ML19332A025
| ML19332A025 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/17/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19332A024 | List: |
| References | |
| NUDOCS 8009100389 | |
| Download: ML19332A025 (6) | |
Text
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T49 M
912) 4se-sooo 435 Samm Avenue Pmstugh Fa.
"2" April 17, 1980 t
United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Boyce H. Grier, Regional Director Ri ion 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. 80-05
Dear Mr. Grier:
In response to your letter dated March 25, 1980, and in accordance with 10 CFR 2.201, the attached reply addresses th* Notice of Violation which was included as Appendix A of the referenced Inspection Report.
The noted violations were:
failure to perform a loop calibration using the approved procedure.
a.
b.
failure of a vendor to calibrate meteorological instruments using an approved station procedure and to maintain the calibration records.
failure to maintain calibration sheets for instrument calibrations c.
performed.
d.
failure to control OMCN's.
We have reviewed the referenced audit report for 10 CFR 2.790 information and none were identified.
If you have any questions concerning this respone, please contact my office.
Very truly yours,
$/
C. N. Dunn Vice President, Operations Attachment 8009100 %
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station
' Unit No. 1
' Reply to Notice of Violation Inspection 80-05 Letter Dated March 25, 1980 Description of Infraction (80-05-02)
Technical Specification 6.8.1 states that written proceduraes shall be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972.
I Appendix A to Regulatory Guide 1.33, paragraph H.1, states that appropriate procedures should be provided to assure readout instruments are properly calibrated and adjusted.
I-Contrary to the above, it was observed that a loop calibration procedure LCP-B-LI-100C, " Refueling Water Storage Tank QS-TK-1 Level Loop L-QS100D Calibration," Revision 0, issued March 2, 1979, which had been reviewed by the Onsite Safety Committee (OSC) and approved by the Station Superintendent was not properly established and implemented in that:
Data sheets in the procedure did not include the proper calibration input signals which were required as a result of a change in the level indication from wide range to narrow range performed November, 1977.
_ Calibration of Loop "D" level recorder, LR-QS100D, was performed on t
April 26, 1979, without using the above procedure.
Corrective Action The modifications that are presently being done during the outage will require the RWST level indicators to be reranged. A new calibration procedure for these indicators will be written and performed prior to plant start-up.
There is no need to revise the' existing procedure for narrow range level indication at this time since it will be superseled by the new procedure prior to the next scheduled use.
Action Taken To Prevent Recurrance The computer calibration carda which schedule the calibrations will be reviewed by the Instrument Engineer, as they come due, for the proper procedure number before the cards are sent to the instrument department for performance of the work.'
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Manual card changes will be made, if necessary, to preclude the option of using'either the generic calibration procedure or loop calibration / instrument calibration that exists while the present program is being changed.
~Date On Which' Full' Compliance'Will Ee Achieved 4
Full' compliance has been achieved at this time.
B :vir Vcllcy Power Station, Unit No. 1 Reply to Notice of-Violation Inspection 80-05 Letter Dated Merch 25, 1980 Attachment - Page 2 Description of Infraction Technical Specification 6.8.1.a states that written procedures shall be established, implemented and maintained coverir.g the activities recommended in Appendix "A" of Regulatory Guide, 1.33, November, 1972.
Regulatory Guide 1.33, November, 1972, Appendix A, paragraph H.2, states, in part, that implementing procedures are required for each calibration listed in Technical Specifications.
Further, Technical Specification 6.10.1.d states that records of surveillance activities and calibrations required by Technical Specifications shall be retained for at least five years.
Contrary to the above, it was observed that:
Calibration of triaxial seismic switches as required by Technical Specification Table 4.3-4, was performed on September 29, 1978, by an outside vendor using the vendor's procedure which had not been reviewed or approved by your staff.
At that time, a procedure, MSP 45.02,
-21smic Monitoring Instrument Calibration - Engdahl System," which calibrated these instrumests, was in affect and had been approved by your staff.
Calibration of Meteorological Monitoring Instrumentation was accomplished
. quarterly during the year 1979 by an outside vendor using a vendor procedure which had not been reviewed or approved by your staff. At that time, a procedure, MSP 45.17, " Meteorological Monitoring Calibration Test,"
which calibrated these instruments, was in effect and had been approved by your staff.
For the meteorological instrument calibrations accomplished by the vendor, records of these calibrations were nnt being maintained by your staff as required.
Corrective Action The vendors meteorological instrumentation data will be reviewed by the OSC by May 9, 1980.
Action Taken To Prevent Recurrence A review of the vendor's procedure and the existing station procedure will be performed, prior'to next required calibrations, to develop a procedure that is satisfactory to the vendor and meets station requirements.
This procedure will be in station format ;nd approved in accordance with existing procedures.
s BanvIr Vallrsy Pow 2r Station, Unit No. 1 Reply to Notice of Violation Inspection 80-05 Letter Dated March 25, 1980 Attachment - Page 3 This existing vendor's purchase order and all new purchase orders that secure vendor assistance for maintenance surveillance tasks shall state that the vendor will work from a station approved procedure and that any changes have station approval prior to test acceptance.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by June 30, 1980.
