ML20214V144
| ML20214V144 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/28/1987 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-7-149, IEIN-83-38, NUDOCS 8706110467 | |
| Download: ML20214V144 (8) | |
Text
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'At3 2NRC-7-149 Beaver Valley No 2 Unit Project organization Telecopy(41 )
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May 28, 1987 o
Shippingport, PA 15077 United States Nuclear Regulatory Commisison Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTI9N:
Mr. Steward D. Ebneter, Director Division of Reactor Safety SUSJECT:
Beaver Valley Power Station - Unit No. 2 Cocket No. 50-412 Inspection Report 50-412/86-29
REFERENCES:
- 1) Letter dated December 30, 1986 (S. D. Ebneter to J. J. Carey)
- 2) Letter dated April 28, 1987 (W. T. Russell to J. J. Carey)
Gentlemen:
Reference 2, dated April 28, 1987, transmitted a Notice of Violation.
The Attachment to this letter provides Duquesne Light Company's (DLC) response pursuant-to the requirements of 10CFR2.201 and the NRC's Notice of Violation.
DUQUESNE LIGHT COMPANY By
.M i
//J. D. Sieber VVice President Nuclear LMR/ijr NR/IR/50412 Attachment 3
cc: Mr. P. Tam, Project Manager (w/a)
Mr. J. Beall, NRC Sr. Resident Inspector (w/a)
Mr. L. Prividy, NRC Resident Inspector (w/a)
NRC Document Control Desk (w/a) 8706110467 570528
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United States Nuclear Regulatory Commission Mr. Steward D. Ebneter, Director Inspection Report 50-412/86-29 Page 2 COMMONWEALTH OF PENNSYLVANIA )
Ss:
COUNTY OF BEAVER On this,[MI, day of
, / k [, before me, a Notary Public in and for said Commonwdalth and County, personally appeared J.
D. Sieber, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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ATTACHMENT-Violation 86-29-01 During an NRC inspection conducted between September 29 and October 3,1986, a -
violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is set forth below:
10 CFR 50.55(e) requires, in part, that the Commission be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and with a written report within 30 days, of each deficiency in design and construction which, were it to have remained uncorrected, could have affected adversely the safety of operations at. any time throughout the expected lifetime of the plant, and which represents a significant deficiency in construction which will require extensive redesign or repair to establish the adequacy of the component to perform its intended safety function.
The written report shall include a description of the correc-tive actions taken and sufficient information to permit analysis and eval-uation of the deficiency and of the corrective action.
Contrary to the above, Duquesne Light Company (DLC) did not adequately describe, as required by 10 CFR 50.55(e), the corrective actions taken and provide sufficient information to permit analysis and evaluation of a deficiency and of corrective action for the deficiency that, were it to have remained uncorrected, could have affected adversely the safety of operations and that required extensive repair / redesign to establish its adequacy to perform its intended safety function.
Specifically:
a.
On June 16, 1983, the NRC was notified by DLC that an error was identified in the Westinghouse 7300 Process Protection System involving deficient Temperature Channel Test (NTC) circuit cards at Beaver Valley 2.
The final written report of the deficiencies submitted to the NRC on August 26, 1983 did not adequately describe the corrective actions in that the report stated the NTC circuit cards would be - replaced.
However, NTC circuit cards in safety-related Balance-of-Plant applications were subsequently determined to be acceptable and NTC cards in the process protec-tion system were subsequently modified by the installation of an additional circuit board, and the NRC was not notified of this change in corrective actions, b.
On July 25, 1984, deficiencies were identified by DLC involving 21 deficient Loop Power Supply (NLP) circuit cards in the Westing-house 7300 Process Protection System and the Commission was not notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and a written report required to be submitted within 30 days was not provided until March 13, 1986.
This is a Severity Level III violation (Supplement II).
Page 1 of 5
Response
A thorough review of all documentation relating to the NLP and NTC cards has been completed.
This review has determined that the reason for the viola-tion was the result of an oversight on the part of the cognizant personnel.
