ML20046D144
| ML20046D144 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/10/1993 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308160194 | |
| Download: ML20046D144 (4) | |
Text
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( 1L hN O'awer Valiey Power Station D. B Shippingport. PA15077-0004 August 10, 1993 JOHN D. SIEBER (412) 393-5255 Sernor Vice President and Fax (412) 643-8069 Chief Nuclear Officer 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 j
BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspectica Report 50-334/93-12 and 50-412/93-13 Reply to Notice of Violation and Notice of Deviation In response to NRC correspondence dated July 2, 1993, and in accordance with 10 CFR 2.201 and 10 CFR Part 2, Appendix C, the attached replies addresses the Notice of Violation and the Notice of Deviation transmitted with the subject inspection report.
This reply is being submitted within 30 days of our receipt of the Notice of Violation and the Notice of Deviation as previously agreed to by the site Resident Inspector.
If there are any questions concerning this response, please
. contact Mr..N. R. Tonet at (412) 393-5210.
Sincerely, t.A.e-----~
D. Sieber Attachment cc: 'Mr. L. W. Rossbach, Sr. Resident Inspector-l:
Mr. T. T. Martin, NRC Region I Administrator Mr. J.
C.
Linville, Chief, Project Branch No. 3 Division of Reactor Projects, Region I Mr. G.
E.
Edison, Project Manager-Mr. M. L. Bowling (VEPCO)
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DUQUESNE LIGHT COMPANY Nuclear Power Division v
Beaver Valley Power Station, Unit Hos. 1 and 2 l
Reply to Notice of Violation Combined Inspection Report 50-334/93-12 and 50-412/93-13 Letter dated July 2, 1993 VIOLATION A (Severity Level IV; Supplement I)
Description of Violation (50-334/93-12-01) 10 CFR 50, Appendix B,
Criterion V,
requires that activities-affecting quality have been prescribed by and accomplished _in accordance with instructions, procedures, or drawings which include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the
- above, on June 8,
- 1993, an activity affecting
- quality, reactor coolant system
- heatup, was not accomplished in accordance with instructions or procedures which included appropriate acceptance criteria in that the operator aid for reactor coolant system pressure and temperature limitations curve, figure OM-50-11, issue 3,
revision 8,
was of the incorrect revision and contained outdated acceptance criteria.
Reason for Violation f
A revision to the Unit 1 Operating Manual was necessary as a result
[
of a
new operating cycle heat-up curve.
This revision was performed using an Operating Manual Change Notice (OMCN).
The distribution of the OMCN requires changing any affected operator aids.
The operator aid in this case was the copy of the heat-up curve which is located on the reactor operator's portion of the main control board.
While the change to the heat-up curve was properly made in the Operating
- Manual, the individual performing the distribution inadvertently i
omitted changing the reactor operator's control board copy.
Thus the reason for the existence of the incorrect heat-up curve revision was personnel error.
Corrective Actions Taken The correct revision of the Unit 1 heat-up curve was immediately.
placed on the reactor operator's' console.
Reactor Coolant System pressure and temperature were within the acceptable range of operation when this deficiency was identified.
The remaining operators aids at the Unit 1 operator's console were checked to ensure the proper revisions were in place.
It was discovered that the corresponding cooldown curve was also of the incorrect revision, and that curve was also immediately replaced with the correct revision.
Data from the Unit 1 cooldown on March 27, 1993 was reviewed and determined to be in the range of acceptable operation for the correct cooldown curve.
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. Reply to Notice of Violation Combined Inspection Report 50-334/93-12 and 50-412/93-13
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Page-2 Corrective Actions Taken, (Continued)
All remaining Unit 1
curves were verified to be the proper revisions.
The corresponding curves located at the Unit 2 reactor operator's console were verified to be the correct revision.
Actions Taken to Prevent Recurrence The preliminary investigation could not identify the individual who placed the specific OMCNs into the Unit 1 manual.
It was determined that numerous individuals could have potentially distributed the heat-up curve changes.
Operation's
- clerks, procedure
- writers, administrative assistants, and program engineers had previously distributed OMCNs depending on the nature and timeliness of the change.
A lack of understanding of the distribution requirements is believed to be the cause for the failure to place a copy of the revised curve on the operator's console.
To preclude recurrence, two letters were issued by the
'Init 1 Operations Manager.
One letter defined and limited the nurP2r of individuals who distribute OMCNs.
This action limits the individuals distributing OMCNs to a
small group having accountability for maintaining the Operating Manual and operator aids.
The second letter clarified the method by which OMCNs are processed, since the preliminary investigation identified the need to simplify and clarify this process.
This letter outlines the OMCN distribution process in detail and focuses on the importance of correctly changing the Operating Manual and the operator aids.
In order to further investigate this event and enhance the process of incorporating OMCNs into the Operating Manual, a human performance evaluation will be performed for this event.
Additional process improvements will be implemented as necessary to ensure operator aids are the current revision.
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l Date When Full Compliance will be Achieved i
The station is in full compliance at this time.
The human performance evaluation will be completed by November 12, 1993.
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i DUQUESNE LIGHT COMPANY i
Nuclear Power Division l
Beaver Valley Power Station, Unit Nos. 1 and 2 j
i Reply to Notice of Deviation Combined Inspection Report 50-334/93-12 and 50-412/93-13 f
Letter dated July 2, 1993
{
l Description of Deviation (50-412/93-13-02) t Duquesne Light Company
- letter, J.
D. Sieber to U.
S.
NRC, "10 CFR I
50.62, ATWS Rule Implementation,"
December 2,
- 1987, states that i
periodic testing of AMSAC will include a "funct.onal test of the
[
logic, time delays, and setpoints."
Contrary to the above, periodic testing of Unit 2 AMSAC, including a functional test of the time delays and setpoints, has not been accomplished since original AMSAC installation in 1989.
Reason for Deviation Operational Surveillance Tests (OSTs) were issued for both Unit 1 and l
Unit 2
to perform part of the required functional checks.
A maintenance procedure to test AMSAC logic, time delays and setpoints was issued to perform the remainder of the functional tests for Unit 1.
- However, the equivalent procedure for Unit 2 has not yet l
been developed.
Corrective Actions Taken A
Plant Problem Report (2-93-027) and associated Basis for Continued i
Operation were written to document and evaluate the deviation.
l A
task has been initiated on _the maintenance tracking system to develop and issue a test procedure for Unit 2 AMSAC.
The procedure-will be issued and the testing performed during the fourth Unit 2 l
refueling outage, scheduled to begin in September 1993.
j Action Taken to Prevent Recurrence I
'With the development of this maintenance procedure to test AMSAC i
- logic, time
- delays, and setpoints, all procedures necessary to perform detailed testing of the Unit 2 AMSAC_will be available and will be implemented on an 18 month frequency.
Date When Corrective Actions will be Completed l
The procedures to fully test Unit 2
AMSAC will be developed and testing will be -completed prior to restart from the fourth Unit 2 i
refueling outage, scheduled to begin in September 1993.
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