ML20042A278
| ML20042A278 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/14/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20042A275 | List: |
| References | |
| NUDOCS 8203230278 | |
| Download: ML20042A278 (8) | |
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'Af' (412)4564000 435 Suth Aveaue Pittsburgh, Pa ism January 14, 1982 United States Nuclear Regulatory Commission Office.of Inspection and Enforcement Attn:
R. W. Starostecki, Director Division of Resident and Project Inspection Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley. Power f tation, Unit No.1 Docket No. 50-334, License No. DPR-66 IE Inspection Report No. 81-25 Gentlemen:
In response to your letter of December 15, 1981, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A with the referenced Inspection. Report. The Notice of Violation identific'i five items considered to _ be in noncompliance. The attached reply does not address Item E in your Appendix A as it was noted in your letter that we have already taken corrective action.
We would like to express our concern related to the classification of Violation E as a Severity Level III. We believe that the actual circumstances which occurred warrant NRC reclassification of this event as a Severity Level V as appears to be the case for any late surveillance test. We reiterate that this violation was identified by us, was promptly reported and prompt and effective corrective action was taken. We believe that the enforcement
' history, as published in the Atomic Energy Clearinghouse reports, resulting f rom events of a similar nature clearly point to an established NRC practice of classifying such events at Severity Level IV or V.
We understand that Region 1 has chosen to utilize the Interim Enforcement Policy as guidance for determining Severity Level classifications.
Severity Level III under this interim criteria does not recognize the fact that actual loss of a safety function or actual degradation of a safety system did not occur or could have occurred in the event of a loss of offsite power in this instance. We believe that use of the Interim Enforcement Policy does not suf ficiently consider the actual effect on the margin of safety. By using this logic, licensee violations are artifically escalated to higher severity level categories by incidents which could be considered to evidence programatic deficiencies warranting management attention, but having no real effect in reducing the actual margin of safety.
We believe that our corrective actions demonstrate our sincere concern for maintaining a high level of assurance of the operability of safety equipment in the plant.
KO PDR m
R. W. Starostecki, Director January 14, 1982 Page 2 -
While Paragraph 4.0.3 of the Technical Specifications requires that surveillance requirements be performed within the specified time interval to meet operability requirements for a Limiting Condition for Operation, failure to perform such tests does not demonstrate that equipment will not perform its intended function if required. The surveillance test for this item of equipment was performed promptly upon discovery of this missed surveillance and the equipment was shown to be fully operable at that time.
Therefore, the pump was fully capabic of performing its safety function during the seven day period which elapsed between the last date allowed to perform the surveillance and the date upon which the surveillance test was actually performed. This item of safety equipment was at all times capable of performing its safety function satisfactorily if required during any period of time that this equipment was in service. We believe that there was no actual degradation of the margin of safety; nor was there any measurable ef fect on the environment.
We have examined the enforcement history related to similar instances at other facilities which involve exceeding Limiting Conditions for Operation without satisfying the appropriate Action Statement.
In each of the nine similar instances which we have identified, Severity Levels of IV and V have been assessed for such events.
In view of the refinemenes made to the Interim Enforcement Policy as set forth in SECY-81-600 and the apparent practice of the NRC, as demonstrated in at least nine enforcement actions taken by the NRC in 1981, we believe that there is substantial justification for the reclassification of this event as a Severity Level V.
This reclassification would provide a consistent NRC application of
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the Interim Enforcement Policy.
If you have any questions concerning this response, please contact my office.
Very truly yours, J. J. Carey Vice President, Nuclea r cc:
Mr. D. A. Beckman, Resident Inspector l
U. S. Nuclear Regulatory Commission L
Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 1
COMMONWEALTH OF PENNSYLVANIA)
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a Notary /Public in and for said Commonwealth me, and County, 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 knowleoge, information and belief.
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of 71olation Inspection 81-25 Letter dated December 15, 1981 VIOLATION A (Severity Level V; Supplement I)
Description of Violation (81-25-04)
Technical Specification 6.4.1 requires a retraining program for the facility staff. The NRC approved operator requalification training program in BVPS Training Manual, Issue 2, Revision 2, Section 2.2.4.4, specifies that reading assignments, including facility procedure changes, will be periodically made for licensed operators and senior operators on shif t.
