ML20038B902
| ML20038B902 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/15/1981 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20038B900 | List: |
| References | |
| NUDOCS 8112090267 | |
| Download: ML20038B902 (9) | |
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w amn pa ma 4ss-swo 436 Sam Avertue
- =weh October 15, 1981 15219 United States Ni; lear Regulatory Commission Office of Inspection and Enforcement Attn:
R.
C.
Hayaes, Regional Director Region 1 631 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 81-18 Gentlemen:
In response to your letter of September 14, 1981, and in accordance with 10 CFR 2.201, the attached replies address the Notices of Violation which were included as Appendices A and B with the referenced Inspection Report.
i Since the Reply to Notice of Violation, Appendix B,
contains information subject to Section 2.790 (d), Title 10, Code af Federal Regulations and is, therefore exempt from disclosure, it is my understanding that this portion of this 81-18 response will not be placed in the Public Document Room 2nd will receive limited distribution.
Your letter specifically addressed Item A of Appendix B whereby you stated this item was identified during a previous inspec-tion and that our corrective actions were not effective since this item has recurred.
Additionally, you stated we should give particular attention to those actions taken or planned to ensure that identified items of noncompliance will be completely corrected and will not recur.
We share your concern in this matter and as a result, severe disciplinary actions were taken against those individuals who were involved in this incident.
In addition, all security force management personnel have teen instructed to attain a high degree of profession-alism in the performance of security duties.
Further, this incident was reviewed to reveal important " lessons learned" to prevent future recurrence of this type of incident.
We believe that these measures will be effective in assuring compliance.
If you have any questions concerning this response, please con-tact my office.
Verv truly yours, s'
8112090267 811109 1
PDR ADOCK 05000334 CY vl G
ppR J.
J.
Carey Vice President, Nuclear Attachments:
Reply to Notice of Violation, Appendix A Reply to Notice of Violation, Appendix B
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,Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 IE Inspection Report 81-18 Page 2 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 i
COMM0fMEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER
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/f day of
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, before dd[nthis6 @p h,>
, a Notary Public in and for said Commonwealth me, and Co0nty, personally appeared 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 kncwledge, information and belief.
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DUQUESNE LIGHT COMPANY g,,
Beaver Valley Power Station Unit No. 1 Ih- -
Reply to Notice of Violaiton Appendix A-
, In'spection No. 81-18 1
Letcer dated September 14, 1981 m.
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'i VIOLATION A '(Severity Level IV; Supplement I)
Description of Violation *(81-18-06) v Technical Specification (TS) 3.b.3.1 states in part, "The~ containment isola' tion valves specified in Table 3.6-1 shall be OPERABLE with isolation times *ns,shown_in Table 3.6-1.
APPLICABILITY:. Modes 1,
2, 3,
and 4.
ACTION:
Mith one or more of the isolation valve (s) specified in Table 3.6-1-inoperable, either:
...b.
Isolate the affected penetration wi, thin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deacti-vated automatic valve' secured in the isolation position, or..."
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Tabic 3.6-1, Amendment'23, Item C.1 lists Containment Purge Exhaust valves VS-D-5-3A and -3B and requires a demonstrated isolation (closure) time of 8 seconds for both.
The table also lists Contain-r#
ment Purge Exhaust. valves VS-D-5-3A and -3B and requires a demon-f,
strated isola tion -(closure) time of 8 seconds for both.
The table
- a l s o' lists Item C.2, Containment Purge Supply valves VS-D-5-5A and
-5B and requires demonstrated isolation times of 8 and 11 seconds respectively.
a Technical Specification 3.0.4 states " Entry into an OPERATIONAL MODE or other spe_cPfied condition shall not be made.unless the conditiens
- { p; of the limiting Condition for Operation are met without reliance on q,
provisions' contained in the ACTION statements requirements.
This provision,shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION requirements.
Exceptions to these q.
requirements ar,e, stated in the individual specifications".
9 Contrar'y to the above, on July 29, 1981, the facility entered into 4
Opeiational Moden 4 and 3 while relying on Action b of Technical S p e cifica t ion '3.'6. 3.1 in violation of Technical Specification 3.0.4 (d
Specifically:
0 Testing cf the above Containment Purge & Exhaust contain-ment isolation valves on July 24, 1981, in accordance with Operating Surveillance Test 1.1.10, Cold Shutdown Valve 1.
