ML20101U711
| ML20101U711 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/16/1992 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207230193 | |
| Download: ML20101U711 (8) | |
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Be ver 'a ley Power $ tat +n un= ="-
JOHN D. SIEBER Vge President. Nuclear Group Director, Office of Enforcement U.
S. Nuclear Regulatory Commission i
Attn Document Control Desk Washington, DC 20555
Subject:
Ileaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. HPF-73 Iteply to Notice of Violation and Proposed Imposition of
)
Civil Penalty Gentlemen:
In response to NRC correspondence dated June 17, 1992, 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 ovents were discussed in Inspection Report No. 92-07 and also in an Enforcement Conference held on May 19, 1992.
A check in the amount of $75,000 is enclosed for payment or the civil penalty.
If there are any questions concerning this response, please contact Mr. Nelson Tonet at (412) 393-5210.
Sincerely, A
D. Sieber Attachment cc:
Mr.
L. W. Rossbach, Sr. Resident Inspecter Mr. T.
T. Martin, NRC Region I Administrator Mr. A.
W.
DeAgazio, Project Manager Mr. M.
L. Bowling (VEPCO)
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COMMONWEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER
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On this
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day of
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, 1992, L ltb 8/-
f((dQe', a Not ry Public in and for said before me, commonwealth and County, personally appeared J.
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Sieber, who being duly sworn, deposed, and said that (1) he is Vice President - Nuclear of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.
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B'$cycr'ValloyPowerStation,UnitNo.2 Docket No. 50-412, License No. NPF-73 Notice 1of Violation and Proposed Imposition of Civil c
? Penalty
.Page 2 bcci ORC Members T..P.
Noonan K.
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Starr Central File (2)
ND2NSM:5652
-Egferenegg:-
ND1MNE 6205-
.ND1MNE:6209 BV-2 LER.92-004 -
BV-2 LTR 92-005 ND3MNO:3310
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DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Unit No. 2 Reply to Notice of Violation and Proposed Imposition of Civil Penalty Letter dated June 17. 1992 VIOLAllgill (Severity Level III; Supplement I)
Q_escrint. ion of Violation (50-412/92-07-01) 10 CFR Part 50, Appendix B, Criterion III (Design control) requires, in part, that measures be established to assure that regulatory requirements and design bases are correctly translated into design documents.
Design control measures shall provide for verifying or checking the adequacy of design.
Also, design changes shall be subject to design control measures commensurnte with those applied to the original design.
BVPS Unit 2 FSAR, Section 8.3.1.1.8, Automatic Loading and Load Shedding, states in part, that reconnection of EDG loads will commence, sequentially, in specified load blocks described in Table 8.3-3.
Contrary to the above, the licensee failed to establish adequate design control measures for verifying or checking the adequacy of a vendor-recommended change to a component installed under Design Change Package (DCP) 1545 in September 1990.
The DCP 1545 was initiated to replace the electro-mechanical relays (Nos. 162-EGSAA (B)X1, 762-EGSA(B)A, and 862-EGSA(B)A) in emergency diesel generator (EDG) 2-1 and 2-2 load sequencers with commercial grade solid state relays.
To meet the EDG sequencers design bases, the replacement relays had been qualified for the safety-related application through qualification testing in a configuration that applied 24 vde across the internal timer clock circuit.
However, the vendor-recommended change, made prior to completion of the DCP, resulted in the application of excessive voltage (112 to 129 Vdc) across the circuit.
The effect of this configuration change on the relay function was not reviewed by the licensee to ensure that the regulatory requirements and design bases specified in FSAR Table 8.3-3 for the EDG sequencers were met.
Discussion of Violation The'need for this configuration change (i.e., to
.intain the clock circuit of the six relays in a continuously energized state) was based on the results of the pre-testing of this relay which was performed prior to completion of DCP 1545 (May, 1990).
At that time, verbal discussions with the manufacturer's applicatic' engineers resulted in their recommendation (which was not documented) for this configuration change for six of the sixteen relays installed, in order to achieve improved timing accuracy at the 0.5 and 2 second settings.
Startup testing was successfully completed and the relays were placed in service during October 1990.