Attached to this letter is a final six part report detailing all the action taken with regard to the NLP and NTC cards.
As acknowledged in the inspection report submitted on December 30, 1986, the corrective action has been completed and is acceptable.
With regard to the action to be taken to further avoid violations of this nature, BVPS-2 feels confident that the program in place for the handling of 10CFR50.55(e) concerns is adequate and no changes need to be made to this pro-The late filing of this one issue is viewed as an isolated occurence.
gram.
Currently, all 10CFR50.55(e)'s are tracked on a computer and statused weekly at tne DLC "NRC Next Step" meeting chaired by the Regulatory Affairs Department (RAD) Lead Compliance Engineer. At this meeting, the "Next Step" towards completion of these items are discussed, including submittal of reports to the NRC and status of corrective action.
Since this reporting incident is an isolated occurrence, based on past history of reporting, and considering the programs to monitor the progress and completion of 10CFR50.55(e) items that are currently in effect, BVPS-2 feels that full compliance with NRC regulation has been and will continue to be attained.
Page 2 of 5
1.
Summary The NRC Office of Inspection and Enforcement issued IE Information Notice No. 83-38, " Defective Heat Sink Adhesive and Seismically Induced Chatter in Relays within Printed Circuit Cards," on June 13, 1983.
This Informa-tion Notice informed recipients of problems with the Westinghouse 7300 Process Protection System printed circuit cards.
The problem printed circuit cards are the Loop Power Supply (NLP) cards and the Temperature Channel Test (NTC) cards. Note that the IE Notice was based upon a letter from the NSSS Designer (7300 Process Protection System) and did not address the Secondary Process Racks (furnished by the A/E).
2.
Immediate Action Taken Mr. S. D. Hall, Lead Compliance Enginer, Beaver Valley Power Station Unit No. 2, notified Mr. H. Kister, tRC Region I, of this concern on June 16, 1983.
An Interim Report, 2NRC-3-046, was issued July 19, 1983, and a Final Report, 2NRC-3-068, was issued on August 26, 1983.
A Supplement Report, 2NRC-6-023, was issued on March 13, 1986.
3.
Description of Deficiency NLP The first problem concerns the NLP cards which were shipped from Westing-house Industrial Electronics Division (W-ISD) between August 1,1980, and September 1, 1982.
These cards were found to have adhesive bond failure which could cause the heat sink plate to separate and fall of f of the printed circuit board.
The plate is a conductive metal and under certain circumstances could cause shorting of low level signals if it became wedged between cards in a card frame. The affected printed circuit boards are:
5NLP sub-level 18 and above; and, 6 NLP sub-level 18 and above. The heat sinks of concern can be identified by an inspection of the printed circuit cards for hex nuts which are visible on the top side of the assembly.
Twenty-one (21) NLP cards are located in the Secondary Process Racks (RK*2SEC-PROC A&B) and five spares are located in the war ehouse.
NTC The second problem deals with contact bounce of mercury relay contacts experienced during seismic testing of the NTC cards.
The subject NTC cards are located in the Westinghouse 7300 Process Protection System (Primary Process Racks RK*2PRI-PROC 1, 2 &3), and in the safety-related 80P Racks (Secondary Process Racks RK*2SEC-PROC A, A1, B & B1).
A total of 27 NTC cards have been identified in the Primary and Secondary Process Racks.
Thirteen of these are in the Primary Process Racks, and fourteen are in the Secondary Process Racks.
For the NTC cards used in the Westinghouse 7300 Process Protection System (Primary Process Racks)
Page 3 of 5
1 9
the possibility exists for signal saturation of the downstream RTD Ampli-fier (NRA) card in the T Hot and T Cold circuits. This signal saturation could resut in a possible: delay of the Overtemperature-Delta Temperature (OTAT) and Overpower - Delta Temperature OPAT) trips.
