ML20197D778
| ML20197D778 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/28/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806070389 | |
| Download: ML20197D778 (7) | |
Text
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'Af Telephone (412) 393-6000 Nuclear Group ShSppYn'oport, PA 15077 0004 Y
.-S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 88-12 Gentlemen:
In response to NRC correspondence dated April 28, 1988 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation for the referenced inspection report.
The violation was discussed at an Enforcement Conference held in King of Prussia on March 24,-
1988.
A copy of the Enforcement-Conference Agenda is enclosed with our Reply to the Notice of Violation.
Your letter also asked that we describe our actions taken or planned to assure that FSAR commitments are met.
This is also addressed in our reply.
If there are any questions concerning this response, please contact my office.
Very truly yours, n.
/. D. Sieber I ice President Nuclear Group Attachment l
cca Mr. J. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Director, Safety Evaluation & Control (VEPCO) l I
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8806070389 880528 PDR ADOCK 05000334
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DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No 88-12 Letter dated April 28, 1988 VIOLATION (Severity Level III; Supplement I)
Description of Violation (88-12-01)
Tecnnical Specification Limiting Condition for Operation 3.3.2.1
- requires, in
- part, that whenever the reactor is in the power operation,
- startup, or hot shutdown
- modes, the engineered safety feature actuation system instrumentation channels shown in Table 3.3-3 shall be operable.
Table 3.3-2 specifies that a minimum of three of the four containment pressure High-High channels shall be operable for automatic actuation of the containment spray systems (CSS) and phase "B" containment isolation (CIB).
Technical Specification LCO Action Statement 3.3.2.1.b specifies that when the number of operable channels is one less than the total number of channels (4),
the licensee shall demonstrate that the required number of minimum channels operable (3) is met within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Operation may continue with the inoperable channel bypassed and one additional channel may be bypassed for up to two hours for testing in accordance with Technical Specification Surveillance Requirement 4.3.2.1.
l Contrary to the above, between about 7:30 a.m. on February 24, 1988 and about 6:30 a.m.
on March 3,
- 1988, while the reactor was at various time.s in the hot shutdown, startup or power operation modes, the required minimum number of operable high-high containment pressure channels (3) was not maintained in that two of the four channels for CSS actuation and CIB isolation were inoperable because their associated bistables were in the bypass position.
Reason for Violation l
The violation involved the inoperability of two of four channels used to actuate the Containment Spray Systems and Phase B Containment Isolation whenever high-high containment pressure setpoints were exceeded.
The channels were inoperable in that their associated bistables were in the bypassed position, and therefore, not capable of performing the intended automatic safety function.
The bistables were left in this condition after completion of maintenance surveillance tests performed on February 22, 1988.
As a result, although the safety function remained available throughout the period since the other two channels were operable, the "built-in" redundancy
(
for automatic actuation of these systems was lost.
At the time the tests were performed, the reactor was in the cold shutdown mode and being prepared for startup.
l
Raply to Notice of Violation Inspection No. 88-12
.Pa'ge 2 The procedure. used to perform the maintenance surveillance test specified that if the reactor was in the cold shutdown or refueling
- modes, the bistables were to be returned to the bypassed position upon completion of the test.
It was envisioned that the startup checklist, performed prior to entering the hot shutdown condition, would identify this bypass condition and return the bistables to the proper position prior to startup.
However, the startup checklist had been performed apprcximately six hours prior to the performance of the maintenance surveillance test for those two channels.
As a
- result, the bistables were placed in the bypassed position after the startup checklist had been completed.
Additionally, during the investigation into this event it was discovered that there was no Control Room indication of these bistables being bypassed, contrary to IEEE 279 and the Beaver Valley Unit I FSAR requirements.
Although there was cor. trol room indication at the time the commitment was made in the F.3AR, this indication capability was removed during a plant modification (DCP 94) made in 1980.
Corrective Actions Taken 1.
An immediate investigation was initiated to determine why these bistables were bypassed.
After verifying that no valid reason existed for having these bistables bypassed, they were returned to service within 30 minutes of discovery.
