monitor Startup Procedures, Revision 4, each require that the operator:
" Observe that the High or Low Flow lights are extinguished," and that "If required (flow) values are not observed, adjust the flow to the desired value (Table 43-1)."
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Reply to Notico of Viointica Innpaction 79-24 Letter Dated February 1,1980 Attachment - Page 3 Contrary to the previous page, on November 29-30, 1979:
Procedures for the startup and operation of gaseous and particulate radiation monitors were improperly established and implemented in that Form No. RCM-F229, Revision 3, the document in use for periodic checks and adjustment of sample flow rates, included incorrect acceptance criteria for the sample flow rates required to be maintained on radiation monitors RM-1VS-102A and B, RM-1VS-105, RM-IVS-106, RM-IVS-107, RM-1RM-215 and RM-1GM-101.
Procedures for the operation of gaseous and particule.te radiation monitors were improperly established and implemented in that operating data collected on Form No. RCM-F229 during the period of October 3, 1979, through November 28, 1979, documents operation of the following radiation monitors for periods of one week or mere at flow rates which did not meet the applicable acceptance criterion, or operation with sustained flow alarms present, or both: RM-1GW-108, RM-1VS-102A and B, RM-1VS-105, RM-IVS-106, RM-lRM-215, and RM-lRM-217.
Flow adjustments performed in accordance with existing procedures were unsuccessful in correcting out of specification sample flow rates, and effective, further corrective action was not taken.
Neither procedures nor appropriate setpoints have been established for the calibration and maintenance of process radiation monitor sample flow alarm equipment.
Corrective Action Taken 1.
The Radeon Engineer has been assigned to coordinato Radcon, Maintenance and Operations activities directed to correcting monitor flow problems and adjustments.
2.
Radeon Instrument Procedures have been written that delineate actions for investigating and adjusting noted out of specification sample flows.
In the event the specified flow rate cannot be achieved, the monitoring channel is to be placed out of service.
3.
The equipment vendor was contacted and met with the Radcon Engineer to determine proper methods of maintaining sample flow rates.
4.
Maintenance has corrected major problems associated with the inability to adjust sample flow rates within tolerences.
5.
Flow rate tolerances have been established that will be specified in the applicable Maintenance Radeon and Operations Procedures.
Reply to Notico cf Violction In:picticn 79-24 Letter Dated February 1, 198d Attachment - Page 4 Action to Prevent Recurrence The Radeon Engineer has been assigned the responsibility for surveillance and coordinating station activities requ' ired to maintain the radiation monitoring equipment operable.
Current Radiation Mon ering System Radeon Procedures will be revised to include required actions for investigating and adjusting flow rates.
Radcon, Operations and Maintenance procedures will be revised to ensure that correct nominal flow rates and tolerances are specified.
Date On Which Full Compliance Will Be Achieved i
March 30, 1980.
Discussion of Unresolved Item (79-24-03)
We have conducted a preliminary review of Item 4.d in the inspection report concerning the illuminated control room annunciator alarms which are out of service or otherwise illuminated. We have determined that a major portion (48%) of the 83 annunciators enumerated were in that condition because of valid alarm conditions, or out of normal conditions, existing at the time.
Of the 40 alarms in this category, 33 were indicative of either equipment not operating and not expected to be operating or tank levels outside of the normal operating range.
For those alarm situations which are caused by operation outside the normal parameter range, instructions have been issued to require Operations personnel to maintain plant parameters within the required range.
For those instances where annunciators are illuminated where the condition is normally expected to exist during operation, it is believed that the existing annunciator logic does not interfere with the operator's ability to respond to transient or emergency conditions.
i Thirty-five (35) percent of the illuminated annunciators were in that condition due to maintenance being required upon the equipment being monitored or upon the instrument or the associated annunciator circuit.
Maintenance is in progress to significantly reduce the number of annun-ciators in this category.
We will commit to reduce the annunciators in this category to as few as is reasonably achievable before startup for Cycle 2.
Eight (8) of the 83 annunciators illuminated appear to have associated design problems in the application of the annunciator circuit and seven (7) are illuminated without an easily identifiable cause or cannot be-easily categorized.
Each of the annunciators will be reviewed on a case by case basis for possible redesign of the circuit or other appropriate corrective action.
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