Exercise Test, Revision 23, established the individual
'l valDe isolation times to all be in excess of the require-
.m ments of Table 3;6-1.
The unacceptable test results were
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apparently not identified to licensee supervision at the
~tise of occurren'ce, but were identified by routine post-performance supervisory review about 10:40 a.m.
on July 29, 1981.
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Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation j
Appendix.A Inspection No. 81-18 Page'2 VIOgATION A (Continued)
Description'of Violation The valves were shut, their motor operators deactivated, and'their manual operators locked-prior to plant heatup from Mode 5 to Mode-4 thereby satisfying the require-ments of TS 3.6.3.1, Action b.
j The fecility entered ^ Mode 4 fro'm Mode.5 at 5:16 a.m.,
4 July.29, 1981, prior to licensee identification of the unacceptable test results and in coincidental compliance with the Action requirement.
This constitutes a licensee identified example of noncompliance with TS 3.0.4.
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Upon identification of the above circumstances, licensee management directed control room operators to maintain the' facility in Mode 4 (RCS Temperature less than 350*F)'
in accordance with TS 3.6.3'.1 and 3.0.4, pending resolution of the valve isolation time deficiencies.
Between 1:37 p.m.
and'2:00 p.m.,
July 31, 1981, RCS temperature was inadver-1 tently increased to 352-355'F, constituting entry into Mode
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3 while still relying on TS 3.6.3.1, Action b, in violation of Technical Specification 3.0.4.
This constitutes a second, inspector identified, example of noncompliance.
Corrective Action Taken The immediate corrective action taken was to initiate a plant cooldown to Mode 4.
Action Taken To Prevent Recurrence The Station Operating Supervisor conducted special training aessions with the operators in which each of these incidents and the actions which permitted them to occur were thoroughly discussed.
The BVPS Station Startup Checklists, have been reviewed and revised to-include all required OSTs.
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Beaver Valley Powe r Station, Unit No. 1 Reply to Notice of Violation Appendix A Inspection No. 81-18 Page 3 VIOLATION A (Continued)
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
VIOLATION B (Severity Level IV: Supplement I)
Description of Violation (81-18-07)
Technical Specification 6.8.1, Procedures, states in part, " Written procedures shall be established, implemented, and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Append'x "A" of Regulatory Guide 1.33, November 1972...
c.
Surveillance and Test activities of safety related equipment..."
Appendix A of Regulatory Guide 1.33, November 1972, Item B, General Plant Operating Procedures, recommends that procedures for "Startup-Cold to Hot" be established.
Contrary to the above, on July 29, 1981, procedures for plant heatup from cold conditions and procedures for administration of surveillance testing were inadequately established and maintained in that:
BVPS Operating Manual, Section 1.50.3, Station Startup Checklists, Revision 22, did not include verification of acceptable results for Operating Surveillance Test (OST) 1.1.10, Cold Shutdown Valve Exercise, as a prerequisite for plant heatup from Mode 5 (Cold Shutdown) to Mode 4 (Hot Shutdown).
OST 1.1.10 tests valves required to be operable in Modes 1,
2, 3,
and 4, and is at least partially performed during each Cold Shutdown period.
Startup Prerequisites list, dated July 28, 1981 (DLC Memorandum No. BVPS:LCS:141) similarly did not address OST 1.1.10.
EVPS Gyerating Manual, Section 1.55A.1, Periodic Checke - Operating Surveillance, Issue 1,
Revision 4, provides instructions for performance, documentation and review of OSTs, but does not address prompt identification of unacceptable test results for partially completed tests.
OST 1.1.10 was partially performed with unacceptable test results for Containment Purge and Exhaust Valves Nos. VS-D-5-5A,
-5B,
-3A, and -3B on July 24, 1981, after the facility had entered Operational Mode 4.
The subject valves were required to be operable (acceptable test results) prior to entry into Mode 4.
