ML20086R837
| ML20086R837 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/24/1995 |
| From: | George Thomas DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9508010006 | |
| Download: ML20086R837 (6) | |
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Beaer Valley Power Station swax ~~
(412) 643-8069 FAX e
GEORGE S. THOMAS Dwision Vice President NeNE oivision July 24. 1995 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Integrated Inspection Report 50-334/95-09 and 50-412/95-09 Reply to Notice of Violation
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In response to NRC correspondence dated June 23,1995, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the i
subject inspection report.
If there are any questions concerning this response, please contact Mr. N. R. Tonet at (412) 393-5210.
Sincerely, Aufa eor e S. Thomas Attachment c:
Mr. L. W. Rossbach, Sr. Resident Inspector Mr. T. T. Mattin, NRC Region I Administrator Mr. D. S. Brinkman, Sr. Project Manager Mr. J. C. Linville, Chief, Projects Branch No. 3 Division of Reactor Projects, Region I os enmm 9508010006 950724
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DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station Unit No. I and 2 Reply to Notice of Violation Integrated Inspection Report 50-334/95-09 and 50-412/95-09 Letter Dated June 23,1995 VIOLATION 1 (Severity Level kV, Supplement I)
Description of Violation (50-334/95-09-01) 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Furthermore, for significant conditions adverse to quality, it states that the measures shall assure that corrective action is taken to preclude repetition.
Contrary to the above, established measures did not assure that conditions adverse to quality in the Unit I river water system were promptly identified and corrected.
Specifically:
A.
Between October of 1991 and May of 1995, adequate measures were not taken to j
prevent flow induced erosion of the river water side of the Unit I high head safety injection pump oil coolers.
In October of 1991, flow induced erosion was identified as the cause of failure of the "A" HHSI pump oil cooler and the cause of degrad.1on of the "B" and "C" coolers. All three coolers were replaced, but actions were not taken to prevent erosion of the new coolers. In June of 1993, an engineering memorandum identified the need to control river water flow through the oil coolers to limit erosion, but controls were not implemented prior to May of 1995, when degradation due to flow induced erosion was again identified in all three coolers, and caused failure of the "A" cooler.
B.
Between May of 1990, and May of 1995, appropriate measures were not taken to ensure that adequate river water flow was available to the high head safety injection (HHSI) pumps and the control room cooling units from both river water supply headers. In May of 1990, the need to establish differential pressure limits across the two in-line strainers for river water supplies to the HHSI pumps and the control room cooling units was identified; however, limits were not established until testing on May 22,1995, showed that inadequate flow was available from the "B" river water supply header due to a clogged strainer. Additionally, compensatory actions
.a Reply 80 Notice of Violation Integrated Inspection Report 50-334/95-09 and 50-412/95-09
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' were not initiated to monitor strainer differential pressures when the installed indicators were out of service.
Most recently, this was noted - between December 13,1994,.and May 22,-1995, when the "B" train differential pressure gage was considered damaged.
Reason for the Violation A.
The reason that adequate measures were not taken to prevent the Unit 1 HHSI pump lube oil cooler failure is that the proper priority (safety significance) was not established in 1993 when the need to reduce river water flow through the coolers to limit erosion was identified.
B.
The need to establish differential pressure limits for the river water in-line wye strainers in the Operating Manual log was not identified by a formal work tracking program (design change open item, engineering memorandum, or procedure deficiency) and, therefore, was not completed until recently identified.
Corrective Actions Taken A.
The following corrective actions were taken for the Unit I HHSI pump lube oil cooler erosion problem:
Following the discovery of the leaking "A" HHSI pump lube oil cooler, the cooler was inspected. Inspection of the "A" cooler identified that the tubes experienced flow induced erosion at the tube inlet, resulting in loss ofintegrity in one tube. The "A" cooler was replaced on May 6,1995. Inspection of the "B" and "C" HHSI pump oil coolers identified similar degradation, but no loss of tube integrity. The "B" and "C" coolers were also replaced.
An engineering evaluation was completed which recommended a nominal river water flow rate through the coolers which would minimize erosion of cooler tubing and provide adequate flow during accident conditions. The river water system flow was throttled on May 9,1995, to provide the recommended flow rate through the coolers.
Reply to Notice of Violition Integrated Inspection Report 50-334/95-09 and 50-412/95-09 Page 3
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B.