The NTC cards in the B0P Racks (Secondary Process Racks) are utilized for temperature control of the diesel generator building and the emergency switchgear room, and for post-accident temperature monitoring of the reac-tor containment sumps and fuel pools.
Two additional NTC cards are located in the warehouse.
4.
Analysis of Safety Implication NLP The adhesive bond failure on the NLP card heat sinks could cause the heat sink to separate from the thermal links and fall off the printed circuit card. The plate is made of a conductive metal and could cause shorting of low level signals if it became wedged between cards in the card frame.
This signal shorting could cause damage to the Secondary Process Racks.
NTC The seismic induced chatter in the NTC cards could cause signal saturation in the downstream RTD Amplifier (NRA) card in the T Hot and T Cold circuits of the Westinghouse 7300 Process Protection System.
This signal -
saturation could result in a possible delay of the Overtemperature-Delta Temperature (OTAT) and Overpower-Delta Temperature (0 PAT) trips.
This condition had it gone uncorrected, could have affected the safe operation of the plant.
Six NTC cards are associated with the T Hot and T Cold circuits.
For the other seven NTC cards in the Westinghouse 7300 Process Protection System, six are located in channels associated with monitoring functions.
It should be noted that the erratic operation of the NTC cards is limited to the duration of the seismic event.
Therefore, there is no permanent error associated with the contact bounce and no impact on safety.
The remaining NTC card is a spare, located in Primary Process Rack RK*2PRI-PROC-1.
It has no impact on safety.
For the BOP safety-related NTC cards, worse-case analysis shows that a temperature transient would result from a temporary loss of temperature control in both the diesel generator building and the emergency switchgear room.
In either location, the maximum temperature would not exceed any equipment qualification limits, which are set at 120*F.
Additionally,
-since the NTC cards operate properly after the seismic event, operation of the post-accident indicators associated with the reactor containment sumps and the fuel pools, would not be a problem.
Therefore, any erratic oper-ation of the B0P safety-related NTC cards during a design basis seismic event will not adversely affect the safe operation of the plant.
Page 4 of 5
5.
Corrective Action to Resolve the Deficiency NLP Westinghouse issued Technical Bulletin NSD-TB-83-04 on June 15, 1983.
The existing heat sinks on the installed NLP cards were. replaced in accordance with this Technical Bulletin and N&D 4650 was closed on June 18, 1985.
Note that all defective NLP cards were installed in the Secondary Process Racks.
For the five spare NLP cards located in the warehouse, N&D 38712A has been dispositioned to return the defective cards to Westinghouse. for repair / replacement.
NTC The six NTC cards that are used in the T Hot and T Cold circuits were repaired in accordance with Westinghouse Field Change Notice DMWM-10638, dated August 6, 1985.
This repair consisted of the-addition of a
" daughter" board to the NTC card.
The " daughter" board has two additional reed relays wired in parallel to the mercury wetted relays.
Westinghouse confirmed -structural integrity of the modified cards by performing a structural and seismic analysis.
For the other six Westinghouse 7300 Primary Process System NTC cards,,N&D 45638 was dispositioned to accept-as-is.
The Technical Justification for this was based on the fact that these cards are in channels associated with monitoring functions and the contact bounce experienced in a seismic event will _ not effect the intended functional requirements.
The 14 B0P safety-related NTC cards were acceptable-as-is.
These NTC cards provide temperature control of the diesel generator building and emergency switchgear room, and also provide temperature monitoring of the reactor containment sumps and the fuel pool.
None of the intended safety-related functions provided by this equipment are impaired as a result of the erratic output of the NTC card during a seismic event.
For the three spare NTC cards, one NSSS and 2 B0P, a warning has been attached to preclude use in the Narrow Range Temperature Channel.
This precaution will prevent these NTC cards from being installed in a circuit where contact bounce of the mercury switch could impede a safety-related function.
In ' addition, the cards have specific part numbers such that in addition to the warning, following of the part number procurement and installation procedures will preclude erroneous installation of cards.
6.
Additional Report No Additional Reports are expected.
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