- ~___.______ _ - _ _ _ _.. _ _
R$ ply to Notice of Violation Page 2 Discussion of Violati2D (continued)
Drawings of the relay's internal circuitry were requested from the manufacturer-at the time that this change was recommended but were not supplied due-to their proprietary nature.
An alternate analysis was not completed to justify the change due to the unavailability of internal wiring information.
As a result, the manufacturer's verbal recommendation became-the basis for the acceptability of the configuration change.
Admission of the Alleged Violation Duquesne Light Company (DLC) admits to the violation as stated.
Reason for Violation This violation resulted from the inadequate implementation of procedural criteria which address the design and documentation requirements for the application of equipment used in a configuration
- differing from the qualified. design configuration.
This instance was further complicated _by-the manufacturer's proprietary information restrictions on the relay's internal design needed for full circuit analysis and the failure to document verbal communications with the manufacturer.
ggrrective Action Take.D i
corrective actions were immediately initiated to resolve the problems found.
These actions are as follows:
1.
All six relays were replaced and rewired por the qualified configuration by-April 8, 1992 (as approved by design change package 1870 issued March 31, 1992.)
Testing was successful, and the relays and the emergency diesel generator load sequencing circuits are-in service in accordance with the qualified configuration, regulatory requirements and design bases as described in FSAR Table 8.3-3.
2.:
TheLmanufacturer's proprietary design information for the relay internals was obtained, and a technical evaluation of the failure
' of-these relays was completed on May 15, 1992.
It was found that an internal-2 watt resistor (R9) could generate in excess of 2-watts of heat energy depending on input voltage, electrical tolerances..This resistor's size was marginal in this application and therefore represents-an underdesign for this configuration..
(Note: The manufacturer subsequently recommended a replacement'of this 2 watt resistor ~with a 5 watt resistor to resolve this problem, after these failures were. discovered and
- reported by DLC.)
3.
Safety evaluations were-conducted for the complete failure of the six a+tached relays, and they concluded that the equipment loads that should have atarted at step 4 of the oequencer timer (auxiliary feed pump and quench spray pump) would now start at
- step 6, 45 seconds 11ater.
This 45 second delay wou'd not havc 1
_ caused any of the safety analysis limits to be exceeded.
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R$ ply to Notice of Vic stion i
Page 3 991IIecMve Actions Takert (continued) 4.
Simulator scenarios were conducted for a possible worst case condition (which would involve the sequencer locking out if the relay energized shut and the timer unit failed.)
In this case, operator actions were necessary to energize the proper equipment as specified in Emergency Procedure E-0.
These actions were successfully completed by the operators during the simulations.
Therefore, it is expected that the condition would have been recognized and properly addressed by operations personnel.
5.
A Procedure Report was issued on May 21, 1992 to notify all Nuclear Engineering Department personnel of the event and of pending procedure changes which were directed to improve documentation of vendor input.
6.
Bench testing of this relay was initiated on April 3, 1992 to determine the life of this relay under this alternate configuration.
As of the date of this letter, this relay has not failed.
7.
This event was reported to the NRC via a 10 CFR 50.72 four hour notification and subsequently reported in LER 92-004.
Ac_tipps Taken to Prevent Reci1EI_ence 1.
Procedural changes have been initiated in the areas of Design Change control, Engineering Specifications, and Design Verification.
These changes clearly specify the necessary design and documentation requirements (including proprietary information) in appropriate design control procedures.
These changes also specifically regr. ire that all vendor communications used as design input information be documented.
Training of Nuclear Engineering Department personnel who perform design activities will be initiated upon issue of these cevised procedures.
2.
A review of design change packages involving Class 1E electrical / electronic equipment which were implemented over the last five years will be performed to identify any potential deviations from the qualified design configuration.
Date When Full Compliance will be Achieved Full compliance was achieved upon replacement and testing of the failed relays.
Procedure changes and training will be completed by October 1, 1992.
The review of design change packages will be completed by December 31, 1992.
_ Reply'td Notice of Vic1ation Page
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ylQQ 32N TT (Severity Level IV; Supplement t.
