ML20205T285
| ML20205T285 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/04/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8606130091 | |
| Download: ML20205T285 (7) | |
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Telephone (412) 393-6000 Io.'*s'o'[l ","
Shippingport PA15077-0004 June 4, 1986 U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement
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Attn:
Mr. Edward C. Wenzinger, Chief L
Projects Branch No. 3 Division of Reactor Projects Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 L
Inspection Report 86-06 b
Gentlemen:
r In response to your letter of May 6, 1986, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation and the Notice of Deviation which were included with the referenced report.
We share your concern regarding the circumstances surrounding Violation B.
As requested, our reply addresses actions which should prevent recurrence.
If you have any questions concerning this
- response, please contact my office.
I Very truly yours, W
i e President, Nuclear Attachment cc W. M. Troskoski, Recident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric and Power Company P.O. Box 26666 One James River Plaza 8606130091 860604 ADOCK 05000 4
Richmond, VA 23261
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection 86-06 Letter dated May 6, 1986 VIOLATION A (Severity Level IV: Supplement I)
Description of Violation (86-06-02)
Technical Specification 4.3.3.5 requires remote shutdown monitoring instrumentation channel TRB-RH-606, RHR Temperature - HX Outlet, to be demonstrated operable by performance of a monthly channel check.
Technical Specification 1.10 defines channel check as a qualitative assessment of channel behavior during operation by observation.
Contrary to the
- above, the monthly remote shutdown monitoring instrumentation channel check failed to qualitatively assess TRB-RH-606 as inoperable from December 25, 1985 to March 19, 1986, when indicated readings were off-scale low (less than 50*F) at less than expected ambient temperature (70-80*F).
Discussion Our evaluation of this incident determined the following items materially contributed to this problem:
1.
The acceptance criteria contained within the procedure were inadequate for assessing the operability of the instrument since the requirements only compared the shutdown panel instrument response to, the control room temperature recorder.
Although the expected indication of the RHR temperature, while shutdown, does trend with containment temperature, no qualitative assessment of this expected response was required by the procedure.
2.
An inconsistency was identified in Technical Specification 3.3.3.5, regarding the Emergency Shutdown Panel, as it requires
" Channel Checks" and
" Operability" of the Source Range Nuclear
- Flux, Source Range Startup Rate and RHR Temperature Heat Exchanger outlet instruments in Mode 1.
This is inconsistent with the requirements of Technical Specifications 3.3.1.1 on the Source Range Instrumentation and Technical Specification 3.4.1.3 on the RHR System which do not require system level operability in Mode 1.
The requirements of Technical Specification 3.3.3.5 are potentially non-conservative and unnecessarily restrictive as they could force the plant into a shutdown condition which would require the need of this instrumentation.
Technical Specification 1.10 requirements for a
" Channel Check" specify that.."this determination shall
- include, where
- possible,
" Reply to Notica of Violction In pecticn 86-06 Letter dated May 6, 1986 Page 2 comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter" (emphasis added).
Since there are no installed
" independent instruments measuring the same parameter",
in the case of the RHR temperature instrument, and in consideration of the requirements of Technical Specification 3.4.1.3 only being applicable in shutdown conditions, these inconsistencies contributed to a
personnel error in Maintenance Work Request prioritization and concluding that the operability of this instrument was not required.
This conclusion is further supported in the Bases of Technical Specification 3.3.3.5 which states that..."The operability of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of Hot standby of the facility..."
(emphasis added) which could have been done without the benefit of the RHR System and associated instrumentation.
Corrective Actions Taken 1.
OST 1.45.2 wts revised to require a more critical examination of the expected response of the RHR temperature indicator and other instrumentation installed on the shutdown panel.
2.
OST 1.10.1 was revised to require a channel check of the RHR temperature indicator when the pumps are tested to check the dynamic response of the instrument.
3.
All control room and shutdown panel instruments that are part of the surveillance program were checked to insure that the calibration date was within the required frequency and channel l
checked.
No violations of Technical Specification requirements were found.
4.
All open Maintenance Work Requests (MWRs) were reviewed to determine if any other instrumentation required by Technical Specification was inoperable.
No violation of Technical Specification requirements were found.
I Date of Full Compliance I
These items have been completed.
Actions Taken to Prevent Recurrence 1.
This incident is being presented to operations personnel during Requalification Training Modulo 6
by the Site Opera *. ions Director.
This Module is scheduled to complete during June 1986.
l
Neply to N;tica of Violction In:pection 86-06 Letter dated May 6, 1986 Page 3 2.
Appendix "C"
of the Instrument and Control Department Manual has been placed in the Shift Supervisors office as a cross reference to assist the Operations Department in determining applicable Technical Specification requirements for related instruments.
