ML20071Q289
| ML20071Q289 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/23/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20071Q269 | List: |
| References | |
| NUDOCS 8212290289 | |
| Download: ML20071Q289 (5) | |
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'Af Telephone (412) 456-6000 Nuclear Division P.O. Box 4 Shippingport, PA 15077 6 gg United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
R. W. Starostecki, Director Division of Project and Resident Programs Region 1 631 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. 82-22 Gentlemen:
In response to your letter of October 22, 1982, 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 identified two items considered to be in non-corpliance.
We share your concern regarding the recurrent nature of these items. We are taking steps to provide better administrative control in these areas as discussed in our attached reply.
In order to adequately address the recurrent items, additional time was required for this reply. This was discussed with our Resident Inspector and his management on November 22, 1982 at which time a com-mitment to submit our reply by November 29, 1982 was established.
If you have any questions concerning this response, please contact my office.
Very trily yours, J. J. Carey Vice President, Nuclear 8212290289 821222 PDR ADOCK 05000334 G
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-BIavsr Vallcy Power Station, Unit No. 1 Docket No.-50-334,. License No.'DPR-66 IE Inspection Report No. 82
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Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear.egulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 i
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DUQUESNE LIGHT COMPANY i,
Beaver Valley Power Station Unit No. l Reply to Notice of Violation Inspection 82-22 Letter dated October 22, 1982 i
VIOLATION A (Severity Level V; Supplement I)
Description of Violation (82-22-02)
Technical Specification 6.8 and Appendix A of Regulatory Guide 1.33, '
November,1972 require the implementation of procedures to control system i
operation and surveillance and test activities of safety related equip-ment. The BVPS OM Chapter 1.48.3, Section G, Adherence to Operating Procedures, Revision 22, requires activities affecting the nuclear safety of the plant be conducted in accordance with procedures developed for such activities and, in the event a procedure cannot be followed as written, the evolution should not be conducted unless required by an emergency situation, or the procedure has been revised, or a decision l
has been made by the Station Superintendent that a revised procedure is l
not necessary.
Contrary to the above:
1.
OST 1.11.9, Accumulator Isolation Valve Breaker Alignment Verifica-tion, Revision 5, was performed on September 9,1982 with the pressurizer pressure less than the minimum 2,000 psig specified in the initial conditions. No Operating Manual Change Notice had been submitted or approved to change this initial condition.
I 2.
Loop Calibration Procedure 24-L498, Steam Generator 1C Water Level Control Loop Calibration, Revision 4, was used to trouble shoot the 1C level control system on September 24, 1982 without meeting the specified initial conditions.
Corrective Action Taken 4
l 1.
We have reviewed the OST 1.11.9 event and determined that a revision I
is needed for the Startup Checklist (OM Chapter 50) to better define I
when the initial conditions can be satisfied. An OMCN has been I
issued to implement this change.
2.
Loop Calibration Procedure (LCP) 24-L498 was revised to correct the deficiency which resulted in the plant trip.
1 3.
The violation of the initial conditions in the procedures noted above have been discussed with the personnel involved.
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Bravar Vallsy Power Stnti:n, Unit Ns.1 htply to Notico cf Violaticn Inspection 82-22 Page 2 Action Taken to Prevent Recurrence The following actions will be taken to preclude similar noncompliances in the future:
1.
Supervisory and management personnel are performing a review of the procedure compliance requirements in the Station Operating and Maintenance Manuals and troublenhooting guidelines.
2.
Small group meetings with selected representatives in maintenance, operations and first-line supervisica will be conducted to discuss procedure compliance and their understanding of the current require-ments..
3.
Based on the information obtained in items 1 and 2 above, the pro-cedure compliance requirements contained in the Operating and Main -
tenance Manuals will be clarified.
4.
Following issuance of the new procedure revisions, training sessions will be conducted to inform personnel of the revised procedure com-pliance requirements.
5.
As an interim measure, a letter from the Station Superintendent has been issued to inform Station employees of Duquesne Light's concern regarding these instances of procedure violations.
With the increased awareness and involvement by Station personnel on this issue as indicated above, improvement in the area of procedure compliance is expected.
Date on Which Full Compliance Will Be Achieved Procedure revisions to clarify procedure compliance requirements will be issued by January 31, 1983.
VIOLATION B (Severity Level V; Supplement I) rescriptica of Violation (82-22-03)
The BVPS Quality Assurance Program (Appendix A to the FSAR), Section A.2.2.14, Inspection, Test and Operating Status; ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants; and QA Procedure OP-9, i
Technical Procedure Control for Operations and Maintenance, Revision 4, require the establishment of procedures for equipment control to maintain reactor and personnel safety and to avoid unauthorized operation of equipment. The BVPS OM Chapter 1.48.6, Section B, Mechanical and Electri-cal Clearance Procedures, Revision 19, requires the Reactor Operator or Flant Operator to update the Control Room prints and Status Boards when performing all clearance related valving and switching.
BEnv;r Vall;y Power Stcticn, Unit No. l '
Reply to Notice of Violation-Inspection 82-22 Page 3 Lescription of Violation, Continued Contrary to the above, the Control Room prints and Status Boards were not updated to reflect the operating status resulting from the following Equipment Clearances:
1.
No. 479543, Changing Filter 4B, posted June 28, 1982.
2.
No. 480017, Reactor Plant River Water Pump 1A Vacuum Breaker, posted September 9,1982.
3.
No. 480032, Diesel Generator No. 2 Cooling System Heat Exchanger B, posted September 20, 1982.
Corrective Action Taken Af fected drawings and status boards were corrected to reflect current plant conditions.
Operators on shif t at the time these discrepancies occurred were interviewed with their Shif t Supervisors and were reminded of the responsibilities associated with signing switching orders.
Actions Taken to Prevent Recurrence The Operations supervisor discussed the problem and the corrective actions with Operations personnel during Training Module II.
Operating Manual Chapter 48 is being changed to require Startup Operators writing switching orders to update Control Room drawings and status boards upon direction from on-shif t NCO or NSOF.
e The Startup Operators' Turnover Checklist is being modified to include a signof f for a daily review of previous day's clearances each midnight shift. The requirement for this review will be added to Operating Manual Chapter 48.
Letters have been issued to Operators and to NSS's and N50F's outlining the above mentioned changes and reminding everyone of their responsibili-ties in this area.
Date on Which Full Compliance Will Be Achieved Full compliance will be achieved by November 30, 1982 with the changes to Operating Manual Chapter 48.
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