2.
A walkdown of all reactor protection and ESF bistables was conducted on the following shift, using Operating Manual Table 1-6, Reactor Protection Bistable Function and Location List.
All bistables were found in the normal alignment.
3.
Plant operators performed a walkdown to verify the normal system alignment positions of specified ESF valves. raitches, breakers and power supplies as per Special Operating Order No. 85-9, Unexplained or Malicious Degradation of Safeguards Operability.
The ESF verification identified no components out of normal system alignment.
4.
The event was reported to the NRC pursuant to 10 CFR 50.72 l
notification requirements and LER 88-04 was issued pursuant to 10 CFR 50.73 criteria.
In addition, the event was placed on NOTEPAD to alert other utilities to this problem.
l S.
The Operations Dep,Jtment performed a
review of Operations Surveillance Tests that are performed prior to startup to l
determine if similar alignment problems could exist
.(i.e.,
l restoring a
system to Mode 5 conditions follcwing an alignment l
that was intended for mode escalation.)
Operating manual changes I
were implemented to correct deficiencies identified as a result l
of this review.
l 6.
Detailed reviews of this incident were conducted by senior l
management to determine the root causes and necessary corrective actions.
l
lRoply to Notice of Violation Inspection No. 88-12
,Pa'ge 3 7.
A review of DCP 94 was performed to determine the reason why the bypassed / inoperable status indication in the Control Room for the four High-High Containment Pressure (HHCP) bistables had been deleted.
This change was not a design objective for DCP 94 and was made to accommodate bistable monitoring of a design change required as a license condition for Beaver Valley 1.
8.
A review was performed on all modification packages associated with the Control Room status lights and main annunciator panels from initial startup through March 14, 1988.
No similar circumstances were found.
9.
Safety Evaluations of all operationally accepted Category I and F Control Room-related electrical design change packages were reviewed for adequacy.
No similar problems were identified.
- 10. LCP 1044 was initiated to reinstate the HHCP bistables status indication.
Installation was completed on March 23, 1988.
Action Taken to Prevent Recurrence 1.
The Containment Hi-Hi Pressure bistable surveillance procedures have been revised to prevent recurrence of this event.
The procedures now require the Maintenance technicians to leave the bistables in their "as found" condition.
If the bistables are found
- bypassed, the procedure requires the technicians to notify the NSS before leaving them in a
bypassed state.
We have evaluated the procedure sequencing problem as the basic root cause of this event.
2.
A review of maintenance surveillance procedures was performed to determine if additional procedural deficiencies existed with I
respect to protection histables directed to be placed in l
off-normal positions that are dependent on plant mode.
Similar I
discrepancies were corrected.
3.
A review of the station startup procedures was conducted to verify that all safety-related components, realigned during the shutdown
- sequence, are placed in their normal arrangement for a j
given operating Mode prior to entering that mode.
4.
A review was initiated to determine if any other safety-related functions cot d be bipassed without Control Room indication.
l l
This review determined that indication existed for all safety-related functions with the exception of the Hi-Hi l
Containment Pressure bistables and the Refueling Water Storage 1
Tank (RWST)
Lo-Lo Level bistables.
DCP 1044 has installed Control Room indication to alert the operator whenever any l
Containment Hi-Hi Pressure or RWST Lo-Lo Level bistable is bypassed.
l l
R3 ply to Notice of Violation
- Ingpsction No. 88-12 Pige 4 A.
5.
The Startup Procedures will be completely reviewed and revised to ensure that mode dependent systems are verified operable prior to entering the required mode.
Guidelines being used for this review will include:
a.
All ~ action steps will be performed in the procedure and not in a checklist.
b.
The present checklists will be combined and/or deleted as necessary, c.
A new checklist is being developed and will be performed during the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> preceding entrance into Mode 4.
It will include:
Control Board Walkdowns to ensure proper control switch alignment, abnormal status lights and/or annunciators, verification of Protection Rack switches including Solid State Protection
- System, and Containment Integrity verification.
