ML20155F232

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-334/88-21

ML20155F232
Person / Time
Site:	Beaver Valley
Issue date:	10/10/1988
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Sieber J DUQUESNE LIGHT CO.
References
NUDOCS 8810130190
Download: ML20155F232 (2)

See also: IR 05000334/1988021

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OCT 101999

Docket Nos. 50-334

Ouquesne Light Company

ATTN: Mr. J. D. Sieber

Vice President

Nuclear Group

Post Office Box 4

Shippingport, Pennsylvania 15077

Gentlemen:

Subject: Inspection Raport No. 50-334/88-21

This refers to your letter dated September 2,1988, in response to our letter

dated August 3, 1988.

Thank you for informing us of the correcti e and preventive actions documented

in your letter. These actions will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated. j

Sincerely, I

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Ort.r t r:15 t5r.et By s

Jacque P. Durr

Thomas T. Martin, Director

Division of Reactor Safety

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8810130190 001010

gDR ADOCK 05000334

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OFFICIAL RECORD COPY RL BV1 88-21 - 0001.0.0

09/27/88

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Duquesne ' Light Company -2-

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J. J. Carey, Executive Vice President, Operations

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J. O. Crocket?., General Manager, Corporate Nuclear Services

W. S. Lacey, General Manager, Nuclear Operations -

N. R. Tonet, Manager, Nuclear Engineering i

T. P. Noonan, Plant Manager  !

C. E. Ewing, QA Manager <

K. D. Grada, Manager, Nuclear Safety

Public Document Room (POR) .

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

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Region I Docket Room (with concurrences)

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September 2, 1988

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U. S. Nuclear Regulatory Commission

Attn Document Control Desk

Washington, DC 20555

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Reference: Beaver Valley Power Station, Unit No. 1

Docket No. 50-334, Licence 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

of Violation included with the referenced inspection report. .

If there are any questions concerning this response, please

contact my office.

Very truly yours,

$j

. D. Sieber r

Vice President

Nuclear Group

Attachment

cc Mr. J. Beall, Sr. Resident Inspector

Mr. W. T. Russell, NRC Region I Administrator

Mr. William V. Johnston, Anting Director,

Division of Reactor Safety

Mr. P. Tam, Project Manager .

Director, Safety Evaluation & Control (VEPCO) l

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DUQUESNE LIGHT COMPANY

Nuclear Group

Beaver Valley Power Station, Unit No. 1

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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 the

equipment to be qualified is acceptable. .

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 estcblish the qualification of Ideal

Model wirenuts utilized in the motor stator wiring circuit. .

Admission or Denial of Alleged Violation

The violation is correct as stated.

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Reason for Violation

During the performance of a routine Equipment Qualification (EQ)

inspection in April, 1987 for motor operated valve MOV-SI-885B, a

motor lead wire was found damaged and had to be repaired.

The maintenance instructions / procedures used for the EQ inspection

did not specifically addreas the repair of the particular Limitorque l

wiring found to be damaged since this wa; not part of the preplanned

inspection. Consequently, Maintenance obtained a wirenut which was

stocked for use in safety related systems, but which was not approved

for use in Electrical Equipment Qualification Master List (EEQML)

equipment. Approved methods for reconnecting / splicing wiring in

EEQML equipment were in existence at that time and should have been

used.

DLC believes the major contributing factor to the occurrence of this

violation was a weakness on the part of the Maintenance 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 l

approval by the Equipment Qualification Group. I

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Corrective Steps Which Have Been Taken And Results Achieved j

The wire nut for valve MOV-SI-885B was replaced with a qualified

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compression crimp connector on May 12, 1988 via Maintenance Work

Request 883020. ,

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AEPLY.TO NOTICE OF VIOLATION

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To. a'scertain 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 equipped with dual voltage

motors for the presence of splice connectors 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 Request 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 Manter List.

Maintenance supervisors have been instructed to perform a timely post "

maintenance revicw of EQ maintenance work requests prior to turning

the equipment over to operations to assure the equipment aas 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 been 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, 1988.

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

qualificatica 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

complated by September 30, 1988.

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Additional EQ retraining classes will be held for those F,lectrical l

Maintenance personnel who have been unable to attend ther. classes to '

date. We anticipate this will be completed by September 20, 1988. l

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

i september 30, 1988.

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