The use of this document for the expressed purpose was implemented by Special Operating Order 86-1 dated 3/21/86.
3.
An amendment request to correct the inconsistencies in the Technical Specifications will be submitted by October 1, 1986.
Date of Full Compliance These dates have been provided above.
s
Reply to N:tica cf Violation Inspecticn 86-06 i
Letter dated May 6, 1986 l
Page 4 4
1 VIOLATION B (Severity Level IV; Supplement I)
Description of Violation (86-06-04) i F
Technical Specification 4.3.3.6.1 requires that the fire detection i
instrumentation accessible during normal plant operation for each L
fire detection zone listed in Table 3.3-10 shall be demonstrated j
operable at least once per six months by performance of a channel functional test.
A channel functional test, as defined by Technical Specification 1.11, is the injection of a simulated signal into the channel as close as practical to the sensor (detector) to verify operability including alarm and/or trip functions.
L contrary to the
- above, on March 26, 1986, it was determined that implementation of OST 1.33.16, Smoke Detector Instrumentation Test, on the smoke detection system in the No. 2 Diesel Generatcr Room, failed to demonstrate individual detector operability in that a l
complete channel functional test was not performed to verify the control room alarm function for each detector.
Due to inadequate i
- testing, the licensee was unaware that detector D100 was inoperable between January 7, 1985 and March 26, 1986.
i Corrective Action Taken i-The test procedure (OST 1.33.16) was revised to clarify the testing l
requirement and a
retest of the entire smoke detection system was i
conducted.
No similar problems were identified with the smoke detectors, and all detectors were verified operable.
i The contractor responsible for performing the surveillance testing and maintenance of the smoke detection system in the plant has been reminded cf the importance of procedure adherence while performing work at the site.
Action Taken to Prevent Recurrence The above procedure (OST 1.33.16) as clarified should prevent recurrence.-
In addition, the contractor responsible for performing the surveillance testing has enhanced its training program by including a
checklist to ensure that its technicians are fully aware of the procedural requirements at Beaver Valley Power Station prior to performing work at the site.
Date of Full Compliance l
Full Compliance has been achieved at this time.
[
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Deviation Inspection 86-06 Letter: dated May 6, 1986 DEVIATION (Supplement II)
Description of Deviation (86-06-03)
FSAR_ Appendix B,
Seismic resign, Section B.2.2.4, specification Requirements, states that all Seismic Class I equipment will be shown to meet the requirements for Operational and Design Bases Earthquakes.
For 'subh an
- event, stress- ' levels are kept within maximum working limits permitted under applicable design standards, or other codes or specifications.
FSAR Table B.1-1, Structures and Systems Requiring Design for Seismic
- Loading, identifies the emergency diesel fuel oil day tanks as Seismic Class I components.
Contrary to the
- above, on March 26, 1986, the licensee could not demonstrate that any applicable design
- standard, code or specification had been employe.d during the fabrication of the fuel oil day tank support stands 'as evidenced by incomplete and poor quality welds, and lack of any QC inspection records.
Corrective Action Taken An inspection of the emergency ' diesel fuel oil day tanks support welds was pe'rformed and Quality' Control Report 259 was issued on April 4,
1986.
Although no acceptance / rejection determinations were made on the
- welds, the report identified numerous apparent welding deficiencies.
The original design specification and seismic' calculations for the day tanks were reviewed substan,tiating the design adequacy of the l
supports.
- However, no documentation was found that verifies the supports were fabricated and installed in conformance uith the design specifications.
I Based on the
- above, Design Change Package (DCP) 739 has been l
initiated to install new supports on the fuel oil day tanks.
The new supports will be designed l installed and inspected as to insure the integrity of the day' tanks during a design bases earthquake.
Action Taken to Prevent Recurrence
- Current engineering procedural requirements ensure the review of design outputs against the Design Concept which were not' in existence at the time the fuel oil day tanks were installed.
Specifically, the following procedures presently address this concern:
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,,, Reply to Notica of Deviction In:pecticn 86-06 Lettcr dated M;y 6, 1986 Page 2 Nuclear Engineering Management Procedure NEMP 2.8, Rev.
3,
" Handling of Design Change Packages",
issued 5/22/84 requires verification of a design.
Nuclear Engineering Management Procedure NEMP 2.13, Rev.
2,
" Design Verification Guidelines, Methods and Requirements",
issued 4/5/84 included questions on the Design Review Checklist in addition to those required by ANSI N45.2.11 which require the Primary Verification Engineer to verify that the Design Outputs are in compliance with the conditions and conclusions stated in the Design Concept and Safety Evaluation.
Date of Full Compliance The new supports for the fuel day tanks will be installed prior to plant startup from the Fifth Refueling Outage (tentatively scheduled for August 1986) l l
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