ML19343C188
| ML19343C188 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/29/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19343C187 | List: |
| References | |
| NUDOCS 8102180896 | |
| Download: ML19343C188 (4) | |
Text
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'Af (412) 456-6000 December 29, 1980 g(s ;lg7 15219 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 I.E. Inspection 80-20
Dear Mr. Brunner:
In response to your letter dated December 8, 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 inspection report.
If you have any questions concerning this response, please contact my office.
Very tru3;
.urs, est -
C. N. Dunn Vice President, Operations Attachment e
cc:
Mr. D. A. Beckman, Resident Inspector U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 8102 J 8 01F}4
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 80-20 Letter dated December 8,,1980 Description of Infraction Based on the results of an NRC inspection conducted on July 1-August 15, 1980, it appears that two of your activities were not conducted in full compliance with the conditions of your NRC License No. DPR-66 as discussed b.elow.
These ite=s are deficiencies.
10 CFR 50, Appendix B, Criterion XVII, states, in part, " Sufficient recordo shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
...the results of reviews...".
The BVPS FSAR, Appendix A.2 Operations Quality Assurance Program, Section A.2.2.17, states, in part, "The Operations Quality Assurance Program requires that sufficient records be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
...results of reviews....:
Quality Assurance Procedure No. OP-15, Quality Assurance Records, Revision 1, Section 15.1, states, "This procedure sets forth the requirements for the accanulation...of records attesting to the quality cf installed struc-tures, syste=s, and components, or of activities performed on those co=po-nents.
The requirements of this procedure shall be applied to records of all safety-related (Category I) structures, syste=s, components, and activities." Section 15.2.1.a)(1) of procedure OP-15 states:
"... Life-time records are those which meet one or more of the following criteria:
(1) Those which would be of significant value in demonstrating the capability for safe operation..."
IE Bulletin 79-27, Loss of non-Class 1E lastrucent and Control Power System Bus During Operation, provided revisions, and/or modifications necessary to ensure that unsafe system condition) or designs were identified and corrected.
Duquesne Light Co=pany rgsponded to this Bulletin by letter dated March 4,1980, pro-viding thr*, results and conclusions of their reviews to NRC:RI.
Speci-fically cl.e letter stated that "...the review of Class lE and non-Class lE busses *, supplying power to all instrumentation and control systecs which could affect the ability of the station to achieve cold shutdown has been completed.'....
IE Eulletin 80-06, Engineered Safety Feature (ESF) Reset Controls, provided requirements for the performance of desigS reviews and evaluations, testing and modifications necessary to ensure that unsafe conditions or designs were identified and corrected.
Duq'uesne Light Company responded to this Bulletin
- by letter dated July 4,1980, providing the results and conclusions of their reviews to NRC:RI.
Specifically, the letter stated that, "A review of the drawings.for all systems serving s'afety rela'ted functions to determine whether or not upon the reset of an'ESF actuation signal, all associated safety related equipment remains in its emergency mode has been completed..."
)
. R2 ply to Notics of Violstion Inspection No. 80-20 Letter dated December 8, 1980 Page 2 1
1.
Contrary to the above, QA records of reviews affecting quality were not maintained; in that, during the period of July 20-August 15, 1980, the licensee was unable to identify or provide QA records which described the performance and results of reviews condu:ted pursuant to IE Bulletin 79-27 or which would substantiate the conclusions included in the DLC l
response letter of March 4, 1980.
The licensee was unable to produce documentation which described the scope, content, or specific results of these reviews.
Subsequently, the re riews were determined to be incomplete or unperformed for the 125 VDC electrical systems (80-20-09).
2.
Contrary to the above, QA records of reviews affecting quality were not maintained; in that, during the periot of July 14-17, 1980, the licensee was unable to identify or provide QA records which described the per-formance and results of portions of reviews performed pursuant to T.E Iulletin 80-06 or which would substantiate portions of tha results ar.d conclusions included in the DLC response letter of July 4, 1980.
The licensee was unable to produce documentation which described the scope, content or results of reviews of reset circuitry for the Safety Injection Pumps, Feedwater and Auxiliary Feedwater Pumps, River Water Pumps, Quench and Recirculation Spray Pumps, Control Room Ventilation rotation equipment, and the Emergency Diesel Generators (80-20-14).
Corrective Action Taken 1.
In addition to the reviews of the 120 VAC Vital busses and the associated revisions to the BVPS Operating Manual, Chapter 38, Abnormal Procedures, which were completed and referenced in the inspection report (80-20-09) additional reviews -were made related to DC busses to cover the full scope of the IE Bulletin 79-27 and a supplemental response to the Bulletin wcs provided on October 21, 1980.
The review performed consisted of a failure mode on loss of DC power analysis for each load on the load list for each DC bus.
The loads were analyzed on a system-by-system basis to determine the overall effect on the plant and to form the basie. for developing Abnormal Procedures to cope with the loss of the DC bus as required by the Bulletin.
No design modifications were identified as being required.
The OSC reviewed and approved the Abnormal Procedures developed from this investigation.
Records have been placed in the files of the Licensing and Compliance Section documenting the reviews performed (80-20-09).
1 2.
A re-review of schematics for the following systems or equipment which 1
I receive ESF actuation signals was conducted:
Safety-Injection (Injection and Automatic Recirculation Switchover) a.
b.
Main Feedwater Isolation c.
d.
River Water System
~
e.
Containment Depressurizatica System f.
Containment Isolation g.
Control Room Ventilation ar d. Press 6rization h.
Main Stem =14ne Isolation i.
Emergency Diesel Genera m Startup l
-1
=_
Reply to Notice of Violation Inspection No. 80-20 Letter dated December 8, 1980 Page 3 This review was conducted for all pumps, valves, fans and dampers in these systems which receive an ESF signal.
An additional response dated July 31, 1980 was provided to the NRC documenting this review (80-20-14).
Action Taken to Prevent Recurrence on September 11, 1980, a written instruction was issued to personnel in the Licensing and Compliance Section which requires the assemblage and maintenance of appropriate records which will identify the reviewer and indicate the scope of reviews, identify the documents reviewed and the conclusions drawn from the review.
This instruction also requires the main _tenane_e of other supporting documents such as training, procedure preparation and approval, advice from vendors, status of plant equipment and test results.
The instruction requi,res the preparer of correspondence to the NRC to review the documentation to assure that statements made in such correspondence are substantiated by supporting documentation.
Date Upon Which Full Compliance Will 3e Achieved Full compliance has been achieved at this time.
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