ML19322E502
| ML19322E502 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/07/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19322E499 | List: |
| References | |
| NUDOCS 8003280261 | |
| Download: ML19322E502 (3) | |
Text
.
h
'Af (412) 456-6000 os s..
4..~.
agww. e.
February 7,1980 l
United States Nuclear Regulatory Coaunirsion 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 IE Inspection No. 79-29
Dear Mr. Crier:
In response to your letter dated January 17, 1980, and in accordance with 10CFR2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report.
The noted violation was failure to follow procedures during hydraulic snubber testing.
We have reviewed the referenced report for information subject to claim from withholding from disclosure under 10CFR2.790 and no such information was identified.
If you have any questions concerning this response, please contact my office.
Very truly yours, 0 +/ L C. N. Dunn Vice President, Operations i
i 1
l l
8003280 2 6 )
r DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation inspection 79-29 Letter Dated January 17, 1980 Description of Infraction (79-29-01)
Technical Specification 4.7.9.1 requires that safety related hydraulic snubbers listed in Table 3.7-9 be demonstrated operable by performance of functional tests to verify correct piston movement, lock up and bleed.
Technical Specification 6.8.1 states, in part, that " Written procedures shall be established, implemented and maintained.
Station Administrative Directive No. 8 " Adherence to Procedures" states, in part, that "All station employees shall conduct operating, maintenance, test... activities which affect the QA Category I systems, structures, and components in accordance with the required approved procedures.
Corrective Maintenance Procedure No. 1-75-159, " Operating and Maintenance Procedure for ITT Grinnell Snubber Tester," Rev. O,Section IV.B.14 requires that the hydraulic fluid temperature be measured and recorded on Test Report Form PHD-5434-F.
Contrary to the above, procedures were not implemented in that:
During the Technical Specification required, Functional Testing of safety related ITT Grinnell Snubbers from July 5 to July 18, 1979, the hydraulic fluid temperature was not measured or recorded on the Test Report Form PHD-5434-F.
Corrective Action We have reviewed data from Operational Surveillance tests which recorded the ambient air temperature on two levels in the Auxiliary building during the testing period. The temperature on the 722 level ranged from 74 to 85"F with an average ambient air temperature of 80.81*F.
The ambient air temperature on the 752 level ranged from 72 to 85'F with an average of 82.58'F.
The snubber testing machine is located on the 767 level of the auxiliary building, but no air temperature recordings were required to be taken at this level.
Reply to Notica of Violation In p ction 79-29 Letter Dated January 17: 1980 Corrective Action (continued)
Since the air supply is common to all levels of the auxiliary building, and the deviation in the average ambient air temperature between the two levels of the building where data was recorded is less than 2*F, we believe that it can be reasonably assumed that the ambient air temperature at the level where the testing machine is located will be in the same ranges as those recorded at the other levels in the building and within the range required by the procedures. We further believe that the hydraulic fluid was in thermal equilibrium with the testing environment.
Fluid temperature data was not recorded during the test because it was believed that the steps required to be performed to measure the fluid temperature would disturb the "as found" condition of the snubbr.rs.
Action Taken to Prevent Recurrence Procedures will be reviewed to determine the need for hydraulic fluid temperature data or to devise a better method of determining hydraulic fluid temperature during testing and to require a review of contractor data by maintainence personnel after completion of their work.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved on March 30, 1980.