ML20011A306

Responds to NRC 810818 Ltr Re App a Violations Contained in IE Insp Rept 50-334/81-08.Corrective Actions:Operating Requirements of 10CFR50.72 Will Be Covered in Retraining Program.Response to App B Withheld (Ref 10CFR2.790)

ML20011A306
Person / Time
Site:	Beaver Valley
Issue date:	09/21/1981
From:	Carey J DUQUESNE LIGHT CO.
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20011A303	List: ML20011A306
References
NUDOCS 8110090278
Download: ML20011A306 (6)

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'3ji;;^;"'" September 21, 1981 15219 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: R. C. Haynes, 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 Report No. 81-08 Centlemen:

l In response to your letter of August 18, 1981, and in accordance with 10CFR 2.201, the attached replies address the Notices of Violation which were ircluded as Appendicies A and B with the referenced Inspection Report.

Since the Reply to Notice of Violation, Appendix B, contains information subject to Section 2.790 (d), Title 10, Code of Federal Regulations and is, therefore exempt from disclosure, it is my understanding that this portion of this 81-08 response will not be placed in the Public Document Room and will receive limited distribution.

If you have any questions concerning this response, please contact my office.

1 Very truly yours,

<D

/ - CI/L f L J. J. Care.y Vice President, Nuclear Attachmen+.s: Reply to Notice of Violation, Appendix A Reply to Notice of Violation, Appendix B cc: Mr. D. A. Beckman i U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Fbnagement Branch Washington, DC 20555 l

8110090278 811001 PDR ADOCK 05000334 G PDR

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.- ;, e COMMONWEALTH OF PENNSYLVANIA)

) SS:

COUNTY OF BEAVER )

On this J day of dujM , /9[/ , before me, m 'Ae/ /d u m/ W-ma# a Notary'Public in and for said Commonwealth and g Tounty, personally appeafed J. J. Carey, who being duly sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly-authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowled:;e, information and belief.

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JUD'TH D. ANTMONE N0fary Pobre Shippmgport Be< cog't Beaver Co., Pe.

My Comrnission E.xpires Cec. 12, 1983 1

i i

, s e-DUQUESNE LICHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Appendix A Inspection No. 81-08 Letter dated August 18, 1981 VIOLATION A (Severity Level IV; Supplement I)

Description of Violation (81-08-07) 10 CFR 50.72, Notification of significant events, states, in part, "(a) each licensee of a nuclear power reactor licensed under 50-21 or 50.22 shall notify the NRC Operations Center as soon as possible and in all cases within one hour by telephone of the occurrence of any of the following significant events and shall identify that event as being reported pursuant to this section: ... (3)

Any event that results in the nuclear power plant not being in a controlled or l expected condition while operating or shutdown..."

The Beaver Valley Power Station Operating Manual, Section 1.48.9.D, Miscellaneous Reports, Paragraph 1.c, Revision 12, December 31, 1960, states, in part: "c.

Prompt Notification - The NRC shall be notified immediately (not to exceed 1

, hour) of any significant events at operating nuclear power plants. Notification i will be given directly to I&E Headquarters by way of the NRC Hotline ... it is

! preferable to report a questionable eveat than not. Therefere: for any operational, radiological, or security problem which is not expected and which may possibly generate public requests for information ... the NRC hotline will be also used to notify NRC Headquarters. It is considared that the following significant events are examples requiring NRC notificaiton: ...

l 3) Any event that results in the nuclear power plant not being in

! a cc ... ' led or expected condition while operating or shutdown. . ."

l Contrary to the abus , on March 5, 1981, an unexpected degradation in Residual Heat Removal Syster low through the core was not reported to the NRC Operations i

Center within one nc. . The degradation of core flow, due to apparent air

! entrainment in t ~ e F_ idual Heat Removal System pumps began at about 6:2 ,.t.

and was termir. ced a about 7:35 p.m. The NRC Operations Center was notit' / of the event via the NRC Emergency Notification System at 8:39 p.m.

l l Corrective Action Taken 1

Upon resolution of the reportability of the incident, the NRC Operations Center was notified via the NRC Emergency Notification System.

Action Taken to Prevent Recurrence l

This violation notice and the reporting requirements of 10 CFR 50.72 will -

covered in the Licensed Operator Retraining Program.

. w l* ,

Beaver Valley Power Station. Unit No. 1

_ Reply to Notice of Violatio

.,  : Appendix A .

Inspection- Report 81-08 Page 2

VIpLATION A (Continued)-

Date On Which Full Compliance Will Be Achieved Full compliance will be ' achieved by December 31, 1981.

VIOLATION B (Severity Level IV, Supplement 1)

Description of Violation (81-08-09).

l Technical Specification 6.8.1, Procedures, states, in part, " Written procedures j shall be established, implemented, and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide

.l.33, November 1972 ..."

