ML20085N420
| ML20085N420 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/04/1991 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111150117 | |
| Download: ML20085N420 (9) | |
Text
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November 4,1991 JOHN O SIEBER Vee Prndent Nuclear Group Director, Office of Enforcement )
U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555
Subject:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Notico of Violation and Proposed Imposition of Civil Penalty Gentlemen:
In response to NRC correspondence dated October 8, 1991 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation and Proposed Imposition of Civil Penalty which was enclosed with your letter.
The cited events were discussed in Inspection Report Nos. 91-09 and 91-14 and also in an Enforcement Conference held on August 5, 1991.
A check in the amount of $25,000 is enclosed for payment of the civil penalty.
If there are any questions concerning this response, please contact Mr. Nelson Tonet at (412) 393-5210.
Sincerely,
')J' J. D. Sieber Attachment cc: Mr. J. Beall, Sr. Resident Incpector Mr. T. T. Martin, NRC Region I Administrator Mr. A. W. DeAgazio, Project Manager Mr. M. L. Bowling (VEPCO) ff f o.
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4 CO.4MONWEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER )
On this . . / day of / (T C)tCIL/ar / , 1991, before me, d,_L_dZ- / #1k a Notary Public in c.1d for said Commonwealth and Ccunty, personally appeared J. D. Sieber, who being duly sworn, depo.:cd, and said that (1) he is Vice President - Nuclear of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittul on behalf of said Company, and (3) the statements set forth in the submittal .tre true and correct to the best of his knowledge, information and beltet.
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l DUQUESNE LIGHT COMPANY
. Nuclear Group Beuver Valley Power Station Unit No. 1 i Reply to Notice of Violation and
! Proposed Imposition of civil Penalty Letter dated October 8, 1991 VIOLATION I (Severity Ls.el III; Supplement I) p_e_s_trlption of Violatiqn (50-334/91-14-03)
A. 10 CFR Part 50 Appendix B, Critorion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality and nonconformances are promptly identified and corrected.
Contrary to the above, as of July 9, 1991, the licensee did not take prompt and adequate corrective action for a quality assurance auditor's finding on June 12, 1991 that identified that a longitudinal pipe weld on the low head safety injection system (LHSI) ris not on his drawing and not included in the ISI program, or for a SSFE finding in 1989 concerning similar longicudinal welds. Specifically, in neither instance had the llcensee conducted sufficient additional reviews to identify and resolve similar problems with longitudinal pipe welds which were present in other safety-related piping.
10 CFR 50.55a(g) requires, in part, that components shall meet the requirements of paragraph (g) (4) of this section and piping shall meet the requirements applicable to components which are classified as ASME Code Class 2.
10 CFR 50. 55a (g) (4 ) requires, in part, that components which are classified as ASME Code Class 2 shall meet the requirements set forth in nplicable editions of Section XI of the ASME Boiler and Pressure vessel Code. The applicable edition of the Code is the '
1974 Edition through Summer of 1975 addenda.
Sectior. XI, Article IWC-2000, requires, in part, that inservice examinations be performed on longitudinal weld joints in pipe fittings such that the intervals between examinations will not exccel the 10 year inspection interval.
Contrary to the above, (1) on June 18, 1991, licensee engineering personnel 3dentified 76 longitudinal welds (45 of which were fitting welds) on the low head safety injection system that were classified as ASME Code Class 2, and that were omitted from the Unit 1 isometric and vendor supplied drawings, resulting in the failure to include these welds in the licensee's inservice inspection (ISI) program and the failure to inspect these welds during the first 10 year ISI interval which ended in 1988; and (2) subsequent document review, on July 11, 1991, also revealed
Reply to Notice of Violation Page 2 l
i 76 Icigitudinal welds (66 of which were fitting welds) in the residual heat removal and 71 longitudinal welds (71 of which were fitting welds) in the high head safety injection system which were not included and inspected in the first 10-year interval of the ISI program.
Admission of the A11eaed Violation Duquesne Light Company admits to the violation as stated.
Reason for ttL9_Yiolatio.D A field investigation by a Quality Assurance auditor identified welds that were not specified in the NDE inservice inspection program. A subsequent investigation revealed that additional longitudinal welds in fittings had not been included on the piping drawings used to develop the First Ten Year NDE Inservice Inspection Program (ISI),
and thus the required number of longitudinal welds in fittings were not inspected during the First Ten Year Inspection Interval.
In 19R4, the information contained in original plant construction drawings and documentation, which was utilized to formulate the First Ten Year Interval Inservice Inspection Program, was consolidated on a new series of ISI isometric drawings formatted for ISI purposes.
