ML20138C062
| ML20138C062 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/23/1997 |
| From: | Jain S DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9704300023 | |
| Download: ML20138C062 (7) | |
Text
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4 VaNey Power Station SNpper.gport, PA 16077-0004 W
Vice esident Fax 412 3-8 9 April 23, 1997
[S. Nuclear Regulatory Commission ttention: 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 Reply to Notice of Violation 4
In response to NRC correspondence dated March 24,1997, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the letter.
The cited events were discussed in NRC Inspection Report Nos. 50-334/96-10, 50-412/96-10 and also during a Predecisional Enforcement Conference held on March 7, 1997.
If there are any questions concerning this response, please contact Mr. J. Arias, Director, Safety & Licensing at (412) 393-5203.
Sincerely,
&J=-h Sushil C. Jain c:
Mr. D. M. Kern, Sr. Resident Inspector f
Mr. H. J. Miller, NRC Region I Administrator g(
g Mr. D. S. Brinkman, Sr. Project Manager l
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AFFIDAVIT COMMONWEALTH OF PENNSYINANIA)
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COUNTY OF BEAVER
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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 Reply to Notice of Violation EA 97-076 Befi re me, the undersigned notary public, in and for the County and Commomvealth aforesaid, this day personally appeared Sushil C. Jain, to me known, who being duly sworn according to law, deposes and says that he is Division Vice President, Nuclear Services of the Nuclear Power Division, Duquesne Light Company, j
he is duly authorized to execute and file the foregoing submittal on behalf of said Company, and the statements set forth in the submittal are true and correct to the best of his knowledge, infonnation and belief.
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Sushil C. Jain Subscribed and sworn to before me onthis),3Yayaf hpi[, /Q Y L
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DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Pm"ar Station, Unit Nos. I and 2 Reply to Notice of Violation i
Letter dated March 24,1997 VIOLATION (Severity Level III; Supplement I)
EA 97-076 A.
Technical Specification (TS) 6.8.1.a requires that written procedures be properly established and implemented covering activities recommended in Appendix A to NRC Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements (Operation)." Section 3 of Appendix A to Regulatory Guide 1.33 specifies that procedures be established for operation of safety related systems.
Procedure 1/2 OM-48.2.C, " Adherence and Familiarization to Operating Procedures," Rev.17; NPDAM 1.2.1, " Establishment of written directives and procedures," Rev. 3; and Chemistry Manual Chapter 3, " Sampling and Testing,"
Rev. 7, specify criteria for implementing procedures as written.
Contrary to the above, on numerous occasions, licensee staff did not implement I
procedurcs as written, as evidenced by the following examples.
1.
When repeatedly depressurizing the Unit 2 residual heat removal (RHS) system from January 23 to January 30, 1997, operators and chemistry technicians did not properly implement station procedures 20M-10.4.C,
" Residual Heat Removal System Shutdown," Rev. 20, and CM 2-3.40 Part D, "RHS Grab Sample Purging to Sample Sink," Rev. 6. Specifically, Operators did not perform RHS depressurization as specified in l
a.
procedure 20M-10.4.C in that although operators had reviewed 20M-l 10.4.C, they continued to depressurize RHS based on their memory of the procedure instead of perfonning and signing off the procedure step-by-step, as required by Procedure 1/2 OM-48.2.C; and, b.
Chemistry technicians did not properly perform steps in procedure CM 2.3-40 in that steps to reposition 2SSR-SOV129A1/A2 were performed out of the required sequence in Sequence D of the procedure, and Valve SS-175, a primary system sample valve, was not returned to the correct position.
9 i
Reply to Notice of Violation Page 2 These errors contributed to mispositioning Valve SS-175, which unexpectedly altered the existing RHS depressurization lineup.
2.
On January 14,1997, Unit 1 operators failed to properly implement station procedures OM 1.15.4.H, " Securing a component cooling water (CCR) pump or placing the spare CCR pump in service,".Rev.1, and.10M-15.3.B.1, " Valve List-1CCR," Rev. 7, when securing the 'C' CCR pump.
Specifically, the operators did not shut the 'C' CCR pump discharge valve, i
ICCR-9, as specified by the Procedure OM 1.15.4.H, Step IV.C.4.b.2, and also failed to annotate system configuration drawings and procedures to reflect this change, as required by Procedure 1/2 OM-48.2.C, Step VI.B.15.
B.
Beaver Valley Power Station Technical Specification 4.11.2.6.1 requires oxygen concentration to be monitored during waste gas decay tank (WGDT) filling operations to ensure that an explosive gas mixture is not present.
Contrary to the above, operators failed to monitor oxygen concentration when running the degasifier to the waste gas decay tank (WGDT) on November 30, 4
1996, since operators had inadvertently deenergized both Unit 1 oxygen analyzers on November 25,1996, a repeat problem caused by corrective actions previously l
implemented to address a known human factors issue (look-alike control switches) not precluding recurring misoperation of the oxygen analyzer control switches.
i C.
10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
Contrary to the above, following the identification of mispositioned service water valves 2SWS-82 on July 14,1995, and 2SWS-MOV-105D on October 3,1995, I
and other mispositioned components during this time period, which represented a condition adverse to quality involving inadequate management of plant configuration control, the licensee did not take appropriate measures to correct this condition adverse to quality and prevent recurrence, as evidenced by the fact i
that numerous component mispositionings occurred which were identified by the l
licensee during the period September 1996 to February 1997.