Appendix "A" of Reguletory Guide 1.33, November 1972, Section C, states in part:

"C. Procedures for Startup. Operation, and Shutdown of S,fety Related PWR Systems I

Instructions for energizing, filling, venting, draining, startup, shutdowt, and changing modes of operation should be prepared, as cppropriate, for the following  ;

l systems:

1. Reactor Coolant System ...

4. Shutdown Cooling System ..."

Contrary to the above, on March 5, 1981, appropriate and adequate procedures for i the Reactor Coolant System and Shutdown Cooling (Residual lleat Removal) System were not properly established, implemented and maintained for oparation of these i systems during periods when the Reactor Coolant System (RCS) was partially drained.

l The licensee procedures, established as of March 5, 1981, for the conduct of operations with the RCS partially drained were:

BVPS OM Section 1.6.4.N, Draining the RCS to the Centerline of the llot Leg Loops for Maintenance, Issue 2, Revision 2.

I BVPS OM Section 1.10.4.J, Residual Heat Removal Operation When the RCS is Partially Drained, Issue 2.

3 BVPS CN Section 1.10.4.K, Abnormal Procedure: Loss of RHR with RCS Drained to tud Span of Loops.

4 I- --

BVPS OM Section 1.53.4, Emergency Operating Procedure E-20, Loss of Residual Heat Removal System, Iesue 2, Revision 4.

Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Appendix A Inspection Report 81-08 Page 3 VIOLATION B (Continued)

-- Corrective Maintenance Procedure No. 1-6RC-LT- TEMP-lI, Temporary RCS Level Indication, Revision 3.

Collectively, the procedures listed above failed to specify requirements for:

-- Tha frequency of operator surveillance of actual RCS water level (measured by a temporary standpipe inside containment);

-- Periodic cross-checking of temporary remote Control Room RCS level indication with actual RCS water level;

-- Periodic calibration checks of the temporary remote Control Room RCS level indication; or

-- Actions to be taken for either abnormal actual or remotely indicated RCS level.

The inadequate procedures appear to have contributed to the cause of degraded core flow on March 5, 1981.

Corrective Action Taken A procedure review was undertaken with regard to the Inspector's concerns to determine what revisions are needed to provide improved control over the Residual Heat Removal System during periods when the Reactor Coolant System is partially drained.

Action Taken To Prevant Recurrence Procedure revisions have been issued which require redundant level indication, periodic channal checks and required actions resulting f rom abnormal level indication in the Reactor Coolant System. Level transmitter calibration is accomplished prior to use and is recalibrated upon request from the operating group when a deviation between actual standpipe level and remote level indication is observed and recalibration appears necessary.

Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.

C

}

Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation i

Appendix A l Inspection Report 81-08 l Page 4 VIOLATION C (Severity Level V, Supplement 1)

Description of Violation (81-08-06)

Technical Specification 6.8.1, Procedures, states, in part, " Written procedures shall be -9tablished, implemented, and maintained covering the activities referenced below: ... c. Surveillance and test activities of safety related equipment ..."

Technical Specification 4.7.11.1, Residual Heat Removal System - Tavg < 350 F.,

Surveillance Requirements, states, "The Residual Heat Removal subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of Specification 4.7.10.1."

Technical Specification 4.7.10.1 states, in part, "Each residual heat removal subsystem shall be demonstrated OPERABLE: ... d. At least once per 18 months by verifying that each residual heat removal pump develops a diocharge pressure of 2 135 psig on recirculation flow." i Contrary to the above, licensee procedures covering these surveillance activities worn inadequately established, implemented, and maintained from December 8, 1978, to March 8, 1981, as indicated below:

Operating Surveillance Test (OST) 1.10.1, Residual Heat Removal Pump Performance Test, Revision 10, performed March 7 and 8, 1981, included erroneously worded acceptance criteria for the above Specification: i "The pump discharge pressure 3 135 psig." Neither performance of the test met the acceptance criteria of the Technical Specification in that j tests were performed at a system flow of about 4000 gpm vice only recir-culation flow; the pumps developed a differential pressure of 90 psid and 100 psid respectively; and, indicated discharge pressure was less  ;

than 135 psig for both pumps on both occasions.

1 l

Temporary Operating Procedure (TOP) No. 79-10, Residual Heat Removal Pump '

(1RH-P-1A 6 1B) Pump Curve Generation Procedure, Issued January 1979, and i

performed on January 19, 1979, and October 9, 1980, did not include acceptance criteria pursuant to TS 4.7.10.d or 4.7.11 bet appears to constitute the tests of record for the twenty-seven month period between December 8, 1978, and March 8, 1981. Although the test records indicate pump discharge pressures of 380-420 psig, system pressure (backpressure) was approximately 300 psig and differential pressure was less than 135 psig in all cases.

The test of October 9,1980 was performed at a system flow of about 4000 gpm vice recirculation flow only.