ML20236B272
| ML20236B272 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/17/1987 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707290028 | |
| Download: ML20236B272 (6) | |
Text
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"?>vp3C DuquesneIJ@t Telephone (412) 303 6000 j
Nudear G oup P,0. Box 4 Shippingport PA 15077-0004 July.17, 1987 1
l U. S. Nuclear Regulatory Commission 1
Attn:
Document. Control Desk Washington, DC 20555 i
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 l
Inspection Report 87-07 1
I Gentlemen:
In response to NRC correspondence dated June 17, 1987 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced report.
Your letter also requested that we address the. concern regarding the number of apparently unrelated events involving errors by
. personnel during the past five months.
Therefore, included in our reply is our assessment of the cause of these events and actions being taken to address this concern.
If there are any questions concerning this response, please contact my office.
Very truly yours, d
J. D. Sieber Vice President, Nuclear 1
1 8707290028hh{0334 PDR ADDCK PDR a
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B3 aver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 87-07 Page 2 cc:
Mr. F.
I. Young, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U.
S. Nuclear Regulatory Commission Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Peter S. Tam U.
S. Nuclear Regulatory Commission Project Directorate No. 2 Division of PWR Licensing - A Washington, DC 20555
- Mail Stop 316 Addressee only Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 E
g DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 q
Reply to Notice of Violation Inspection 87-07 Letter dated June 17, 1987 VIOLATION I (Severity Level IV; Supplement I)
Description of Violation (87-07-01)
Technical Specification 0.8.1 and Appendix A
of Regulatory Guide 1.33-1972, require the establishment and implementation of procedures for Collection, Storage, and Discharge of the Gas Systems.
Operating Procedure 1.19.4.B (System Running Procedure) requires that the associated sample return valve be shut when isolating a filled decay tank.
Contrary to the above, on May 14, 1987, the
'C' sample return valve was not shut when isolating the filled
'C' decay tank, resulting in a subsequent minor unplanned gaseous release.
Corrective Action Taken The discharge of GW-TK-1C was immediately terminated upon the operator's observation of the GW-TK-1C pressure change.
GW-TK-1C tank contents were sampled and revealed a slight (insignificant) increase in isotopic activity.
No Technical Specification limits were exceeded.
Action Taken to Prevent Recurrence The unplanned release of gas from the
'C' gas decay tank has been attributed to operator failure to close the sample return valve I
following completion of sampling.
In
- addition, the operator initiating the discharge on a subsequent shift did not observe the unsatisfactory alignment and the discharge procedure did not address l
checking the subject valve prior to discharge.
The following actions have been taken to prevent recurrence:
1.
A special operating order was issued on July 6, 1987, to require Senior Reactor Operator review of procedural steps performed, alignments performed, rad monitor checks performed, and notifications performed prior to initiation of discharge.
This order took effect at the time issued, and will remain in effect I
until permanent procedure changes are made.
2.
Shift briefings will be held with each operating crew to discuss operator responsibilities during discharges, procedure l
compliance, and the significance of this violation.
3.
Procedure changes were immediately initiated to provide:
a.
More detailed instruction during the pre-discharge sampling evolution as well as the sampling evolution which is l
required for tritium analysis during discharge.
Reply to Notice of Violation I'nspection 87-07 (Continued)
Page 2 Action Taken to Prevent Recurrence (Continued) b.
Specific steps for sampling valve alignments prior to and J
following the sampling evolutions.
c.
Initial condition requirements to have technicians verify 1
proper rad monitor operation and setpoint verification prior l
to initiation of discharge.
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l d.
Instruction so as to make the gaseous waste discharge g
procedure more informative and usable to the operator.
This includes steps to more closely coordinate the discharge process among the three plant groups involved (Operations, i
Radcon, Chemistry).
j Date on Which Full Compliance will be Achieved Item 1 has been completed.
Item 2 will be completed by September 15, 1987.
Item 3 will be completed by October 31, 1987.
VIOLATION II (Severity Level IV; Supplement I)
Description of Violation (87-07-04) i Title 10 CFR Part 50.72, requires, in part, any event or condition that results in manual-or automatic actuation of any Engineered j
Safety Features (ESF), shall be reported to the NRC within four hours 1
of the occurrence.
Contrary to the
- above, on May 1, 1987, an a'itomatic EL7 actuation occurred involving flow diversion of the Auxiliary Building exhaust air through filter banks and an elevated
- release, and was not reported to the NRC within the prescribed time.