BVPS Operating Manual Section 1.48.3.F Issue 1, Revision 19 states the Operating Supervisor is responsible for making available copies of all new or revised procedures which may af fect station operations and for designating the operating personnel required to become familiar with each procedure and the date and time by which each procedure must be understood.
The Shif t Supervisor is responsible for assuring that shif t personnel designated by the Operating Supervisor become familiar with new or revised procedures before the procedure is used and for assuring that a record is maintained of the designated personnel who have been made familiar with and understand each procedure.
Contrary to the above, Operating Manual Revision Review No. 10, issued by the Operating Supervisor on September 17, 1981 with a review completion date of October 1,1981, and including revised Operating Procedures for eight plant systems, station logs, and administrative controls for operating, was reviewed and signed by only 19 of the 50 designated individuals by October 6,1981.
Corrective Action Taken i
The remaining 31 individuals reviewed and signed off Operating Manual Revision Review No. 10 in an expeditious manner.
l Action Taken To Prevent Recurrence l
l A review for completeness of the Operating Manual Revision Review form will be performed before the due date.
If the form is still incomplete, the Station Operating Supervisor will be notified and he will in turn inform the cognizant supervisor to have those individuals under his supervision complete the review at the earliest possible time.
t Date On Which Full Compliance Will Be Achieved l
Full compliance has been achieved at this time.
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Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Inspection No. 81-25 Page 2 VTOLATION B (Severity Level V; Supplement I)
Description of Violation (81-25-02) 10 CFR 30, Appendix B, Criterion XIII requires measures for the handling and storage of material and equipment to prevent damage or deterioration.
BVPS QA Procedure No. OP-6, Material Control, Revision 4, Part 6.6, requires trace-7 ability of an item from issuance f rom storage to installation in the station.
The BVPS Maintenance Manual, Chapter 1, Section R, Revision 0, requires that nonsalvageabic and salvageable material be placed in designated areas for storage until processed. The procedure also requires that material or items salvaged from BVPS equipment repairs, overdrawn stock, or other sources be repaired to uscable condition, and/or reclaimed into stock, and/or placed in a designated Storage Hold Area for future use, and tagged to indicate status.
Contrary to the above, on September 22-23, 1981, the following parts were stored in the No. 2 Emergency Diesel Generator Room without application of the above controls:
One gasket, Stock No. 852217, bearing a QA Accept Tag, I
-- Two gaskets, Stock No. 85222, bearing a QA Accept Tag, Seven metal gaskets without tag or other identification, About 18 fiber composition gaskets also untagged.
-- An untagged mechanical part appearing to be an Emergency Diesel Cencrator turbo-charger clutch.
Corrective Action Taken The parts identified in the inspection report were placed in a locked cabinet in the Emergency Diesel Generator. Room No. 2.
Action Taken To Prevent Recurrence All foreman will be instructed on the disposition of salvagable and nonsalvagable materials as described in Section R of the Maintenance Manual, Chapter 1. In addition, this section will be revised to control untagged parts and non-QA spares to prevent inadvertant or unauthorized use in QA Category I applications.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by February 15, 1982, i
c Beaver Valley Power Statione Unit No. 1 Reply to Notice of Violation Inspection No. 81-25 Page 3 V10I.ATION C (Severity Level VI; Supplement IV)
Description of Violation (81-25-03)
Techncial Specification 6.11, Radiation Protection Program, states, " Procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure."
The BVPS Radiological Control Manual, Radeon Procedure 10.1, Respiratory Equip-ment, Issue 1, Revision 5, Section 3.7, Returr.ing Respiratery Equipment, states, "It is the responsibility of the individual to whom the respiratory equipment is issued to:
3.7.1 Deposit the used reupirators in receptacles provided, or 3.7.2 If the respiratory equipment was worn and protection factors were assigned, the equipment is to be retained as designated by Radeon."
