ML20235C515

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Responds to NRC Re Violations Noted in Insp Rept 50-334/87-06.Corrective Actions:Discussions Held W/All Operations Personnel Re Proper Procedures for Determining & Performing post-maint Tests on motor-operated Ball Valves
ML20235C515
Person / Time
Site: Beaver Valley
Issue date: 06/26/1987
From: Sieber J
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707090446
Download: ML20235C515 (4)


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"3hrtt Telephone (412) 393-6000 Nuclear Group P.O. Uox 4 June 26, 1987 snippinoport. eA sso7 moo 4 U. 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 87-06 Gentlement In response to NRC correspondence dated May 28, 1987 and in acccrdance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced report.

If. there are any questions concerning this response, please contact my office.

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Very truly yours, nk J. D. Sieber Vice President, Nuclear cc: Mr. F.

I. Young, Sr. Resident Inspector U. S. Nuclear. Regulatory Commission Beaver Valley Power Station Shippingport, PA 13077 U. S. Nuclear Regulatory Commission Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Edward C. Wenzinger, Chief s

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U. S. Nuclear Regulatory Commission l

Project Branch No. 3 Region 1 631 Park Avenue King of Prussia, PA 19406 Director, Safety Evaluation & Control 1

Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261

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i DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit Nc. 1 Reply to Notice of Violation Inspection 87-06 Letter dated M&y 28, 1987 l

VIOLATION I (Severity Level IV; Supplement I)

Description of Violation (87-06-01)

Technical Specification 6.8.1 and Appendix A of Regulatory Guide 1.33

1972, require the establishment and implementation of procedures for performing maintenance.

SAP 3D, Maintenance Wcrk

Request, Appendix B,

Post Maintenance Performance Test Guidelin6s, requires that valves be tested as necessary after undergoing repair to verity performance parameters.

Contrary to the

above, after repair of liquid waste two inch ball valve MOV-LW-ll2A on March 27, 1987, post-maintenance testing did not verify performance parameters in that the actuator was misaligned.

This resulted in the wrong valve position indication in the control room, and led to a minor unauthorized liquid wastr release.

Corrective Action Taken During the discharge of LW-TK-7B, an operator noticed that LW-TK-7A level was also falling.

Investigation found that the release path i

from the 7A tank was through the pump discharge valve MOV-LW-ll2A and into the liquid waste discharge header that had been aligned to receive the 7B tank flow.

The MOV and the liquid waste discharge header were immediately isolated.

This action terminated the discharge.

Calculations were then performed based on LW-TK-7A and 75 sample data (i.e.,

initial and final tank volumes, total time of discharge, etc.)

that verified the technical specification limit of 1.0 Maximum Permissible Concentration Factor was not exceeded.

A nen Radioactive Waste Discharge Authorization permit was then issued to document the release of the combined centents of LW-TK-7A and 7B.

Action Taken to Prevent Recurrence 1.

The Operations Supervisor (NSOS) held discussions with all Operations personnel concerning this incident.

The topics discussed were:

a.

A chronological sequence of events for this incident.

b.

Proper procedures for determining and performing post-maintenance tests on motor operated ball valves.

A Reply to Notice of Violation Inspection 87-06 (Continued)

Page 2 2.

The NSOS has scheduled a

discussion session with each Nuclear Shift Supervisor (NSS) and, in turn, each Nuclear Shift Operating Foreman (NSOF) to determine their understanding of SAP 3D, Post Maintenance Performance Test Guidelines (Appendix B) and obtain their recommended changes to preclude an event of this nature in l

the future.

3.

The Training Department will modify the existing training / retraining programs regarding post-maintenance testing from a strictly theoretical nature (instructor reviewing the SAP) to one of a more practical and demonstrative nature (example of maintenance performed / determining post-maintenance testing).

Date on which Full Compliance Will be Achieved item 1 has been completed.

Item 2 will be ecmpleted by August 15, 1987.

Item 3

will be incorporated into Module 2 of the 1987-1988 Licensed Retraining (LRT) cycle which is expected to be completed by December 15, 1987.

VIOLATION _II (Severity Level IV; Supplement I)

Description of Violation (87-06-03)

Technical Specification G.8.1 and Appendix A cf Regulatory Guide 1.33

1972, require the establishment and implementation of equipment control procedures.

OM Chapter 1.48.6B, Mechanical and Electrical Clearance Procedures, provides detailed instructions controlling plant configuration by preparation and review of equipment clearances and switching

orders, to ensure that specified equipment can be removed from service.

Contrary to the

above, Equipment Clearance 524812 and its related switching order for repair of fire hose station 58 were improperly prepared and reviewed on March 19, 1987, in that it resulted in the unintentional isolation of the motor driven fire pump.

The resultant failure of the diesel driven fire pump rendered the entire fire suppression system required by Technical Specification 3.7.14.1 inoperable for about one hour.

Corrective Action Taken An operator walkdown for proper valve alignment was perforned that identified several valves out of position that isolated FP-P-1.

These valves were immediately returned to normal alignment, thereby restoring system operability.

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Reply to Notice of Violation Inspection 87-06 (Continued)

Page 3 Agtion Taken to Prevent Recurrence 1.

The operations Supervisor held discussions with all operations personnel concerning this incident, the topics discussed were:

a.

A chronological sequence of events for this incident.

b.

Proper configuration control per requirements of Site Administrative Procedure 41 VI.C.,

" Mechanical and Electrical Clearance Procedures",

and proper methods for preparing the Valving / Switching Procedure form.

c.

Good operating practices and the use of proper valve status boards to identify correct system alignments for placement of clearances.

2.

Individuals directly involved in the evolution were personally contacted and counselled concerning their involvement with the

incident, specifically, their failure to adequately control the evolution.

Date on Which Full,Gpmpliance Will be Achieved Concerning Items i and 2 above, full compliance has been achieved at this time.

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