Since the isometric drawings for plant construction did not identify longitudinal welds in fittings made by the piping component manufacturer or spool picco fabricator, they had not been included on the new ISI isometrics and thus had not been included in the First Ten Year Interval NDE Inservice Inspection Program. An inadequate review of the spool piece drawings and associated certified mill test reports (CMTRs), supplied by the piping fabricator during plant construction, resulted in the development of isometric drawings that did not account for longitudinal welds made during component manufacture.
In 1989, during the performance of an internal self assessmunt program, the Safety System Functional Evaluation (SSFE) of the RHR system identified that longitudinal welds were not examined as required and that the piping isometric drawings (ISO's) failed to identify tha existence of certain longitudinal welds. As a result of the investigation of this problem, the Isos associated with the identified welds were revised and the specifically identified longitudinal welds were examined during the seventh refueling outage (7R). In addition, the Nuclear Engineering Department (NED)
- initiated a work task effort to review the subject condition and determine the scope of needed revisions. Isos would then be revised as necessary. Based on this resolution of the observations, the SSFE open item was closed.
However, the MED work task effort was delayed due to receipt and dispocition of higher priority tasks. Since the SSFE open item was already closed, no follow-up of the commitment to complete the NED work task effort was performed.
', Roply to Notice of Violation
,, Page 3 Corrective Action Taken
- 1. A review of all Unit 1 ASME Class 1 and 2 piping that required NDE inservice inspection and had the possibility of containing longitudinal welds was conducted initially by NED-ISI personnel.
This included a detailed review of each spool piece drawing and when necessary, associated piping component certified mill test reports (CMTRs) to determine if longitudinal welds were present and included in the NDE inservice inspection program.
- 2. Based upon this initial review, the required number of longitudinal welds were examined to comply with the sampling requirements of ASME Section XI (74S75).
1
- 3. A root cause analysis of this event was performed by the Independent Safety Evaluation Group (ISEG).
Action Taken to Prevent Recurrence
- 1. Subsequent to the initial review, an independent team of five engineers performed a 100% review of the Unit 1 ISI drawings, piping spool picco - drawings and associated certified mill test report (CMTR) documentation for the purposes of identifying longitudinal welds in piping components. This independent review also served to validate the initial similar effort of NED-ISI l personnel which had been performed near the completion of the ;
eighth refueling outage (8R). '
A total of 131 isometric packages which included all class 1 and 2 piping and each consisting of a piping isometric drawing (s),
original construction piping spool sheets, purchase order bV-50 CMTR's and weld / addition sheets (cut cards) were reviewed.
Determination of method of pipe component manufacture was ascertained from the CMTR for each pipe segment and-fitting except where components could not be positively associated with CMTR information. In these cases, the review team utilized the method of manufacture indicated on the spool sheet drawing.
Where the spool sheet drawing' did not positively identify the method of manufacture, -a welded fitting was assumed. However, subsequent to the efforts of the review team, NED-ISI personnel further researched the Unit i records system and was able to locate CMTRs for all pipe components that were previously not identifiable to- such records. Thus, each piping component that was included in the scope of the first ten year plan is traceable to its CMTR which was in turn utilized to determine method of manufacture.
The results of both the independent review and the follow-up records search effort identified the following total numbers of longitudinal fitting welds that were not included in the BV-1 first ten _ year ISI program.
System No. of longitudinal _ fitting welds Low Head Safety Injection 37 High Head Safety Injection 56 Residual Heat Removal 53
koply to Notice of Violation
., Page 4 The total number of welds is lower than previously identified by the initial review. The cut card and CMTR information revealed that. in some instances fittings specified on the spool sheet drawings as welded were replaced during construction or after commercial operation with seamless fittings. Sufficient welds has been examined prior to and near the completion of 8R to fulfill ASME Section XI First Ten Year Interval Inspection requirements for the longitudinal welds identified above.
- 2. A review of Unit 2 ASME Class 1 and 2 spool shoot drawings and associated CMTR's was performed for tha purpose of identifying longitudinal welds not previously identified. The results of this review identified five (5) longitudinal welds in the main steam system that will be added to the Unit 2 first ten year program. This additional number of longitudinal welds does not impact Lthe Uresent first ten year interval program nor does it impact the preservice program (PSI) since a sufficient number of extra welds from this category were examined during PSI. In addition, four (4) longitudinal welds were identified in the reactor heating and ventilating system (HVR) and twelve (12) were identified in the recirculating spray system (RSS). These welds are exempt from preservice and inservice inspection.
- 3. An engineering- procedure has been developed that provides instructions and guidelines for characterizing and reporting deficiencies identified while implementing Inservice Inspection programs at Beaver Valley. NED Materials Section personnel have received training in the use of this procedure as well as a general familiarization of the Technical Specifications.
- 4. A self assessment of the NED-ISI program is being formulated.
This self assessment will include a critical review of all NED-ISI programs, procedures and practices for the purpose of providing improvement, efficiency and clarification where neceasary.
