ML19312E109
| ML19312E109 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/02/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19312E106 | List: |
| References | |
| 50-334-80-01, 50-334-80-1, NUDOCS 8006030266 | |
| Download: ML19312E109 (3) | |
Text
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O APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted on January 14 - February 8, 1980, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility License No. OPR-66 as indicated below.
Items A and B are Infractions.
Items C and 0 are Deficiencies.
A.
Technical Specification 3.3.3.1 states, "The radiation monitoring instrumen-tation channels shown in Table 3.3-6 shall be OPERABLE with their alarm /
trip setpoints within the specified limits."
Contrary to the above, while in Mode 6 on January 23, 1980, the actual alarm / trip setpoint for containment area monitors, RM-VS-104A and RM-VS-1048, and containment process monitor, RM-2158, exceeded the allowable limits specified in Technical Specification Table 3.3-6 as follows:
T.S. Limit Actual Setting RM-2158 (Containment Gaseous 5 7.3 x 102 cpm
- 8 x 103 cpm Activity)
RM-VS-104A
$ 1.6 x 100 cpm
- 9.25 x 103 cpm (Containment Area Monitor)
RM-VS-1048 5 1.6 x_103 cpm
- 9.34 x 103 cpm (Containment Area Monitor)
- Counts above background.
Background for RM-2158 was approximately 200 cpm and for RM-VS-104A and B were approximately 100 cpm and approximately 200 cpm, respectively.
8.
Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities refer-enced below:
...c.
Surveillance and test activities of safety related equipment...." The BVPS Chemistry Manual, Chapter 3, Sampling and Testing, Part 7, Reactor Plant Sample System, Revision 1, provides the procedures for drawing reactor coolant samples required to satisfy Technical Specifica-tion surveillance requirements and provides detailed valve manipulations to return the primary sample sink to a normal valve lineup upon the completion of sampling evolutions.
8006030 Zh
APPENDIX A 2
Contrary to the above, on February 7,1980, following a sampling evolution from the Residual Heat Removal System, the plant chemist failed to follow the approved Chemistry Manual procedures in that the primary sample flow path was secured by shutting only one valve rather than performing the alignment required by the procedure.
C.
Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities refer-enced below:
a.
The applicable procedures recommended in Appendix A to Regulatory Guide 1.33, November 1972...."
Appendix A to Regulatory Guide 1.33, November 1972 recommends that procedures be established for "...A.10 Bypass of Safety Functions and Jumpers...."
The BVPS Operating Manual, Chapter 1.48.5.0.h, Jumpers and Lifted Leads, Revision 7, states in part,
"...c.
Where temporary jumpers are installed...in troubleshooting equip-ment that has been cleared and tagged for maintenance, no documentation (tagging and logging) is required, but the guidelines of Section 5.D.3 must be followed to preclude restoring the equipment to operable status l
without restoring it to its original position.
If the equipment must be returned to service with temporary jumpers...then the procedures of Section 5.D.2 must be followed...."
Section 5.D.3 provides general instructions for the physical installation of jumpers including type of 1
wire to be used, etc.
Section 5.D.2 describes the control of temporary 2
jumpers including the requirements for identification, tagging and logging, and authorization of temporary jumpers.
Contrary to the above, on January 16, 1980, a temporary jumper was installed with alligator clips on RCS temperature recorder T-RC-4488, Terminals 9(+) to 9(-).
No temporary jumper tag was installed on the equipment and no log entry was present in the Jumper and Lifted Lead Log maintained by the Shift Supervisor. The temporary jumper had apparently been installed during authorized maintenance in accordance with OM Chapter 1.48.5.D.1.c but had not been removed or properly logged at the completion of that maintenance.
D.
10 CFR 50, Appendix B, Criterion XII states, in part:
" Measures shall be established to assure that... instruments, 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 BVPS FSAR, Appendix A.2, Section A.2.2.12, Control of Measuring and Test Equipment, states, in part, "The Operations Quality Assurance Program establishes measures to assure that... instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods or prior to use to maintain accuracy within necessary limits.
Specific pro-cedures shall include the identification of the calibration techniques, the calibration frequency, and the method for tagging of measuring devices to positively indicate their status... The Operations Quality Assurance Program requires that all measuring and test equipment shall be calibrated l
i
APPENDIX A 3
x I
N on or before the calibration due date...." The BVPS Maintenance Manual, Chapter 1, Section 0, Calibration Program, Revision 4, Paragraph 4.b states, in part, "...Each instrument that requires a periodic calibration and/or functional check is assigned a frequency as follows:
...b.
Other instru-ments subject to calibration per the QA Program were assigned their fre-quencies based upon the Onsite Safety Committee's recommendations (See the list of instruments to be calibrated per the QA Program:
Appendix IV, this section).
These'"other" instruments are any instruments which are used to quantitatively verify operability of a safety related system...." Appendix IV above includes the instruments listed below, except LI-FD-202, and spe-cifies an eighteen month calibration frequency for each.
Contrary to the above, on January 24, 1980, the instruments listed below were noted to have been due for the required periodic recalibration in November 1979 but had not yet recalibrated.
Additionally, the inspectors were unable to identify the existence of a calibration procedure or spe-cified calibration frequency for instrument LI-FP-202.
The instruments so noted are:
PI-63-FPC2 Cardox Pressure - Main Cardox Fire Protection Unit LI-FP-202 Cardox Level Indicator - Main Cardox Fire Protection Unit PI-EE-205 EDG Fuel System 1 Filter In PI-EE-206 EDG Fuel System 1 Filter In PI-EE-207 EDG Fuel System 2 Filter In PI-EE-208 EDG Fuel System 2 Filter In PI-EE-209 EDG Lube Oil Engine PI-EE-210 EDG Lube Oil Engine PI-EE-211 EDG Lube Oil Filter PI-EE-212 EDG Lube Oil Filter i
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