ML20154C025
| ML20154C025 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/02/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809140214 | |
| Download: ML20154C025 (3) | |
Text
,
e B vor W%y Power Staten Shwngtort. PA 150774004 Y b du;w Gros (4th 6415255 September 2, 1988 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beever Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 88-21 Gentlemen:
In response to NRC correspondence dated August 3, 1988 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice i
of Violation included with the referenced inspect!.on report.
If there are any questions concerning this response, please contact my office.
Very truly yours, I
.L6 Lr
. D.
Sieber
[VicePresident Nuc1 car Group i
Attachment cc:
Mr. J. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr. William V. Johnston, Acting Director, i
Division of Reactor Safety Mr. P. Tam, Project Manager Director, Safety Evaluation & Control (VEPCO) i I
8809140214 880902 J
PDR ADOCK 05000334 O
DNU
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DUQUESNE LIGHT COMPANY Nuclear Group i
Beaver Valley Power Station, Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 50-334/88-21 Letter dated August 3, 1988 VIOLATION.(Severity Level IV, Supplement I)
Description of Violation (88-21-01) 10 CFR 50.49(f) requires that qualification of each component be based on testing or experience with identical equipment or with similar equipment with a
supporting analysis to show that th?
equipment to be qualified is acceptabic.
Beaver Valley site administrative procedure Chapter 31, Revision 2 Section 2a requires that equipment have sufficient documentation to establish that the equipment is environmentally qualified.
Contrary to the above on May 12, 1988, the equipment qualification file 0044 Revision 3
for motor operated valve MOV-SI-885B did not have sufficient documentation to establish the qualification of Ideal Model wironuts utilized in the motor statol wiring circuit.
Admission or Denial of Alleged Violation The violation is correct as stated.
Reason for Violation During the performance of a
routine Equipment Qualification (EQ) inspection in
- April, 1987 for motor operated valve MOV-SI-8858, a motor lead wire was found damaged and had to be repaired.
The maintenance instructions / procedures used for the EQ inspection did not specifically address the repair of the particular Limitorque j
wiring found to be damaged since this was not part of the proplanned inspection.
Consequently, Maintenance obtained a wironut which was l
stocked for use in safety related systems, but which was not approved i
for use in Electrical Equipment Qualification Master List (EEQML) l equipment.
Approved methods for reconnecting / splicing wiring in l
EEQML equipment worc in existence at that time and should have boon used.
l DLC believes the major contributing factor to the occurrence of this i
violation was a
weakness on the part of the Maintenanco and Quality control personnel involved in understanding a certain aspect of the EQ program.
- Namely, the introduction of any new or different materials into equipment on the EEQML requires specific prior approval by the Equipment Qualification Group.
l Corrective Steps Which Have Boon Taken and Results Achieved The wirc nut for valve MOV-SI-885B was replaced with a qualified compression crimp connector on May 12, 1988 via Maintenance Work Request 883020.
REPLY TO NOTICE OF VIOLATION Page 2 4
To ascertain if the possibility existed of wirenuts being used in other EQ MOVs, a
search of Maintenance Work Requests that may have involved wiring changes to MOVs was performed.
We also inspected an additional 43 operators including 21 cquipped with dual voltage motors for the presence of splice ccnnectors other than T&B compression crimp connectors.
As a result of these efforts one other wirenut installation was found in MOV-SI-864A.
This wirenut was also replaced with a
qualified crimp connector on May 13, 1988 via Maintenance Work Roquest 883011.
Station procurement has removed wire nuts from stock for applications in safety related systems to preclude future misapplication of them in equipment on the Electrical Equipment Qualification Master List.
Maintenance supervisors have been instructed to perform a timely post maintenance review of EQ maintenance work requests prior to turning the equipment over to operations to assure the equipment has been properly repaired and restored.
A repeat training review of EQ maintenance requirements was conducted for Electrical Maintenance personnel on August 16 and September 1, 1988, emphasizing that to preserve environmental qualification, particular attention must be made not to introduce unqualified materials into the equipment or its interfaces which have boon qualified.
An 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> EQ seminar for Quality Control inspectors and supervisors and Electrical Maintenance and Construction supervisors was given on August 17 and 18, 1938.
This additional training has resulted in a better understanding and heightened awareness of the combined effort required by Maintenance, Quality Control and Engineering to preserve the environmental qualification of the equipment.
Corrective Steps which Will Be Taken to Avoid Further Violations A
review of Maintenance procedures is being conducted to identify any special requirements for qualified spare parts to preserve the qualification of the Limitorque Operators.
This review will be completed by September 30, 1988.
Additional EQ retraining classes will be held for those Electrical Maintenance personnel who have been unable to attend those classes to date.
We anticipate this will be completed by September 30, 1988.
The Date When Full Compliance will be Achieved Full compliance has been achieved.
As noted above, the review of maintenance procedures and retraining should be completed by September 30, 1988.