ML20064H390
| ML20064H390 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/09/1994 |
| From: | Seiber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9403170285 | |
| Download: ML20064H390 (6) | |
Text
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'f Beavet Valleh Power Station Shippingport. PA 15077-0004 March 9, 1994 JOHN D. SIEBER (412) 393-5255 Sernor Vice President and Fax (412) 643-8069 Chief Nuclear Othcer 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 l
BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Reply to Notice of Violation In response to NRC correspondence dated February 1, 1994, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
'In addition, in accordance with the NRC's request included in the above correspondence, the attached reply also addresses.the actions that were taken and will be taken to prevent recurrence of the administrative error that led to incorrect information-being relayed.
to the NRC staff during.the telephone conference on November 4,.1993.
If there are any questions concerning-this response, please contact Mr. N. R. Tonet at (412) 393-5210.
Sincerely, 4
J.
D.
S eber Attachment cc:
Mr.
L.
W..Rossbach, Sr. Resident Inspector l
Mr. T. T. Martin, NRC Region I Administrator
.Mr.
G.
E.
Edison, Project Manager Mr.
J.
P. Durr, Chief, Engineering Branch Division of Reactor Safety, Region I jrAgpn*
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t DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit Nos. 1 and 2 Reply to Notice of Violation NRC Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Letter dated February 1, 1994 VIOLATION (Severity Level IV; Supplement I)
Description of Violation (50-334/93-24-02 and 50-412/93-24-02)
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XV, "Nonconformiug Materials,
- Parts, or Components,"'
requires that, "[m]easures shall be established to control materials,
- parts, or components which do not conform to requirements in order to prevent their inadvertent use.
These measures chall include procedures for identification, documentation, segregation, disposition and notification to affected organizations.
Nonconforming items shall be reviewed and
- accepted, rejected, repaired or reworked in accordance with documented procedures."
Contrary to the above, as of November 30, 1993, measures to control,
- identify, document, segregate,
- review, and disposition misapplied eyebolts installed on motor-operated valves (MOVs) with Limitorque l
SMB-00 and SMB-000 actuators were not accomplished, although this condition was known in May 1993.
This resulted in eyebolts remaining in MOV-CH-308A, MOV-CH-373, 2CHS-MOV308B, and 2CHS-MOV308C during static testing with torque switches set to allow the MOVs to deliver thrust in an extended thrust range of the actuators.
I I
Rapson for Violation The reasons for the violation are as follows:
1.
The requirements of the Vendor Technical Information were included in the Motor Operated Valve (MOV) Preventive Maintenance-Procedure (PMP) but not in the Corrective Maintenance Procedure (CMP).
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2.
The Vendor Technical Information was incorporated into the training program material, but it was not emphasized nor were all f
qualified electricians trained on this material.
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3.
Work performed prior to the PMP revision to address the eyebolt I
removal was not reviewed to determine if extended thrust values had been applied.
I
i Reply to Notice of Violation NRC Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Page 2 Corrective Action Taken Corrective action was initiated by a review of maintenance records of SMB-00 operators at BV-1 performing to determine which operators could have eyebolts installed.
This effort was supplemented by a walkdown of accessible areas outside the containment.
The review and walkdown identified a potential for 25 valves inside the containment and 16 valves outalde the containment with SMB-00 operators which could have cyobolts installed.
As a result of the review and in accordance with a
commitme.nt made during a conference call with the
- NRC, a
visual inspection was performed of the 16 valves outside containment.
Immediately following the BV-1 inspections, a similar walkdown was performed at BV-2 which was in a scheduled outage at that time.
One valve at BV-1 and two valves at BV-2 were found with eyebolts installed and MOV static testing completed.
These valves were set for operation at an extended thrust rating beyond their commercial rating.
At that time, the startup of BV-1 was placed on hold and efforts were initiated to determine the nature of the discrepancy noted and the extent of required actions to be taken.
An action plan was developed for inspecting all Category 1 operators (SMB-00 and SMB-000) at BV-1 and completing any corrective actions deemed necessary.
Independent inspections were performed by Maintenance Engineering and Quality Control personnel.
Identified deficiencies were dispositioned by Maintenance Engineering and reviewed by Design Engineering.
After completion of the BV-1 effort, a similar inspection was performed at BV-2.
The results of these inspections identified a total of two valve operators at BV-1 and five valve operators at BV-2 which had eyebolts installed and were set for operation at an extended thrust' rating.
