ML20126L103
| ML20126L103 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/18/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8507310053 | |
| Download: ML20126L103 (3) | |
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Telephone (412) 393-6000 Nucker Group
[nippYn*,p' ort, PA 15077 0004 July 18, 1985 U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement Attn: Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 85-11 Gentlemen:
In response to your letter of June 18, 1985, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced report.
If you have any questions enncerning this response, please contact my office.
Very truly yours, rhb
.. / J.
JfcePresident, Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 l
Director, Safety Evaluation and Control Virginia Electric and Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 8507310053 850718 PDR ADOCK 05000334 G
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection 85-11 Letter dated June 18, 1985 VIOLATION (Severity Level IV; Supplement I)
Description of Violation (85-11-02) 10CFR50, Appendix R, Section III.G, Fire Protection for Safe Shutdown Capabil-ity, requires power cables of redundant trains of systems necessary to achieve and maintain hot shutdown conditions that are located in the same fire area outside the primary containment to be separated by a fire barrier having a 3-hour rating, or alternate means be provided to ensure that one of the redundant trains is free of fire damage. The BVPS Fire Protection Assessment, dated June 30, 1982, requests no exemption in this area in complying with 10CFR50.48, Fire Protection.
Contrary to the above, a ventilation duct was routed between the cable spread-ing room and process instrument room fire areas, thereby interconnecting the areas where the redundant emergency diesel generator power cables are located, without the designed fire wrap or dampers to provide a fire barrier with 3-hour fire rating separating the redundant cables.
The emergency diesel systems are necessary to achieve and maintain hot shutdown conditions.
Corrective Actions Taken Engineering Change Notice (ECN) 589-5 was generated on March 9, 1985 by Engineering for construction to install fire-wrapping for the ductwork in question to isolate fire areas CR-2 (Controi Room HVAC Equipment Room) from CS-1 (Cable Spreading Room) and CR-4 (Process Instrument Room).
In the interim, a fire watch was posted by Operations per Technical Specification Requirement 3.7.15.
Since all of the fire areas in question have operable detection systems, hourly fire watch patrol on at least one side of the affected assembly was established until the functional capability of the barrier was restored on April 12, 1985.
Actions Taken to Prevent Recurrence As part of the Appendix A to 10CFR50 review of fire protection and the subse-quent issuance of our Fire Protection Safety Eva!uation Report and Technical Specification Amendment 18 on June 6, 1979, facility modifications for upgrad-ing fire protection systems were made under Design Change Package (DCP) 268.
As part of this DCP, the ventilation duct transversing fire areas CS-1, CR-2 and CR-4 was to have fire-wrapping installed.
Subsequent to the review and initiation of Design Concept, ECN 268-449-0EG(issuedon 12/11/80) revised the design on this duct to install a fire damper in place of the fire wrap.
In 1
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Reply to Notice of Violation Inspection 85-11 Letter dated June 18, 1985 Page 2 response to concerns raised by Quality Assurance Audit BV-1-84-36, a re-review of the design identified the fire damper as not providing equivalent protection as the originally proposed fire wrap.
Therefore, the apparent cause of the violation was a breakdown in engineering controls to assure the original intent of the design was met.
To address this, engineering procedural requirements have been established to ensure the review of design outputs (including ECNs) against the Design Concept and 10CFR50 Appendix R requirements which were not in existence at the time DCP-268 was implemented.
Specifically, the following procedures presently address this concern:
1.
Nuclear Engineering Department Internal Instruction NEDil-31, " Appendix R Review of Design Change Packages" was issued 12/20/84 to establish the method for performing and documenting 10CFR50 Appendix R review of DCP's.
2.
Nuclear Engineering Management Procedure NEMP 2.8, Rev. 3, " Handling of Design Change Packages", issued 5/22/84 specified that the Primary Sponsoring Engineer shall identify Fire Protection (Appendix R) consid-erations in the Design Concept for a DCP.
3.
Nuclear Engineering Management Procedure NEMP 2.13, Rev.
2,
" Design Verification Guidelines, Methods and Requirements",
issued 4/5/84 included questions on the Design Review Checklist in addition to those required by ANSI N45.2.ll which require the Primary Verification Engineer to verify that the Design Outputs (which include ECN's) are in compliance with applicable Appendix R criteria / requirements and for compliance with the conditions and conclusions stated in the Design Concept and Safety Evaluation.
Specific to the fire protection program, the QA Audit which was performed and which initially identified this violation provides assurance that the programmatic defect which caused this violation did not result in other inadequacies in the fire protection program.
Date on Which Full Compliance Will be Achieved A program for adequately reviewing plant modifications is presently in place and a fire barrier has been established in the affected area. Therefore, full compliance has been achieved.