Description of Infraction (80-05-03)
Technical Specification 6.8.1.a states that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix "A" of Regulatory Guide 1.33.
Regulatory Guide 1.33, November, 1972, Appendix A, paragraph H.1, states, in part, chat measuring and test devices should be properly calibrated and adjusted.
Station QA Procedure OP-12, "Coatrol of Measuring and Test Equ*.pment," states, in part, that measuring and test equipment shall be in calibration before use and that a record of data generated during the calibration shall be maintained.
Contrary to the above, it was observed that:
No data was recorded on instrument calibration sheets for calibrations performed on July 28, 1979, and February 2, 1979, for a ramp generator used as a test instrument in the functional test of a Reactor Coolant Loop Flow channel functional test.
On the data sheet dated February 2, 1979, an annotation was made that a calibration had been performed; on the data sheet dated July 28, 1979, there was no indication of satis-factory calibration.
Data recorded for the calibration of a decade resistance box used as a test instsament in the calibration of a Delta T "T" average Pro-tection Instrument Channel, two of five scales calibrated appear to be out of the tolerances specified on the data sheet.
One of the
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scales, 100-1000 ohms, was used in the calibration of the Reactor Protection Channel.
Corrective Action The channel calibration and functional test mentioned will be performed prior to start-up using instruments calibrated with an approved procedure. An approved calibration procedure for ramp generators is presently in effect.
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Be;vir Vallcy Power St tien, Unit No. 1 Reply to Notice of Violation Inspection 80-05 Letter Dated March 25, 1980 Attachment - Page 4 c
Action Taken To Prevent Recurrence Instrument foreman have been informed that no test instrument is to be calibrated without an approved calibration procedure.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by July 22, 1980.
Description of Infraction (80-05-04)
Technical Specification 6.8.1.a states written procedures shall be established, implemented and maintained covering the activities recommned in Appendix "A" of Regulatory Guide 1.33, November, 1972.
Regulatory Guide 1.33, November, 1972, Appendix "A",
paragraph A, states, in part, that administrative procedures should be established for procedure adherence and temporary change method.
BVPS-0M 1.48.3.E.6, "On-the-Spot Revision," states, in part, that Operating Manual Change Notices (OMCN's) will be noted in the operator's and shift supervisor's logs.
BVPS-0M 1.48.9.L, " Maintenance of Operating Manual Controlled Copies" states, in part, approved revisions to the operating manual are to be inserted in the Contral Room and shift supervisor Controlled Copies of the BVPS Operating Mar al.
Contrary to the above, it was observed that:
An OMCN which was in effect for Log Sheet L3-9, used for monitoring Meteorological Monitoring System instrucentation, was not posted to log sheets maintained in the Operator's log files in the Control Room.
Revision 16 to BVPS-0M 1.54.3, which had been in effect for five days at the time of the inspection, had not yet been posted to control copies of the BVPS Operating Mant'Is located in the Control Room and Control Room shift supervisors office although this change was posted to other copies of the Operating Manual at ottsr locations at your station.
Three OMCN's, superseded by Revision 16, were still posted to the Control Room manuals.
Corrective Action For the part of the infraction pertaining to failure to post OMCN's to log sheets, Operators have Saen instructed to ensure that copies of OMCN's are attached to log sheets when used by the Control Room Operators.
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Beavor Vclicy Pow;r. Station, Unit No. 1 Reply to Notice of Violation Inspection 80-05 Letter Dated March 25, 1980 Attachment.- Page 5 We have reviewed the other part of the infraction pertaining to failure to post a revision to an Operating Manual Chapter five days after its effective date. We have reviewed our procedures, specifically Operating Manual Chapter 48, " Conduct of Operations," and have determined that all requirements of Chapter 48 were met.
Revision 16 to BVPS OM 1.54.3 was the permanent incorporation of OMCN's 80-11, 80-12 and 80-13 without change, and therefore, no inconsistency exists between the OMCN's and Revision 16.
Failure to post this revision during the time indicated did not violate the requirement of Chapter 48 since no time requirement exists, nor was the procedure in effect in error. We feel changes to existing practices are not necessary and that no corrective sccion is necessary in this area at this time.
Corrective Action Taken To Prevent Recurrence No further action is required at this time.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
Discussion The Company management shares your concern with the recurrence of problems with procedure compliance, especially those involving instrumentation and controls. A second Instrument Engineer was added to the station staff to permir a more depth review of instrument maintenance surveillance procedures and to reduce the instrument engineers workload.
This will also permit more direct supervision of company and vendor technicians.
Further, the Maintenance Supervisor has discussed the recurrent problems with procedure compliance with his engineers and foremen stressing the importance of procedure compliance in the overall operation of the station.
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