Date of Full Compliance With the restoratica of the bistabla status indication to IEEE 279-1971 compliance via DCP 1044 and revision to the maintenance surveillance procedures, the plant in full compliance at this time.
The new checklist identified in item 5.c. above will be completed by the next station startup from Mode 5.
FSAR Commitments During the investigation into this event it was discovered that there was no Control Room indication of these bistables being bypassed, contrary to IEEE 279 and the Beaver Valley Unit 1 FSAR requirements.
Although there was control room indication at the time the ccmmitment was made in the FSAR, this indication capability was lost during a plant modification (DCP 94) made in 1980.
A change to the FSAR was not made at that time because the design concept for DCP 94 did not specifically address modifying the HHCP l
bypass indication.
The engineering procedures controlling design concepts at that time required an update of the design concept during the detailed design and installation phase if significant changes occurred in the design objectives or boundaries of the design change.
In retrospect it was an error on the part of the design l
engineer not to update the design concept for DCP 94 when it was l
decided to delete the existing bypassed bistable lights as well as a error of ommission in that the applicable sections of the FSAR and IEEE standard were not properly evaluated.
Rnply to Notice of Violation Inspection No. 88-12
.Page 5 Several procedure changes have been made since 1981, which provide increased assurance that adequate design change 10CFR50.59 safety evaluations are performed.
These changes include:
1.
Clarification of the content requirements for design concepts.
Wording was added that clarifies that the boundaries of change portion of the design concept must include the affected structures, systems and components and the proposed additions and deletions of the desc?.ibed boundaries.
2.
Addition of a
specific procedure requirement for engineers assigned to perform safety evaluations to review the design concepts for completeness and to request additional informaticr.
from the engineer who prepared the design concept if they determine that the design concept is incomplete or inadequate.
3.
Addition of a
specific procedure requirement for engineers assigned to perform safety evaluations to evaluate the effect of proposed changes on plant systems sud components, including the effects of systems interactions and to calculate or assess the resulting effect of the change on plant safety and the protection of the health and safety of the public.
4.
Addition specific guidelines for the format and content of 10CFR50.59 safety evaluations.
5.
Upgrading up of the requirements for updating design concepts and safety evaluations.
The current procedures require that if, during the course of design development or installation, it becomes necessary to deviate from the approved design objectives, structure, system or component boundaries, the design concept and safety evaluation shall be revised.
6.
Addition of qualification and training requirements for Onsite Safety Committee members.
In
- addition, engineering personnel performing safety evaluations have received formal training in the 10CFR50.59 process.
An integral part of this
- training, and the current design update
- process, specifies that plant modifications performed under 50.59 are subsequently updated, as required, pursuant to 50.71 requirements.
Enforccm' int Conference Agonda
>i March 24, 1988
Subject:
Special Inspection No. 50-334/88-12 dated 3/10/88 Degraded ESF Actuating Circuit
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1.
Introductions, opening remarks J. D.
Sieber 2.
Event Chronology and NRC Comments W. T. Russell (NRC) 3.
CIB Circuit Description W.
S.
Lacey 1026 - 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> Immediate corrective actions e
4.
Root cause evaluation J. C.
Crockett 1028 - 1122 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.26921e-4 months <br /> Broader implications of event e
e Corrective actions Adequacy of controls allowing work on safety related equipment 5.
Adequacy of safety evaluations for past N. R. Tonet station modifications involv3pg safety 1123 - 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br /> related equipment.
Licensee plans to restore the CIB circuitry to meet IEEE-279 Section 4.13 Circuitry Adequacy of other ESF circuits to meet e
IEEE-279 - 197. Section 4.13 require-ments i
6.
Factors that worsened or mitigated the K. D.
Grada l
event 1146 - 1250 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.75625e-4 months <br /> Safety significance e
Risk assessment e
Emergency Operating procedures e
Control Room Instrumentation & Control e
l 10 CFR 2 Appendix "C" Criteria e
Best estimate containment and radiological e
analysis with delayed CIB actuation 7.
Open discussion, questions / answers NRC/DLC 8.
Closing remarks J. D.
Sieber
. - -.