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Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Appendix A Inspection No. 81-18 Page 4 VIOLATION B (Continued)
Corrective Action Taken The Operating Surveillence Tests (OST) were reviewed to assure that those OSTs required for plant startup are included on the startup checklists.
Action Taken To P: event Recurrence Those CSTs required for plant startup, but not included in the BVPS Operating Manual Station Startup Checklists, have been included in the checklist to assure appropriate tests are complete prior to Mode changes.
Additionally, Operating Manuci Section 1.55A.1, Operat-ing Surveillence, has been revised to provide guidance for the prompt identification of unacceptable test results and instructions for the disposition of partially completed OSTs.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
VIOLATION C (Severity Level IV; Supplement I)
Description of Violation (81-18-03)
Technical Specification 3.7.15, Penetration Fire Barriers, states "All penetration fire barriers protecting safety related areas shall be functional.
APPLICABILITY.
At all times.
ACTION:
a.
With one or more of the above required penetration fire barriers non-functional, establish a continuous fire watch on at least one side of the affected penetration within one hour..."
Contrary to the above, on July 16-17, 1981, an electrical conduit penetration fire barrier in the common wall between the AE and DF Emergency Switchgear Rooms was only partially plugged with fire retardent material.
No fire watch was posted.
Each of the rooms comprises a separate fire protection zone and each contains one train of safety related electrical equipment.
Corrective Action Taken Immediately upon identification of the unsealed electrical conduit penetration, the Shift Supervisor had the penetration sealed with fire retardant material.
Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Appendix A Inspection No. 81-18 Page 5 VIOLATION C (Continued)
Action Taken To Prevent Recurrence A review of the construction department procedures which involve fire barriers was made by the Senior Safety Engineer.
Based on his review, the maintenance work procedure used by the construction department for the opening of fire barriers has been revised to include a pre-caution step to address the requirements of Technical Specification 3.7.15.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
VIOLATION D (Severity Level VI; Supplement I)
Description of Violation (81-18-08)
Technical Specification 6.5.1.8 states "The OSC shall maintain written minutes of each meeting and copies shall be provided to the General Superintendent of Power Stations and Chairman of the Off-site Review Committee."
Beaver Valley Power Station Administrative Procedure, Chapter 10, Onsite Safety Committee (OSC), Revision 1,
September 26, 1980; Step VI.A.2 states, " Minutes shall be recorded for all meetings, and all significant Committee actions shall be documented; minutes should be distributed to Committee members for review within one month of the meeting".
Contrary to the above, the following Committee actions were not documented in OSC meeting minutes generated during 1980:
Fourteen instances in which the quorum requirements at meetings were not clearly documented.
One instance in which a procedure review was not documented.
Review of sixteen out of 200 temporary procedure changes were not documented.
Investigations of violations identified in three inspection reports were not documented.
Many instances in which meeting minutes were not distributed for review within one month.
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Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Appendix A Inspection No. 81-18 Page 6 VIOLATION D (Continued)
Corrective Action raken A review of each of the inspectors concerns identified in the inspection report was conducted to determine the manner in which the documentation of Onsite Safety Committee actions could be improved.
Action Taken To Prevent Recurrence Iter No. 1:
It should be noted that this violation concerned Onsite Safety Committee (OSC) meetings conducted in 1980.
Technical Specification (TS) Amendment No.
39, issued on February 11, 1981, reconstituted the OSC membership.
Since this change, the quorum of the OSC has been properly established and documented for OSC meetings.
Item No. 2 The members of the OSC have been inatructed ta pro-and 3 vide the OSC Recording Secretary with information on materials presented for OSC review so ihat the meeting minutes will properly document these activities.
Item No. 4:
As stated in this inspection report, all inspection reports were documented in the OSC meeting minutes.
It is agreed that the method of documenting comnittee actions may not be consistent, however, each inspection report was reviewed and the statement
"...for informaticn only" documents that the inspection report was presented to the OSC.
The meeting minutes do state that all items on the agenda were reviewed.
To avoid cot. fusion in the future, the OSC Recording Secretary will be required to be more specific in documenting the reviews conducted by the OSC.
Item No. 5:
Additional personnel have been assigned to reduce the backlog of unissued OSC meeting minutes.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
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