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Corrective Action Taken On May 1, 1987, with the plant in Mode 5, the control room received a high-high alarm on the Auxiliary Building
'B' Ventilation Exhaust Radiation Monitor
( RM-VS -10 2B ).
The high-high setpoint initiated an automatic flow diversion of Auxiliary Building exhaust air through the main filter banks and then through the elevated release on top of the containment building.
The high-high alarm was initiated due to a volume control tank sampling evolution.
During the sampling evolution, leakage past another sample system valve to the sample sink caused the flow diversion.
The Radiological Control Department subsequently initiated an abnormal release record which determined that the resulting release was well within Technical Specification limits.
Reply to Notice of Violation Inspection 87-07 (Continued)
Page 3 Corrective Action Taken (Continued)
This event was voluntarily reported in accordance with 10 CFR 50.72.b.2.ii at 1750 hours0.0203 days <br />0.486 hours <br />0.00289 weeks <br />6.65875e-4 months <br /> on 5/12/87.
Initial notification on 5/1/87 was not deemed necessary because this was a planned chemistry sampling activity, and based on the high activity levels, a radiation monitor alarm actuation was very probable.
10 CFR 50.72.b.2.ii states that ESF actuations that result from a preplanned sequence during testing or reactor operation need not be reported.
Inquiries by the Resident Inspector prompted an additional investigation at which time the station determined this event would be reported for I
informational purposes only.
The appropriate notification was then I
made.
Separate correspondence has been provided to the Beaver Valley 1
Resident Inspector identifying the plant's concern that the reporting j
requirements, as they have been recently interpreted by NRC
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personnel, are overly conservative.
The specific radiation monitor j
that was actuated is not an ESF required component and re-positioning I
of the filter bank dampers, in this instance, is a result of a design i
function that is not defined as an ESF feature.
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Action Taken to Prevent Recurrence l
1.
Initial actions taken were to notify shift supervision via the night orders to report future actuations of these dampers under 10 CFR 50.72 requirements for non-emergency notification, until the matter of notification requirements has been resolved.
2.
Guidelines will be established, delineating occurrences that are to be considered inadvertent actuations of ESF equipment.
Included in these guidelines will be a listing specifying those components which are to be considered ESF equipment, such that the unplanned or inadvertent operation of these components will be considered a
reportable occurrence under 10 CFR 50.72 requirements.
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3.
The Chemistry personnel that perform these evolutions have been instructed on the effects that various sampling configurations have on the ventilation
- system, and why releases / rad monitor actuations must be avoided.
Date on Which Full Compliance will be Achieved Item 1,
conservative reporting practices, will continue until the permanent corrective action is completed.
Item 2 will be completed by August 31, 1987.
Item 3 is complete.
Reply to Notice of Violation Inspection 87-07 (Continued)
Page 4 Additional Discussion Inspection Resort 87-07 (cover
- page, paragraph 3) requested an assessment of the cause of recent events and identification of corrective actions.
1 Plant management has also been sensitive to the apparent increase in 1
the number of events that have occurred since January 1987.
The i
possibility of such a
trend developing was initially identified to 1
the shift Operations personnel in Retraining Module 5 during the l
" Operations Supervisor Discussion Period."
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l The fact that the Inspection Report noted that the events were
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apparently unrelated supports the Operations Department observation l
that the events are indeed quite diversified and may not lead to a f
discreet single cause determination.
j The missed surveillance was procedure related, the gas release was procedure performance
- related, the liquid release and one auxiliary feedwater pump start were technical knowledge related, and the ESF l
damper actuations were related to technician experience coupled with J
inconsistent reporting criteria interpretations.
In addition, the I
second auxiliary feedwater pump start was caused by a simple human l
coordination reaction and, as such, is an isolated case that does not j
constitute a trend.
In an attempt to better define and eliminate the potential for a
" trend",
the Plant Manager has established a working group consisting j
of the Plant
- Manager, Assistant Plant
- Manager, Unit Operations Supervisor, and Maintenance Director to review recent events in greater detail and attempt to extract common components.
The results of this working group will be utilized to formulate long term corrective actions.
l The Onsite Safety Committee has also been instructed by the Senior Manager of the Nuclear Operations Unit to independently review the events and provide a
cause determination, including recommended l
corrective action where advisable.
The above actions that are currently in progress are expected to provide an aggressive program that we believe will reverse the
" apparent" trend identified.
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