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"'ggiption of Violation (50-412/92-07-02)
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'Tos5nical Specification-3.9.4 requires, that during core alterations, vi containment penetrationn that provide direct riccess fr)q the 61 1 containment atmosphere to the outside atmosphere, other than for the or' innent purge and exhaust valves, be closed by an isolation a,
blind flange, or manual valve.
to the shove, sparc cont ainment penetrat ons 8D and 11E that direct access were nor closed by a valve or blind flange 6'Ln
' oro alteratianc from IIarch 23 to March 27, 1992, and space
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lent penetration 11E was not closc' by a valve o-blind flange ca core alterations from April 8 to 9, 1992.
Specitically. the
+
?ontainment penetrations, which were opened so that temporary sculd be rdn into the containment building (steam Jenerator e+,.
e$dy
'rrent cables were run through penetration 3D, and video cab]et
- 'ind a 480V pcwer cable were run through penetration 11E), were not g
Jvsed by an isolation valve, blind flange, or manual valve but were Lealed with fire retardant fiber and tape.
Adaission of the Alleced Violation Duquesne Light company admits to the violation as stated.
^
L-Reason for the Violation e-s installed in the containment penetrations used A temocrary o to 7 'n ;e tempvrary electrical cables.
The procedure that was refexenced and used for installing the temporary penetration seal did y
not adequatelv specify a seal which met the requirements for the differential pressura experienced in this application.
C ggrectite Action Taken 1.
After. discovery of the leaking electricsl penetration, the control rnom was notified, and fuel mtvement was immediately halted once a fuel assembly in transit was placed in a safe
- position, j
2.
The temporary cabling was removed, and the penetration was permanently scaled and satisfactorily Type "B"
leak tesned.
3.
The Ceneral Managaz, Ntalear Operations issued a letter requiring
-all temporary seals used in wall / floor penetrations te be initiated through the Temporary Modification Program and evaluated by Engineering fer adequate sealing nothod with a 50.59 evaluation performed.
These requirements will remain in effect until the following Actions Taken to Prevent Recurrence are i
complete.
4.
This event was.repnrted to the NRC via a 10 CFR 50.72 four hour notification and subsequently reported in LER 92-005.
- - _ - ~._
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- ,9 "Rbply.toLNotice of Violation 0
-Page 5
-Actions Taken to-Prevent Recurrence
- 1. -- A review of various Nuclear Group Administrative Procedures
_(NGAP) was performed to determine if the administrative rontrol on penetration seals could be enhanceo.
Based on this review, a new administrative procedure will be issued to consolidate the administrative requirements and controls for all types of permanent and temporary. penetration ses.
2.
NGAP 3.5 " Fire Protection" will be revised to caution personnel that temporary fire seals may have functions / ratings in addition 5
to fire-(i.e., hydrostatic pressure, differential air pressure, radiation, and smoke and gas).
In ad-lition, the new adrir.istrative procedure - (Item #1 above) will be referred to for the appropriate administrative controls for fire seals.
.3.
Plant. Installation Process Standard (PIPS) M16.3, " Fire Stops and Seals" will-be revised to provide specific guidance for temporary
-containment penetration seals used during Modes 5 and 6, and to change the title of PIPS M16.3-to " Penetration Seals" to more accurately reflect its actual scope.
4.
Corrective Maintenance Procedure 2-CMP-75-SG-Cable Install-1E will be_ revised as needed to reflect the procedure changes discussed above.
I 5.
A Technical-Specification Change Request will be submitted to the NRC for'BV-1 and BV-2 Technical Specification 3.9.4 to addross the use of temporary containment penetration seals.
.t Date-When Full Compliance will be Achieved
' Full compliance is in effect'_at this time.
The following actions will be completed prior to the next refueling _ outage at either unit:
1.
The_new administrative procedure on' penetration seals will_be issued-by December 31, 1992.
2.
NGAP_-3.5_will be revised by December 31, 1992.
3..
_ PIPS M16.3 will be revised by September 30, 1992.
4.
2-CMP-75-SG-Cable Install-1E will be revised ty December 31, 1992.
5.
.The Technical Specification Change-Request will be submitted to G
the NRC by November 30, 1992, i.
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