ML20195C009
| ML20195C009 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/13/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806220071 | |
| Download: ML20195C009 (7) | |
Text
-'
aver Va ley Power Station
$4pp+ngport. PA 15077-0004
- ' N #2 JOHN D StEBER v<. n,-. ww opmem June 13, 1988 U.
S. Nuclear Regulatory C.w6 mission Attn:
Document Control Dettk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 88-08 Gentlemen:
In response to NRC correspondence dated May 12, 1988 and in acco15ance with 10 CFR 2.201, the attached reply addresses the Notice of Violation included with the referenced inspection report.
Your letter also asked that we describe our actions taken or planned to address the three unresolved items identified in the report.
These items are also addressed in our reply.
If there are any questions concerning this response, please contact my office.
Very truly yours, k
A !>4[L
. D. Siebe'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, Acting Directer, Division of Reactor Safety Director, Safety Evaluation & Control (VEPCO) k y
D
DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station, Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 88-08 Letter dated May 12, 1988 VIOLATION (Severity Level IV, Supplement I)
Description of Violation (88-08-01)
Section 6.8.1 of Beaver Valley Power Station Unit No. 1 Technical Specifications states in part:
"Written procedures shall be established implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2,
February 1987."
Appendix A of Regulatory Guide 1.33 includes precedures for equipment control (1.c) and performing maintenance (?).
Two examples of the licansee's activities not meeting the regulatory requirement were:
(1) The licensco's Quality Assurance Procedure Number OP-11,
"... detailed Revision 7;
paragraph 11.4.2 requires in part:
implementating procedures shall provide means for assuring...that the acceptability of systems and equipment is known throughout operation...".
Contrary to the above on March 4, 1988 the acceptability of the emergency diesel generator starting air system and associated equipment was not known during operation in that seismic
- supports, for thc 41r start accumulator, adjacent to valves 1DA-138 and 1DA-14C, were degraded due to loose bolts.
This caused the emergency diesel generator number 2 to be declared inoperable.
(2) The licensee's preventive maintenance proceddre (PMP)
No.
1-44VS-VNT-1E, Revision 3,
Table 1, requires the ventilation system dampers VS-D-22-2C and VS-D-22-2D and ventilation i
system fans VS-F-?2A and VS-F-22B to receive preventive maintenance at a frequency of 12 months.
7, Contrary to the
- above, as of March 30, 1988, there was no 1
objective evidence to assure that the dampers VS-D-22-2C and VS-D-22-2D 3nd the fans VS-F-22A and VS-F-22B received preventive maintenance at a frequency of 12 months since May 1986.
In
'R: ply to Notics of Violation l'n2pection No. 88-08 Letter dated May 12, 1988 Page-2 Part (1) Response Corrective Action Taken Upon discovery, Operations made a conservative decision to e
declare the No.
2 Diesel Generator inoperative.
A successful surveillance test of Diesel No. I was conducted within 50 minutes after the declaration.
The loose supports were shimmed and tightened by maintenance (MWR 882654) and the rest of the system was inspected for loose supports.
An engineering evaluation was performed (EM 74076) which indicated that the diesel air start system would have been capable of being operated during and after the postulated Design Basis Earthquake with these loose supports.
Action Taken to Prevent Recurrence The Construction and Maintenance Departments will evaluate their respective programs in regard to preventing this type of event.
Date of Full Compliance The evaluations by Construction and Maintenance of their programs will be completed by August 12, 1988.
Part (2) Response Corrective Action Taken We have reviewed the circumstances regarding preventive maintenance for the equipment identified.
It should be noted that at Beaver Valley, Preventive Maintenance tasks are identified by a Maintenance Engineer and then scheduled by computer generated cards.
The procedures themselves are not used to schedule tasks nor to direct the PM program.
The procedures are developed either for a
specific task, or can be generic and used to support tasks when
- needed, as was the case with PMP l-44VS-VNT-lE.
Therefore, the listing of applicable equipment within a PM procedures does not determine the preventive maintenance program and schedule.
The Proventive Maintenance Program at Beaver Valley was systemically developed based on vendor recommendations, instruction
- manuals, vendor and regulatory bulletins and notices, Tech.
Spec.
requirements, and operating experience.
Preventive Maintenance is a
perception of how the equipment should be
.Raply to Noti,ce of Violation Insp ction No. 88-08 Lottor dated May 12, 1988 Page 3 maintained.
It is developed through the criteria listed above as well as through various icending programs into a reliability centered program.
These trending programs include vibration
- analyses, temperature monitoring, OST performance, ISI inspections, and BV-T performance.
Programmatically, Maintenance Engineers also perform periodic reviews of corrective maintenance history and the PM program per The Conduct of Maintenanco chapter 9,
Section VI.D to insure that the task, frequency, and data acquired are acceptable.
These reviews are normally documented by letter.
As a
result of previous data obtained by fire damper testing (procedure BVT 1.3-1.33.5) and corrective maintenance trending, the entire preventive maintenance program on dampers and fans is in the process of being revised.
This was initiated by a Beaver Valley letter (NDlNSM:3154) dated February 29, 1988.
PMP 1-44VS-VNT-1E is being replaced by PMP 1/2-75VS-VNT-1M.
The dampers and fans associated with the Diesel Generators will be incorporated into our revised program.
Action Taken to Prevent Recurrence currently, for a
PM task to be revised or rescheduled, a
maintenance engineer must obtain approval from a maintenance and operations supervisor as documented on a
PM Task Addition / Initiation / Rescheduling Form.
To enhance this administrative
- control, Chapter 9
of the Conduct of Maintenance has been changed to require authorization from the site Maintenance Director in order to delete a PM task.