Contrary to the above, on September 25, 1981, apparently used respirators were observed lying in each of two stepof f pad areas adjacent to Contamination Zones.
Specifically, one respirator was observed at the exit f rom the Safety Injection Test Pump platform on the 735 ft. elevation of the Primary Auxiliary Build!ng, A second respirator was observed in the Solid Waste Compactor area on the same elevation.
Receptacles designated specifically for disposal of used respirators were not present in either area.
Corrective Action Taken A Radeon Foreman had the respirators retrieved for proper disposal and directed placement of additional receptacles at locations where respirators are presently used. Additionally, laborers police step-off pads and anti-C clothing locations at least daily to retrieve used items.
Action Taken To Prevent Recurrence An evaluation is being performed to determine receptacle type, size and replace-ment to enable proper disposal of used respirators.
In additon, the receptacles will be appropriately identified.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by February 27, 1982.
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Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Inspection Report No. 81-25 Page 4 VIOLATION D (Severity Level V; Supplement I)
Description of Violation (81-25-07)
Technical Specification 6.8.13 states, " Written procedures shall be established, implemented and maintained covering the activities referenced below:
a.- The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972..." Regulatory Guide 1.33-1972, Appendix "A",
Section J, Chemical and Radiochemical Control Procedures, states, in part, " Chemical and Radio-chemical control procedures should be written to prescribe... instructions main-taining water agents that may cause corrosive attack or fouling of heat transfer surfaces, or that may become sources of radiation hazards due to activitation..."
The BVPS Chemistry Manual Administrative Controls, Part 3, Chemistry Manual Description,Section II.B, Chemical Specifications, Issue 2, states, "The pur-pose of Chapter 1 (Water Specifications) is to present the water chemistry specification requirements for various plant systems and components. The chapter shall also include all permit and technical specification requirements relative to chemistry. Finally, this chapter will present a tabulation which will present recommended corrective actions to be taken for rectifying out of specification conditions."
The BVPS Chemistry }bnual, Chapter 1, Part 1, Reactor Plant Specifications, Issue 1, Revision 4, provides limits for numerous chemistry parameters not separately addressed by Technical Specifications including the following (and others):
Boric Acid Hold Tank:
Fluoride, Silica, and Alumina concentration; Refueling Water Storage Tank:
pH, Chloride concentr tion, Fluoride m
concentration, Suspended Solids, Total Solids; Boric Acid Storage Tanks: Chloride, Fluoride, and Silica concentration; Primary Grade Water Tanks: Chloride concentration, Fluoride concentration, Total Solids, Suspended Solids; Coolant Recovery Tanks: Boron concentration, Conductivity.
Contrary to the above, on September 8 - October 13, 1981, instructions for maintaining water quality within prescribed limits and limitations on concentration of agents that may be detrimental to safe operation were inadequately established and implemented in that the BVPS Chemistry Manual, including Chapter 1, Part 8, Reactor Plant - Corrective Actions, Issue 1, Revision 4, did not:
Provide instructions for corrective actions when the parameters above (and others) exceed the specifications provided; Identify the parties responsible for implementing corrective actions; Provide for management escalation / review of out-of-specification para-meters as an alternative to parameter-specific procedures; or l
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1 Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Inspection Report NO. 81-25 Page 5 VIOLATION D (Continued)
Description of Violation Provide rethods of documentation and followup of corrective-actions to m,sure their implementation and/or effectiveness.
Corrective Action Taken The Chemistry Manual was reviewed against the inspectors concerns.
It is agreed that clarification in the Chemistry Manual of these concerns will improve the method of maintaining water quality within prescribed limits.
Action Taken To Prevent Recurrence The Chemistry Manual will be revised to include additional instructions for corrective actions when parameters exceed the specifications provided. An "Open Item". log will be initiated which will be used as a management tool to identify the parties responsible for implementing corrective actions, to provide for management escalation / review of out-of-specification parameters and to serve as a documentation method for following-up on corrective actions to ensure implementation and/or effectiveness.
Date On Which Full Compliance Will Be Achieved Full Compliance will be achieved by March 1, 1982 55