ML20063P616
| ML20063P616 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/30/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20063P613 | List: |
| References | |
| NUDOCS 8210150018 | |
| Download: ML20063P616 (4) | |
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'Af Telephone (412) 4564000 Nuclear Division P.O. Box 4 Shippangport, PA 150774004 September 30, 1982 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Richard W. Starostecki, Director Division of Project and Resident Programs 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. 82-16 Gentlemen.
In response to your letter of August 30, 1982, and in accor-dance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A with the referenced Inspection Report.
If you have any questions concerning this response, please contact my office.
Very truly yours, 9
J. J. Carey Vice President, Nuclear Attachment cc:
Mr. We M. Troskoski, 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 8210150018 821008 PDR ADOCK 05000334 0
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection 82-16 Letter dated August 30, 1982 VIOLATION A (Severity Level IV, Supplement I)
Description of Violation (82-16-01)
Technical Specification 6.8 and Appendix A of Regulatory Guide 1.33, November,1972 require the implementation of procedures to control lif ted leads and jumpers. The BVPS OM Chapter 1.48.5, Section D.
Jumper and Lif ted Leads, Revision 5, requires an independent verifica-tion of installation and/or removal of jumpers and lif ted leads which are used in performance of a test or checkout covered by an approved procedure.
Contrary to the above, connector cables to Power Range Monitor NI41 Detectors A and B were reversed on July 17, 1982 during performance of Maintenance Surveillance Procedure (MSP) 2.03, Power Range Neutron Flux Channel N-NI41 Quarterly Calibration, Revision 15.
The independent verification failed to identify and correct the error.
Corrective Action Taken When it was discovered that the detector cables of N-NI41 were reversed, the cables were reconnected to the correct positions.
Action Taken To Prevent Recurrence A revision has been made to MSP 2.03 to provide positive identification of the correct cable connection by the use of the cable identification number rather than the connector number which is worn and difficult to
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read. A similar change has been made to the surveillance procedures for N-NI42, 43 and 44 as well.
In addition, this violation has been reviewed with the Meter and Control Repairmen (MCRs) by the Instrument and control Supervisor in a recent safety meeting in order to place increased emphasis on the need for proper restoration of plant equipment.
Date On Which Full Compliance Will Be Achieved l
Full compliance has been achieved at this time.
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Riply to Notics of Vioiction
-Inspection 82-16 Page 2 VIOLATION B (Severity Level V, Supplement I)
Description of Violation (82-16-02)
Technical Specification 6.10.1d requires that records of required surveillance activities be maintained for at least five years.
Contrary to the above, records of Maintenance Surveillance Procedure 39.01, Battery No. 1 Test and Inspection, Revision 13, performed June 27, 1982 and Operational Surveillance Test 1.1.11, Safeguards Protection System Train A Test, Revision 34, Turbine and Feedwater Pump Trip Test Section, performed in July,1982 were either misplaced or discarded.
Corrective Action Taken Bdth incidents were investigated to determine if the records could be lo ca ted.
It was found that the MSP in question had been discarded when it was determined that it couldn't be completed 'nd would have co be revised and reperformed at a later date.
In the case of the OST, a portion of the test had to be done at a later date. While it acpears that the unfinished portion of the test was later completed, the data associated with that portion of the test was misplaced and not included with the OST.
Action Taken To Prevent Recurrence A change to the Maintenance Manual has been initiated to insert a caution in Section D, Maintenance Surveillance, regarding the proper handling of incomplete MSP records.
It is expected that this change and appropriate familiarization training for Maintenance will be com-pleted by October. 31, 1982.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by October 31, 1982.
R: ply to Notico cf Violation -
In pecticn 82-16 Page 3 VIGLATION C (Severity Level IV, Supplement I)
Description of Violation (82-16-06)
ANSI Standard N45.2-1971, Quality Assurance Program Requirement for Nuclear Power Plants (endorsed by the BVPS FSAR), BVPS Operations Quality Assurance Procedure OP-13, Control of Nonconforming Items, Revision 5, and Nuclear Division Directive No. 4, Corrective Action Systems, October 12, 1981, require the implementation of a corrective action system to assure that significant conditions adverse to quality are promptly identified and corrected. Nuclear Division-Site Administra-tive Procedures, Chapter 1 Section VI.H., Equipment Failure or Abnormal Condition, Revision 0, requires that abnormal conditions be investigated and ccrrective action steps instituted as appropriate to correct the condition.
Contrary to the above, corrective actions taken as a result of violating Radioactive Waste Discharge Authorization (RWDA) - Liquid No. 1901 on July 23, 1982, were not effective in preventing a similar unauthorized release of radioactive liquid waste from Steam Generator Drain Tank 7A on July 27, 1982.
Corrective Action Taken Both incidents were investigated and it appeare that although we took tha corrective actions established as a result of the first incident, this was not sufficient to prevent a similar occurrence.
The contribu-ting problems as noted in the inspection report were (1) an error in the methods used to calibrate the tank level transmitters and (2) the lack of remote indication in the Control Room.
As a result of our review, Maintenance Work Requests (MWRs) were issued to calibrate the tank level transmitters to account for their as-built conditions (transmitter tap at one foot above tank bottom) and to check the alarm setpoints. MWRs 821909 and 821857 were subsequently satisfac-torily completed.
Action Taken to Prevent Recurrence HSPs 17.01, 17.02, 17.03 and 17.04 are being developed to insure the proper calibration and alarm checks for the tank level transmitters in the future.
1 Also as a result of our investigation, a Station Modification Request (SMR 641) has been issued to request:
(1) remote level indication in the
' Control Room, (2) installation of a permanent level sightglass and (3) in-sta11ation of manual inlet isolation valves.
Date on Which Full Compliance Will Be Achieved With the re-calibration of the tank level transmitters to account for as-built conditions, full compliance has been achieved at this time.
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