ML20195G818
| ML20195G818 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/18/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8811300061 | |
| Download: ML20195G818 (5) | |
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<:unm Novonbor 18, 1988 U. s. Nuclear Regulatory Commission Attn.
Document Control Desk Washington, DC 205C5 Roference:
Boavor Valley Power Station, Unit No. 1 Docket };w. 50-334, Licenso No. DPR-66 Reply to 1otice of Violation Inspection Report Nos. 50-334/86-12 and 50-334/88-21 Gentlemen:
Based on the results of the Enforcement Conference on August 12,
- 1988, items previously identified as potential enforcement items (50-334/86-12-03 and 50-334/88-21-02) have been categorized as one icvority Level IV violation.
In response to NRC correspondenco dated October 20, 1988 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation.
If there are any questions concerning this response, please contact my office.
Very truly yours, l> <,e a
'J.
D.
Sieber Vice President Nuclear Group Attachment cc:
Mr. J.
Beall, Sr. Residol.t Inspector Mr.
W.
T.
Russell, URC Region I Adainistrator Mr. Thomas T. Martin, Director Division of Reactor Safety, Region I Director, Safety Evaluation & Control (VEFCO) h F111300061 G;1118 ss emamam 9
F DL J
DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station, Unit il j
REPLY TO NOTICE OF VIOLATION Inspection No. 50-334/86-12-03
)
50-334/88-21-02 Letter date:
October 20, 1988 i
VIOLATION (Items 86-12-03 and 88-21-02 have been categorized in the aggregate as a
Severity Level IV violation, supplement I)
Descriotion of Violation (86-12-03)
[
On June 12,
- 1986, the NRC inspectors determ ned that the i
qualification of the Victoreen High Range Radiation Monitor (HRRM) cable assembly was not established.
There was inadequate test or analytical inforcation to demonstrate that these
)
instruments would satisfy performance requiremente as a result of potentially high thermal-induced leakage current in the cable I
assembly during accident conditions.
The HRRMs are provided to l
monitor variables specified in Regulatory Guido 1.97 and are therefore defined as electrical equipment important to safety by 10 CFR 50.49(b)(3).
Two HRRMs were identified with this deficiency.
i Reason for Violation 1
The timing of the implementation deadline date for the post TMI modifications and outage schedule of BVPS-1 caused the containment HRRM to be installed with a qualified containment i
penetration module consisting of a
- shielded, twisted l
instrumentation cabic.
DLC was unable to secure a qual!fiable coaxial cable penetration during the outagn vindow.
The existence of 60 inches of the twisted pair at the penetration was not considered to invalidate the operation of the HRRM system.
(
The HRRM provides indication of radiation field dens.ty through j
eight orders of magnitude.
The intent of the modification and i
the design of the device does not allow a precise reading to be
]
taken due to the low level signal.
DLC was pWare of the ter; 71oov prohlons of being able to
[
ampcra signal witn conventional l
sacertain an unemplified p2 cabling during postulate-m ident scenarios.
This problem is generic to the nuclear i Si try.
Continuous coaxial cable was i
t the preferred instal 1MJon u.?.aod, but the IR readings still left doubt as to the reltability of being able to detect the low signal levels.
The various coaxial cables did not have a high success ratio during testing when the cables interfaced with a connector.
The more vulnerable connector shell to cable outer jacket interface usuall) allowed moisture intrusion which caused l
l signal degradataen.
Dic considered their installation on a par with tha industry.
Inc ustry recoqnized the inability to obtain
(
preci.
containment radiation readings using components and cable that,u available at the time.
l i
x
Reolv to Notice of Violation (cont.)
Page 2 NUREG/CR
- 4728, February,
- 1988, reports the results of Sandia 1
tests for synergistic effects of MSLB temperature combined with heat produced during exposure to radiation of HRRM.
Sandia concluded the detector passed the testing and the test anomalies observed were due to cabling and connector problems.
This reinforces the contention that the existing technology continues to experience problems wi.th low level signal transmission during simdlated accident conditions.
Corrective Stoos Which Have Been Taken And Results Achieved DLC has installed a
fully qualified cabling and containment penetration medification to enhance the HRRM system.
The key factors which increase reliability of this detection system are listed below:
The V'.ctoreen sponsored testing monitored a system status light during the MSLB/ LOCA simulation.
The data tapes were lost in transit and therefore, the ability of the monitor to detect radiation with a measure of repeatability during a DBE cannot be assessed.
DLC utilized testing on an identical monitor for another utility to demonstrate the ability to sense radiation during a DBE.
This was accomplished by exposing the monitor to a known source during the DBE simulation and monitoring the output of the device.
DLC chose to investigate alternate cabling methods other than a vapor-proof raceway system.
