ML20205J013
| ML20205J013 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/24/1988 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810310253 | |
| Download: ML20205J013 (3) | |
Text
'!
i Bem ney Power State Stuppingport. PA 150774004 COL %
m m >s m October 24, 1988 U.
S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/88-23 and 50-412/88-18 Gentlemen:
In response to NRC correspondence dated September 23, 1988 and in accordance 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 respond to unresolved item 50-334/88-23-01 regarding the use of aluminum power cable in class 1E equipment.
This itom will be addressed via separate correspondence by November 10, 1988.
If there are any questions concerning this response, please contact my office.
Very truly yours, b
D. Sieber ice President luc' ear Group Attachment cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. W. T.
Russell, NRC Region I Administrator Mr. J. T. Wiggins, Chief Reactor Projects Branch No.
3, Division of Reactor Projects, Region I Director, Safety Evaluation & Control (VEPCO)
O.
8810310253 891024
{DR ADOCK 05000334
- I PDC i
l DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station, Unit No. 2 REPLY TO NOTICE OF VIOLATION Inspection No. 50-412/88-18 Letter dated September 23, 1988 VIOLATION (Severity Level IV, Supplement I)
DescriDtion of Violation (50-412/88-18-01)
Technical Specification 6.8 requires that written procedures be established, implemented and maintained covering activities listed in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
Chapter 17 of the Station Administrative Procedures, Reporting of.
Defects and Noncompliances, requires that analyses of defects which are potentially reportable under 10 CFR 21 be documented and returned to the plant manager within 30 days of receipt of documentation identifying a suspected defect or noncompliance.
Contrary to the above, on August 23, 1988, the licensee completed and returned to the plant manager, an analysis which identified a defect in three containment isolation valves that represented a potential safety hazard approximately 10 months after receipt of the documentation identifying the suspected defect.
The valves involved were subsequently found to be free of the defect described in the analysis when examined by the licensee.
Corrective Action Taken After BVPS
- 2 Xomox plug valves were declared inoperable on August 23,
- 1988, an operability evaluation was performed on all inservice Xomox valves per Nuclear Engineering Department requirements specified in Engineering Memo No.
74350.
This E.M.
provided instructions to examine the Xomox plug valve operators and criteria for required corrective action (pooning of mating surfaces to ensure proper coupling is maintained).
The actions specified in this E.M.
were implemented on all inservice valves via Maintenance Work Requests (MWRs) 886S35 thru 886545.
A Technical Evaluation Report No.
513 (including safety evaluation) was simultaneously completed to document the required procedural reviews for this effort.
A 10CFR21 evaluation report required by SAP Chapter 17 was completed and submitted to the On-Site Safety Committee for review per procedure.
The results of this examination were documented and transmitted for Engineering review via E.M.
63838 which determined that the examination and corrective action performed assured operability of all (11) inservice valves until a permanent repair via incorporating Xomox supplied upgrade kits is performed.
The permanent upgrade kits are currently at the offsite warehouse, and will be installed at the first opportunity, but no later than the First Refueling Outage scheduled for March of 1989.
l..'*
' Reply to Notico of Violation Page 2 Action Taken to Prevent Recurrence In. order to address the deficiency regarding the time frame for evaluating potential Part 21 activities utilizing SAP Chapter 17, the following actions have been taken:
i The Manager of Nuclear Safety has been identified as the focal point through which SAP Chapter 17 evaluation items are now to be processed and tracked.
SAP Chapter 17 has been reviewed and a draft revision issued for comment.
This revision clarifies the reporting and evaluation responsibilities.
On 8/26/88, the Nuclear Engineering Department reviewed all open Engineering memorandums for potential Part 21 implications.
There were no deficiencies identified requiring a 10CFR21 report to be filed.
The Nuclear Engineering Department will draft and issue an Engineering Standard addressing Part 21 issues by December 31, 1988.
The Engineering Standard is to define how Part 21 issues are evaluated, identified, and prioritized within the Engineering organization.
Date for Comoletion of Actiong 1.
SAP Chapter 17 is to be revised and issued by November 15, 1988.
2.
The Engineering Standard for addressing Part 21 issues will be issued by December 31, 1988.
1 l
l I