ML20045G197
| ML20045G197 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/02/1993 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307130031 | |
| Download: ML20045G197 (5) | |
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s Heaver Valley Power Station
. Shippingport, PA 15077-0004 JOHN D. SIEBER (412) 393-5255 Senior Wce Presider't and Fax (412) 643-8069 chief Nuclear Omce' July 2, 1993 Nuclear Power Division U.
S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 DV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/93-09 and 50-412/93 Reply to Notice of Violation i
In response to NRC correspondence dated May 25, 1993, and in accordance with 10 CPR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
This reply is being submitted within'30 days of.our receipt of the Notice i
of Violation as previously agreed to by our site Resident Inspector.
If there are any questions concerning this response, please contact Mr. N. R. Tonat at (412) 393-5210.
Sincerely, w-D.
Sieber Attachment cc: Mr.
L. W. Rossbach, Sr. Resident Inspector
'Mr. T. T. Martin, NRC Re'gion I Administrator Mr.
J.
P.
Durr, Chief, Engineering Branch Division of Reactor Safety, Region I Mr.
G.
E.
Edison, Project Manager Mr. M.
L. Bowling (VEPCO) nnnnnn
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DUQUESNE LIGHT COMPANY Nuclear Power Division i
Beaver Valley Power Station, Unit Nos. 1 and 2 s
Benly to__ Notice of Violation Combined Inspection Report 50-334/93-09 and 50-412/93-09 Letter dated May 25, 1993 VIOLATION A (Severity Level IV; Supplement IV)
Rescription of Violation (50-334/93-09-01)
Beaver Valley Unit 1 Technical Specification 6.12 requires that any individual permitted to enter high radiation areas in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be provided with a radiation monitoring device which continuously indicates the radiation dose in the area.
Technical Specification 6.12 requires that high radiation areas in which the intensity of radiation is greater than 1,000 mRom/hr shall be barricaded and conspicuously
- posted, and locked doors shall be provided to prevent unauthorized entry.
contrary to the
- above, on April 15,
- 1993, the requirements of Technical Specification 6.12 were not satisfied as evidenced by the following examples-1)
Two operators entered the
'A' penetration
- room, which was j
conspicuously posted as a
high radiation
- area, without a
radiation monitoring device.
2)
Two operators entered the
'C' reactor pump cubicle and left the entry way door full open such that the high radiation area, in which the intensity of radiation was greater than 1,000 mR/hr, was no longer barricaded, conspicuously posted, or locked.
Beacon for Violation The operators involved with the first event in the
'A' penetrations area were performing multiple entries into various cubicles for the purpose of posting equipment clearance tags.
As a result of a lack of attention to
- detail, the operators entered the
'A' penetrations without a meter.
The operators in the'second event involving the
'C' reactor coolant pump cubicle exercised poor judgment regarding the requirements for access control.
While posting equipment clearance tags on the reactor coolant loop flow instruments, they failed to close and lock the door to the cubicle.
They did not maintain a clear line of sight with the entrance to the doorway while they performed their task, hence access control was not established.
In both
- cases, a
lack of understanding and attentiveness to the requirements of Technical-Specification 6.12 was evident in the performance of their tasks.
~
l L
-Reply to Notice of Violation l
Page 2 9
Corrective Action Taken Interviews were conducted with the operators who were involved with the entry into
'A' penetrations area to determine the scope of their assignment and the areas they entered.
No other high radiation areas were accessed by these operators in the performance of their duties that day.
Their dosimetry was checked and each operator had an accumulated dose of 10 millirem.
Through radiation surveys, it was later determined that neither operator entered an area exceeding 100 mr/hr in the posting of their tags.
The operations personnel maintain the ability to provide health physics coverage for themselves through training and formal radiation detection meter qualification.
This meter qualification was immediately suspended for operations personnel on the day of the events.
Meter qualification privileges were reinstated following briefings by Operations supervision which emphasized the requirements of Technical Specification 6.12 and the responsibility of the operators to comply with this specification.
As a result of these L
briefings, some questions arose which required discussion with Health Pnysics management.
A formal response to these questions was provided to each member of the operations staff clarifying the appropriate station Health Physics requirements.