- 5. Past and future SSFE observations which have generic or programmatic implications- will- be identified. The SSFE project manager has been assigned the responsibility to resolve the generic or programmatic deficiency prior to close out of the issue.
- 6. Tracking of past and future prcgrammatic/ generic SSFE findings will be performed utilizing the site Commitment Tracking System.
Date When Full Comoliance will be Achieved We are in full ~ compliance at this time.
The self assessment of the NED-ISI Program will be completed by December 31, 1992.
Programmatic / generic SSFE findings will be tracked on the Commitment Tracking System by January 31, 1992.
Neply to Notice of Violation Page 5 VIOLATION II (Severity Level III; Supplement I)
Description of V(glation (50-334/91-09-01)
Technical Specification (TS) 3.7.7.1 requires that when either unit is in mode 1, 2, 3, or 4, the control room habitability system shall be operable. TS 3.7.7.1.c defines the control room energency habitability system as OPERABLE when the series normal air exhaust isolation dampers for both units are OPERABLE, and capable of automatic closure on a control room high radiation and chlorine isolation signal, or the dampers shall be closed.
TS 3.0.3 requires that when a Limiting Condition for Operation is not met except as provided in the associated ACTION requirement, within one hour, action shall be initiated to place the unit in a MODE in which the specification does not apply.
Contrary to the above, on May 17, 1991, while Unit I was defueled and Unit 2 was in 'ade 1, the Unit 1 solid state protection system (SSPS) was out of service (unable to provide an isolation signal), the Unit 1 control room outside air exhaust isolation dampers (two in-series dampers) were neither operable nor closed in that they were deenergized in the open position for a period of 18 1/2 hours, with no action taken to place Unit 2 in a MODE in which TS 3.7.7.1.c does not apply.
Admission of the Alleoed Violation Duquesne Light Company admits to the violation as stated.
Reason for the Violation The dampers were apparently opened when operations personnel inadvertently reenergized the dampers momentarily while racking their breakers onto the bus after motor control center (MCC) cleaning. The dampers are designed without control switches and open when energized without an automatic closure signal present. The lack of procedural control over the restoration of the MCC contributed to the incorrect positioning of the breakers. Subsequent de-energization of the breakers removes control room identification of the damper positions. In the absence of a restoration procedure, the operators relied on their past experience of placing systems in a normal configuration during restoration. Insufficient information was available to the operator to make him aware that the dampers would move when the breaker was closed, and therefore operations personnel were not aware that the dampers remained in the open position.
Reply to Notice of Violation Page 6 porrective Action Taken
- 1. After discovering that the dampers were open, the operator notified the NSS and the dampers were immediately closed and their breakers were locked off the bus with the key placed under administrative control. This process for securing the dampers was then proceduralized and directs plant operators first to closo the dampers, verify they are closed, then open and padlock the MCC breakers. Additionally, this step requires a second check and signature. Physically locking the breakers off the bus provides an additional barrier to preventing the inadvertent energization of the breakers and cause the dampers to reposition.
- 2. Permanent caution tags (controlled operator aids) in the form of yellow placards have been affixed on the outside of the breaker cubicle doors. The placards provide the information that the damper will reposition when the breaker is closed.
- 3. Operations shift crews were briefed on the event, the need for controlling the configuration of the plant, and explaining the operation of the damper's control logic via Night Orders.
- 4. This event was immediately reported to the NRC via a 10 CFR 50.72 one hour notification and subsequently reported in LER 91-015.
-5. The_ damper position indication on the plant variable computer was repaired.
- 6. A detailed human performance evaluation was performed to determine the root causes of the event.
Action Taken to Prevent Recurrence
- 1. Training for licensed and non-licensed operators on the control room ventilation system with particular emphasis on the isolation function was prepared and completed.
- 2. A design evaluation of the control room ventilation system, including a review of the isolation dampers' position control and indication schemes was initiated.
- 3. The damper position indication on the plant variable computer will be verified on a quarterly basis by OST 1/2.44A.12 "CIB Actuation of Control Room Isolation /CREBAPS System Functional Test".
- 4. Other plant components and systems were reviewed to identify ones that are required to be maintained in an "other-than-normal" position to satisfy technical specification action statements.
Sixteen action statements were identified and a review is currently in progress to determine if additional measures are necessary. Action will be initiated to implement any additional measures by December 31, 1991.
,' 0eply to Hotice of Violation
,, ,Page 7 Date When Full Compliance will be Achieved We are in full compliance at this time.
The design evaluation of the control room ventilation system will be completed by December 31, 1991.
OST 1/2.44A.12 will be revised by November 15, 1991.
Action will be initiated to implement any additional measures recommended from the "other-than-normal" position review by December 31, 1991.
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