Utilizing an A-E to coordinate the
- research, design, and acceptance testing, DLC has completed the inLtallation of a hermetically sealed, stainless steel sheathed, mineral-ins 11ated triaxial cable.
An additional benefit is that only the
- onnection to the Victoreen detector is exposed to the DBE environment.
The second cable interface is in the cable vault exterior to the containment.
DLC feels this is a
significant improvement in system configuration from the conventional installations.
The installation was inntalled in an expedient manner considering the magnitude of development, testing, engineering, procurement, and necessary construction labor for the design change installation.
Corrective Stepa Taken To Avoid Further Violations Design Changes are now reviewed at the Design Concept Review Mocting to assure compliance with design requirements.
This mooting reviews the design objectives,
- approach, schedule, constructability, operability, maintainability and testability of the new or modified systems.
In
- addition, the engineering proceduie on Design Concept development, requires a review of the Enviro /nontal Oualification considerations in accordance with the Engineering Procedure on Environmental Qualification of Class 1E equipment.
Reply To Notice of Violation (cont.)
Page 3 Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Description of Violation (88-21-02) on May 12, 1988, the inspector found an unidentified, unqualified wire jumper in MOV-RW-105D.
This MOV was recently added to the licensee's electrical environmental qualification master list (EEQML) to satisfy the guidance of Reg. Guide 1.97 and is defined as electrical equipment important to safety by 10 CFR 50.49 (b) (3).
In follow-up inspections of MOVs conducted by the licensee between May 12 and June 11, 1?88, the licensco identified an additional 20 MOVs, that had been added to the EQ master list to satisfy Regulatory Guide 1.97 guidance with unidentifiable, unqualified jumper wire.
In addition, on June 6,
- list, the licensee identified 11 MOVs in the charging and safety injection systems with unqualified wire.
Reason For Violation The internal wiring of MOVs was inspected in response to Information Notico 86-03.
Interviews with persons involved in those inspections indicated
- that, although the inspection checklist did not make such a distinction, it was interpreted to apply only to "vendor supplied" jumper wires.
The inspection scope was not adequately defined and therefore the inspection personnel exempted certain wires from scrutiny.
Persons performing subsequent inspections did not make this distinction resulting in the proper replacement of any jumper wire that was not identified as qualified.
DLC believes the major contributing factor to the occurrence of this violation was a
weakness on the part of Maintenance and Quality Control personnel involved in understanding the leiol of traceability required to demonstrate Equipment Qualification.
Corrective Steos Which Have Been Taken And Results Achieved As a
result of the discovered deficiency in Limitorque wiring inspection, the 27 MOVs added to the EEQML as a result of Reg.
Guide 1.97 were inspected.
Eighteen MOV's were reworked, six had satisfactory
- wire, and three (MOV-CH-308A, 308B, 308C) remain to be reworked.
A Justification for Continued Operation was abmitted for thesu three.
The original EEQML contained 42 a.
An inspection of dual voltage Movs for Thomas & Betts connectors indicated 5
MOVs had unanalyzed jumper wires.
A review of previously inspected MOVs was conducted to determine whether any additional MOVs might be suspect.
The results of th's review indicated that, in addition to the 5 MOVs noted above, 13 other MOVs merited reinspection.
',, 1-Reolv to Notice of Violation (cont.)
Page 4 Between June 9
and June 11, 1988, wires in the 5 deficient MOVs were replaced with qualified wire.
The 13 suspect MOVs were inspected with the result that 11 were reworked and 2 were found to be acceptable.
Corrective Steos Which Will Be Taken To Avoid Further Violation A
review of the Corrective Maintenance Procedure for Limitorque MOVs has been completed to identify any special requirements to preserve the qualification of the Limitorque operators.
Included in the revised procedure will be a
matrix with EQ approved l
component parts for the MOVs identified in the EEQML.
Any i
deviation from the information noted requires Engineering approval.
- Also, a
checklist / data sheet will be included in a Preventive Maintenance Procedure (PMP) to be completed whenever the PMP is performed.
Additional EQ training held for Electrical Maintenance and Quality Control personnel was completed September 30, 1988.
The scope of training for the Maintenance l
personnel included (1) a description of why certain equipment is i
subject to rules regarding environmental qualification, (2) an explanation of the EQ rule 10CFR50.49, and (3) how Maintenance can preserve the qualification status of the equipment.
A training module specific for Limitorque MOV EQ requirements has been drafted and will be presented to the Electrical Maintenance personnel during the first quarter of 1989.
This training will a
detail the EQ require.ments for the replacement parts, proper lubrication, T-drain and grease relief valve requirements, internal wiring and motor lead terminations.
The Nuclear 4
Engineering Department procedure is being revised to clarify when new equipment is added to the EEQML.
The Date When Full Compliance Will Be Achieved Full compliance has been achieved.
The additional training and procedure revision will be completed by March 30, 1989.
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