The following corrective actions were taken for the Unit I river water in-line wye strainer clogging problem:
The wye strainer in the "B" river water supply header was cleaned on May 22, 1995. Also, the "A" header wye strainer was cleaned on May 23,1995.
The calibration of the differential pressure gage (PDI-RW-18) was checked on May 23,1995, and found to be acceptable.
Operating Manual Log L3 was revised on June 6,1995, to indicate the l
differential pressure at which action will be initiated to clean the strainers.
Action Taken to Prevent Recurrence A.
Future inspections of the River Water / Service Water heat exchangers will include a visual inspection for evidence of erosion.
A review of other heat exchangers at Unit I and Unit 2 was performed to identify those with similar material (90-10 Cu-Ni).
The flow rates through these components have been evaluated for similar potential erosion problems and revised flow rates are being established where warranted.
A review of currently open Engineering Memoranda (ems) is being conducted.
Where necessary, the ems will be increased in priority to ensure timely resolution.
B.
A review of the Unit I and Unit 2 Operating Manual Logs was conducted, and it was determined that there were no additional outstanding items identifying the need to establish operating limits.
Operators will be briefed on the event to reinforce the need to maintain a questioning attitude.
Date When Full Compliance Will Be Achieved Full compliance has been achieved at this time.
A.
The River Water / Service Water heat exchanger monitoring program will be revised l
by August 31,1995, to include a visual inspection for erosion. The review of ems
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will be completed by August 31,1995.
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B.
The operator briefing will be completed by August 31,1995.
Reply to Notice of Violation Integrated Inspection Report 50-334/95-09 and 50-412/95-09 Page 4 Endineering and Maintenance Backlog Concerns The cover letter which forwarded the Notice of Violation also requested that the reply
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address our plans to evaluate the safety significance of the engineering and maintenance backlog.
The engineering and maintenance backlogs are being managed as follows:
1.
A review of safety significant Maintenance Work Requests (MWRs) was completed by Operations personnel and priority levels have been adjusted consistent with their safety significance.
2.
New MWRs are reviewed by both Maintenance and Operations personnel to i
initially establish the proper priority levels based on safety significance.
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The outstanding maintenance work requests are reviewed during each twelve-week maintenance cycle to determine which MWRs will be included in the work performed during the twelve-week period.
4.
A review of currently open Engineering Memoranda (ems) is being conducted to identify safety significant ems which require a timely resolution. This review will be completed by August 31,1995.
5.
Performance indicators for monitoring the EM backlog will be revised by August 31,1995, to better evaluate the completion status of prioritized ems and, where appropriate, initiate necessary corrective action.
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- Reply to_Netice cf Viol
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Integrated Inspection Report 50-334/95-09 and 50-412/95-09 i
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' Page 5 VI L TION 2 (Severity LevelIV, Supplement I) l
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Description of Violation (50-334/95-09-02 and 50-412/95-09-02)
L 10 CFR 26, Section 26.24(a)(2) states in part that, to provide a means to deter and detect substance abuse, the licensee shall implement unannounced drug and alcohol-tests imposed in a statistically random and unpredictable manner so that All persons in the population subject to testing have an equal probability of being selected and tested; and, l
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I As a minimum, tests are administered on a nominal weekly frequency and at various f
times during the day.
Contrary to the above, from January 1,1994 to April 20, 1995, the Duquesne Light I
Company did not implement unannounced drug and alcohol tests as required, in that l
testing was not unpredictable because there was no random alcohol and drug testing on back-shifts between 10:00 p.m. and 6:00 a.m. or on weekends.
Reason for the Violation i
Since the initiation of the Fitness for Duty rule in 1990, a method for random drug and alcohol testing has been performed at Beaver Valley which ensures that workers on all three shifts are randomly selected and tested. However, this process resulted in a period on backshifts (between 10:00 p.m. and 6:00 a.m.)_ when the testing was not being conducted. Additionally, random testing on weekends was' inadequately scheduled.
Corrective Action Taken Adjustments were made to the random testing program to add scheduling of backshift testing between 10:00 p.m. and 6:00 a.m. and on weekends and holidays. Since this change was made, random testing scheduled during the period from April 21,1995 through June 30,1995 included ten backshifts (10:00 p.m. - 6:00 a.m.), three weekend I
days and one holiday, in addition to the normal weekday testing.
Action Taken to Prevent Recurrence The current method of performing unannounced drug and alcohol tests ensures that testing is performed in a random and unpredictable manner.
Date When Full Compliance Will Be Achieved Full compliance has been achieved at this time.
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