The revision to the PM program for dampers cnd fans will ensure that the dampers and fans associated with the Diesel Generators will be included in the PM program.
Date of Full Compliance The task cards and scheduling for the revised preventive maintenance program for dampers and fans will be completed prior to our next Unit 1 Refueling Outage (7R).
.-,g..,.7-, _ -
R3 ply to Notico of Violction In:pection No. 88-08 L3ttor dated May 12, 1988 Page 4 UNRESOLVED ITEM (88-08-02)
Inservice Testing Program for pumps uses a vibration monitoring system that yields inconsistent results.
As a result the observed readings varied between 2 and 8 mils depending on the individual performing the test and location for monitoring.
The licensee committed to review the current BV-1 vibration monitoring program to provide more consistent 1 sults.
Response
vibration inconsistencies have been limited to the Low Head Safety Injection Pumps (LHSI)
ISI-P-1A & B.
These inconsistencies were primarily due to the pumps' deep shaft design and inaccessability of the bearing locations.
Vibration readings were obtained utilizing a
"V" shaped shaft stick against the pump shaft at accessible locations.
This method provided inconsistent readings at least in part because shaft stick locations were not always the same.
During early attempts at standardizing vibration monitoring, shaft markings were made for guidance.
- However, performing vibration measurements tended to wear off these
- markings, resulting in continued inconsistencies in subsequent performances.
The practice of marking the shafts was discontinued, citing inability in finding a permanent marker that would not wear off and still meet site administrative restrictions on consumables.
A decision was made to revise the applicable surveillance procedures OST 1.11.1 and 1.11.2 to provide additional details for accurately positioning the shaft stick.
Both procedures have been recently revised and since then one set of performance data has been completed with satisfactory results.
Since the periodicity for performing surveillance testing for the LHSI pumps was also revised to quarterly to coincide with ASME Section XI, IWP-3400 guidelines, resulting data trends will not be completed until autumn of this year when the third set of data will be completed.
At that time, OST 1.11.1 and 1.11.2 will again be revised to begin taking vibration readings in terms of velocity (in/sec) as well as the present displacement (mils) readings.
'Rsply.to Notica of Violation Incpsction No. 88-08 l
Letter dated May 12, 1988 Page 5 UNRESOLVED ITEM (88-08-03 There was no justification for not incorporating vendor and engineering department recommendations in the station maintenance and operating procedures.
Specifically, the following engineering department authorized vendor recommendations for the turbine driven auxiliary feed pump were not incorporated into the plant maintenance and operation procedures.
(a)
Flushing of oil system for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (b)
Oil preheat to 110*F - 120*F (c)
Weekly testing of overspeed trip
Response
It was noted that vendor and Engineering recommendations were not incorporated into maintenance procedures for the Terry turbine.
A followup review was conducted by maintenance and it was determined that:
(a) an oil flush is only required for new installation (b) the oil does not have to be preheated as documented by a previous Engineering evaluation (EM 62106)
(c) the weekly testing frequency for overspeed trip is based on continuous service, therefore, the frequency was changed to commensurate with the operation of this pump at Beaver Valley.
In general, decisions made by Maintenance Engineers are documented in several ways such as procedure change request forms, PM Task Addition / Initiation / Rescheduling and celetion forms as identified in The Conduct of Maintenance Chapter 9, and PM critique forms which are the last page of Preventive Maintenance Procedures.
- Also, formal letters and memorandums reflect Maintenance Engineer's decisions.
Maintenance engineers have the technical expertise and experience to develop and implement PMP and corrective maintenance requirements and are programmatically ider,tified to perform these tasks.
(..
l *.
Rspl.y.to hotics of Violation In2pection No. 88-08 Letter dated May 12, 1988 Page 6 UNRESOLVED ITEM (88-08-04)
There was no engineering justification for assuring that the safety injection pumps will have sufficient net positive suction head during the recirculation phase of an accident if the containment reaches 8.9
- psia, as allowed in the emergency operating procedures.
Details from Inspection Report A
pressurized surge line break scenario, which resulted n a 700 gpm
- LOCA, was run.
The EOPs were adequate to stabilize plant conditions within the control limits specified by the EOPs.
The inspector questioned whether there would be adequate not positive suction head (NPSH) for the low head safety injection (LHSI) pumps if containment pressure was at the low end of the control band at 8.9 psia.
An accident analysis for a double ended rupture for the suction line to a reactor coolant pump shows that there is about a 0.5 psi difference between the available NPSH (11.2 ft of water) and the required NPSH (10.6 ft of water) at an assumed containment pressure of over 11 psia.
If the assumed containment pressure is reduced to 8.9
The licensee agreed to review the Concern.
There is no engineering bases which assures that the contaiament pressure control band of 14 to 8.9 psia will provide an adequate NPSH to the LHSI pumps during the recirculation mode.
Response
The calculations that were performed to determine the min: mum available NPSH for the LHSI pumps were reviewed and evaluated.
The calculations included sensitivity studies which determined the worst case for minimum available NPSH.
This case consisted of a large break LOCA with initial containment pressure at mininum allowable and maximum available safeguards.,We are in the process of constructing guidance for the operators to be inserted in the EOPs in the form of a lower limit for containment pressure as a function of containment sump temperature and LHSI pump flow rate to assure adequate NPSH to the LHSI pumps during recirculation mode.
This evaluation is based on the sensitivity studies previously performed, and will be documented in a Duquesne Light company calculation.
The results will be completed by July 29, 1988.
Procedure writers will incorporate the information into the EOPs by December 31, 88.
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