Poor work practices, personnel errors, and failure to properly implement station procedures l
continued to result in component mispositionings.
Several of the affected components were on safety related systems, including the emergency diesel j
l j
Reply to Notice of Violation Page 3 generator, component cooling reactor, service water, and auxiliary feedwater systems.
Reasons for the Violation A.
Procedures were not followed as written due to lax enforcement of standards, policies and administrative controls.
B.
Recurring misoperation of the oxygen analyzer control switches occurred because the switches were susceptible to human factors related errors, and inadequate operator self-checking and attention to detail.
l C.
While corrective actions were taken for the 1995 mispositioning events, these actions were not effective in minimizing these type of events. An effectiveness review was not conducted in a timely manner following the completion of the corrective actions for these events.
i Corrective Actions Taken 1.
Mispositioned components were evaluated and restored to their correct positions.
i 2.
Problem or Condition Reports were initiated as appropriate, to document the events and determine corrective actions.
i 3.
The appropriate personnel were counseled on performance problems and management expectations.
4.
The valve list (10M-15.3.B.1) was revised by February 21,1997, to change the normal system arrangement (NSA) of valve ICCR-9 to open.
5.
The procedure (10M-15.4.H) for operating the IC CCR Pump was revised by February 21, 1997, to reflect the new NSA of the pump's discharge valve ICCR-9.
6.
Unit 1 and 2 operator logs were revised by January 24,1997, to strengthen the monitoring of oxygen analyzers 02AS-GW-110-1 and 2.
7.
Procedure 10M-19.4 G was revised by Janutiv 21, 1997, to verify proper operation of oxygen analyzers 02AS-GW-110-1 and 2 prior to transferring gas from the surge tanks to the waste gas decay tanks.
4
l Reply to Notice of Violation j
Page 4 8.
A protective aluminum cover'was installed over the power switch for oxygen analyzers 02AS-GW-110-1 and 2 to provide a barrier to prevent misoperation due to confusing the power switch for the pressure override switch.
9.
The Vice President, Nuclear Operations issued a letter on February 13,1997, to all plant personnel to clearly communicate management's expectations regarding the control of valves, use of procedures, and completing a procedure in its entirety. In addition, restrictions were imposed to limit the approved means by
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which valves can be manipulated. Emphasis was placed on the importance of precluding and correcting these types of problems as they are precursors to more significant events.
Actions Taken to Prevent Recurrence 1.
On March 6,1997, the Independent Safety Evaluation Group (ISEG) completed an evaluation of mispositioning events reported in Problem or Condition Reports since July 1,1995. The ISEG review identified several recommendations for reducing mispositioning events which are being tracked on the Commitment Action Tracking System.
2.
A change notice has been submitted to revise the Unit 1 UFSAR during the next annual update to reflect the change in NSA position for ICCR-9.
i 1
3.
Valve, switch and breaker position verifications were performed on safety systems identified by Operating Manual Table 48.2.C-1 in those areas normally accessible during power operation to baseline the current status of these l
components against their normal system arrangement. These verifications were completed by April 14, 1997. This baseline was completed to facilitate a self-assessment of the effectiveness of corrective actions for these occurrences.
4.
A review of procedures which manipulate components is ongoing to ensure that the final system condition is consistent with the NSA, or otherwise that the off normal condition is administratively controlled.
5.
Additional self-checking training using a self-checking simulator was provided to in-plant operations personnel by April 10,1997.
6.
Smali (2 inch and under) safety related ball valves that have the potential to be moved through inadvertent contact with personnel are being immobilized in position. :In addition an evaluation will be completed in regards to securing safety t
Reply to Notice of Violation j
,.,Page 5.
related ball valves 2 inches and larger. This effort will be completed by May 31, 1997.
7.
A construction standard was issued by March 14,1997, which details the conduct of pre-job walkdowns and the precautions to be taken while working near plant I
equipment during normal operation to minimize the potential for inadvertent contact.
8.
Administrative controls for valve manipulation were enhanced and incorporated into Operating Manual 1/20M-48.3.D, " Administrative Control of Valves and' Equipment" by March 19,1997.
- 9.
The procedural controls and ownership of operator workarounds are being reviewed to insure that they are adequate and well defined. This review will be completed by May 31,1997.
10.
A program will be developed for retiring plant equipment. This program will be incorporated into appropriate procedures by August 15,1997.
I 1.
Operations will perform a self-assessment on the effectiveness of these corrective actions by September 30, 1997, by monitoring the number and type of mispositioning events that have occurred since April 15,1997.
i.
Date When Full Comoliance Will Be Achieved 1
The next annual update of the Unit 1 UFSAR is scheduled to be submitted by July 31, 1997.
l The effort to immobilize ball valves in position will be completed by May 31,1997.
The review of procedural controls and ownership of operator workarounds will be completed by May 31,1997, a
The program for retiring plant equipment will be incorporated into appropriate procedures by August 15,1997.
[
The self-assessment on the effectiveness of corrective actions for mispositioning events will be completed by September 30,1997.
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