The four operators involved with the events were individually counseled and disciplined.
Action Taken to Prevent Recurrence These
- events, including the requirements and responsibilities of Technical Specification 6.12, will be reviewed by the Operations staff as part of their continuing retraining.
l l
The Health Physics Department is also establishing the use of a " Zone 6"
posting for areas that exceed 1000 mR/hr.
This is expected to clarify for station personnel the control requirements for these areas.
A multi-disciplined task force has been formed to assess the root causes of these and other events involving high radiation barrier improper entry or controls.
The task force is led by the Manager, Health Physics Department and includes members from Operations, Health
- Physics, and Training.
The task force will determine any additional changes needed to physical barriers, postings, station procedures, or training to maintain necessary standards for controlling access to high radiation areas.
Date When Full Compliance will Re. Achieved The station is in full compliance at this time.
l l
The revi'w of the above events and Technical Specification 6.12 will be cover o in Module 5 of Licensed and Non-Licensed Retraining which will be com, ated by September 30, 1993.
l The implementation of
" Zone 6"
postings will be completed by September 30, 1993.
_- =_
Reply to Notice of Violation Page 3, 4
VIOLATION B (Severity Level IV; Supplement I)
Description of Violation (50-412/93-09-03) 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
This requirement is implemented by Section 16 of Duquesne Light Company's Quality Assurance Policy, Revision 3.
Contrary to the above, on October 29, 1992, measures to assure prompt correction of a
condition adverse to quality were not taken when workers identified a
missing pipe support bracket for the 21B high head safety injection pump lube oil system in Unit 2.
A maintenance work request was generated to correct the condition; however, actual correction did not occur until April 15,
- 1993, following the discovery of a
similar condition on the 21C high head safety injection pump by NRC inspectors.
Feason for the Violation The deficient condition was not ct 'rected in a timely manner because the maintenance work request which originally identified the condition was improperly coded.
The improper coding indicated that work was necessary on a miscellaneous system instead of the safety injection system.
The improper coding disguised the safety significance of the missing pipe support clamp and resulted in the substantial corrective action delay.
Corrective Action Taken After the discovery of a
missing pipe support bracket and a loose pipe support bracket on the 21C High Head Safety Injection (HHSI) pump lube oil system by NRC Inspectors, the following actions were taken:
1.
A detailem Mdown of all the lube oil piping on all three HHSI pumps was p *>rmed.
A total of six (6) support brackets (U
bolts) were found missing (2 missing brackets for the 21B HHSI pump and 4 missing brackets for the 21C HHSI pump).
2.
The six missing brackets were replaced by transferring parts from the out of service 21A HHSI pump lube oil system.
After the procurement of qualified replacement parts, the brackets removed from the 21A HHSI pump were also replaced.
3.
Detailed engineering stress analyses were performed on the as-found support system for the lube oil piping on HHSI pump 21B (with 2 missing brackets) and 21C (with 4 missing brackets).
The analyses demonstrated that the stresses in the as-found lube oil piping system of both pumps were acceptable.
4.
A Problem Report (2-93-007) was initiated to evaluate the condition and determine reportability.
Reply to Notice of Violation Page 4 Action Taken to Prevent Recurrence A
review of the Maintenance Work Request Control Program has confirmed that provisions are included
- which, if appropriately
- followed, would have identified the improper coding which precipitated the delayed corrective action.
Those provisions include daily reviews of new Maintenance Work Requests by personnel from 1
Maintenance and Operations.
Had the Maintenance Work Request been properly evaluated, the safety significance of the missing pipe support clamp would have been recognized and timely corrective action l
would have been initiated.
In order to insure that such reviews are properly conducted, Maintenance and Operat. ions have collectively re-emphasized the significance of the daily reviews of new Maintenance Work Requt 3ts.
- Also, in the near
- term, a
notice to cognizant personnel will be published to further reinforce awareness of this issue.
Additional training to address the concerns raised by NRC Generic Letter 91-18 will be performed to reinforce the need for the accurate identification and reporting of degraded or nonconforming conditions.
Date When Full Compliance Will Be Ach_ieved The station is in full compliance at this time.
Additional
" Generic Letter 91-18" training will be completed by December 31, 1993.
,