The eyebolts were removed from these seven valves and required fasteners were reinstalled in their place.
.In addition, four valve operators at BV-1 were found with linear indications in either the housing or top housing cover.
The housing or housing cover on the affected valves were replaced.
Actigns Taken to Prevent Recurrence After reviewing the results of the inspections and the. events summarized
- above, it was determined that the following actions would be taken to prevent recurrence:
1.
Generate maintenance work requests (MWR's) for removal of all eyebolts from Category i
valve operators during the next refueling outage for each unit.
2.
Evaluate the MOV testing program and MOV inspection program and make appropriate adjustments to ensure that the programs are consistent.
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Reply to Notice of Violation NRC Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Page 3 Aqtigas Taken To Prevent Recurrence, Continued 3.
Perform a
formal evaluation of Maintenance processing of Vendor Technical Information and implement the corrective actions as.
appropriate.
4.
Review the existing MOV training program and implement any enhancements necessary to emphasize proper MOV operator inspection criteria and maintenance requirements to field maintenance personnel.
Date When Corrective Actions Will Be Co.pplete Actions completed or which remain to be completed include those actions to prevent recurrence.
These actions have been or will be completed according to the following schedules.
Action 1 is complete with MWR's generated for each unit refueling outage.
Action 2
will be completed by March 31, 1994 Jor BV-1 and June 24, 1994 for BV-2.
Actions 3 and 4 will be completed by September 30, 1994.
Additional Actions Taken to Prevent Recurrence of Administrative Error That Led to Incorrect Information The following describes actions to prevent recurrence of the subject 4
violation and the administrative error that led to incorrect information being relayed to the NRC staff during the telephone conference on November 4, 1993.
The Nuclear Safety Department (NSD) has developed and issued a document entitled
" Guidelines for Communications with the NRC."
The guideline document includes the following items:
A copy of 10 CFR 50.9.
A discussion of the seriousness of communicating incorrect information, even though unintentional.
Guidance on what to do if a
communicated response is subsequently determined to be incorrect.
Guidance on providing accurate information and developing the necessary internal documentation and tracking of commitments made during the course of any communication with the NRC.
A quick reference one page summary of the guideline intended for desktop or departmental bulletin board use.-
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Reply to Notice of Violation j
-NRC Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Page 4 a
1 Additional Actions Taken to Prevent Recurrence of Administrative Error That Led to Incorrect Information Continued
)
4 In addition to the existing process for written communications, specific commitments regarding NRC correspondence are being identified in order to assist in the identification, capture, assignment, and tracking of regulatory commitments.
The appropriate personnel have been counseled.
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1
,. ' Reply to Notice of Violation NRC Combined Inspection Report Nos. 50-334/93-24 and 50-412/93-24 Page 5 4
VIOLATION (Severity Level IV; Supplement I)
Description of Violation (50-334/93-24-01 and 50-412/93-24-01)
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion
- XVI,
" Corrective Action,"
- requires, in
- part, that
"(mjeasures shall be established to assure that conditions adverse to
- quality, such as
- failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above, as of October 30, 1993, measures had not been taken to ensure that MOV anomalies observed during an NRC inspection in April 1992 had been promptly identified and corrected for MOV-QS-100A, MOV-QS-100B, MOV-SI-885A, MOV-SI-885B, MOV-SI-885C, and MOV-SI-885D.
Subsequent inspection identified deficient conditions such as loose bolts, worn parts and housing cracks.
Reason for Violation The reasons that measures had not been taken to ensure that MOV anomalies observed during an NRC ir spection in April 1992 had been properly identified and corrected ducing the Ninth Refueling Outage (1R9) at BV-1 are provided below:
1.
On May 6, 1992, in a conference call to the NRC, a commitment was made to inspect the subject valves during 1R9.
In a subsequent conference call on May 14,
- 1992, this commitment was 4
misinterpreted and resulted in the -rescheduling of the valve inspections as allowed by the guidelines of GL 89-10.
2.
Inadequate follow-up to the commitment tracking system allowed certain valves that were initially scheduled to be inspected during 1R9 to be rescheduled to the Tenth Refueling Outage (1R10).
)
C_ocrect.va_Aallon Taken Immediate action was taken to inspect the valves in question in accordance with the preventative maintenance procedure.
All anomalies found were corrected.
Action Taken to Provent Recurrence The schedule change process will be evaluated and a method for reconciling regulatory commitment impact on a schedule change will be established before the next refueling outage.