ML20247H522
| ML20247H522 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/19/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905310256 | |
| Download: ML20247H522 (4) | |
Text
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p; e
aver Valley Power Stathn Shinpingport, PA 16040()04.
4
?33,S$ln$'"mucw con i4e ms2ss May 19, 3989 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 50-334/89-04 and 50-412/89-04 i
Gentlemen:
In response to NRC correspondence dated April 19, 1989 and in accordance with.10 CFR 2.201, the attached reply addresses the Notice of' Violation included with the referenced inspection report.
The letter also noted several personnel errors and other deficiencies which contributed to. the event.
As requested, our reply also addresses these concerns.
If there are any questions concerning this response, please contact my office.
Very truly yours, b c. 0 3 J.
D. Sieber Vice President Nuclear 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) 8903310256 890519 I
TEOI PDR ADOCK 05000334 %
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PNV E
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DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station, Unit No. 2 Reolv to Notice of Violation Combined Inspection Report 50-334/89-04 and 50-412/89-04 Letter dated April 19, 1989 VIQLATION (Severity Level IV; Supplement I)
Description of "<iolation (50-412/89-04-02) j 10 CFR Part 50, Appendix B, Criterion V (" Instructions, Procedures and Drawings")
requires that activities affecting quality shall be prescibed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Contrary to the
- above, on March 22, 1989, an inadvertent safety injection occurred due to several procedural inadequacies in that procedures were not appropriate for the circumstances since they did not prevent or adequately address the following:
1.
Maintenance Surveillance Test Procedures did not prevent taking a second pressurizer pressure channel out of service before the first channel was restored to normal, resulting in the safety injection signal.
2.
Activities associated with taking a pressurizer pressure channel out of service for a
24-hour period were not specified by the associated maintenance surveillance procedures.
3.
Operations Surveillance Test No.
2.11.15,
" Safety Injection Accumulator Check Valve Test,"
did not prevent nor address enab.'.ing of all three accumulator stop valves at the same time.
Such a
configuration could have resulted in overfilling the pressurizer and spilling the potentially contaminated water into containment during the March 22, 1989 safety injection.
Correction Action Taken Operators verified that no conditions existed which required a Safety Injection and used the Station's Emergency Response procedures for guidance to recover the plant.
Action Taken to Prevent Recurrence The following actions were taken with regard to this incident.
The Shift Technical Advisory (STA) group evaluated this event using the Human Performance Evaluation System (HPES) and a separate Root Cause Analysis was conducted by the Independent Safety Evaluation Group (ISEG).
- Boavor Valloy Power Station, Unit No. 2
' Reply to Notice of Violation Combined Inspection Report 50-334/89-04 and 50-412/89-04 q
Page 2 For the remainder of the current Refueling Outage and for future
- outages, calibration procedures are to be pre-reviewed and scheduled by I&C and an SRO before being submitted to the NSS for final approval.
This pre-review will determine whether the procedure can be properly performed in a
given plant condition and identify any specia) precautions that may be necessary.
This will provide an additional barrier against conflicting plant configuration.
In order to reduce the probability of inadvertent ESF Actuations, the i
operating Manual has been revised to remove the Solid State j
Pr %,ection System (SSPS) from service whenever it is not required to support testing or maintenance in Modes 5 or 6, The SSPS will be maintained in a
bypassed condition until required for entry into l
Mode 4.
The following actions have been taken to address the deficient activities noted in the violation:
I Items 1
and 2:
I&C has revised its Pressurizer Pressure Loop l
Protection Channel Tests and Calibrations to check the status of the P-11 permissives of the other channels before testing a loop.
They also have been revised to explicitly require a waiting period to perform the stabilization of these pressure transmitters.
I&C will perform a
review by July 31, 1989 to determine if any other procedures may present a similar problem.
Any procedure revisions resulting from this review will be scheduled thereaftar.
Item 3:
The referenced operating procedure (OST 2.11.15) has been revised to enable each accumulator isolation one at a time.
Date of Full Comoliance The Station is in compliance at this time.
A review by I&C to determine if any other procedures may present a similar problem will be performed by July 31, 1989.
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. * ' '.Esaver' Valley Power Station, Unit No. 2 l
Reply to Notice of Violation Combined Inspection Report 50-334/89-04 and 50-412/89-04 Page 3'*
Evaluation of Ad3itional Concerns In addition to the deficient activities identified in the Notice of l
Violation, the following addresses-the personnel errors and activity control deficiencies which may have contributed to the March 22, 1989 inadvertent safety injection.
As a
result of our investigation into the circumstances surrounding this event, several improvement areas have been identified:
1.
Increased personnel communication 2.
Improved work schedules 3.
Improved procedures and shorter implementation of plant modifications.
Duquesne Light Company (DLC) has taken the following steps to address these areas.
1.
Line management communication with the employees has been enhanced.
Operations Supervisor Discussions, Shift Briefings and Maintenance Safety Meetings provide a forum to communicate specific concerns with employees.
2.
Improving Operation's shift work schedules has been addressed.
Union and management personnel were sent to the circadian schedule seminars.
A committee was formed from a
cross section of Operations personnel to determine how work schedules could be improved.
A revised work schedule was developed and will be implemented at the end of BV-2 first refueling.
The new schedule provides improved means of personnel shift schedule management for human performance improvements.
3.
As a
result of our
- review, several improvements have been suggested.
One of the suggested actions.taken included the development of a procedure writer's guide reflecting enhanced human factors in procedures.
It will provide guidance for both writers and reviews and will be included in the Site Administrative procedures.
In addition. to the actions taken to improve human performance, procedures and control of activities, DLC has initiated a Pilot Proiect for a
Systematic Anoroach for Problem Solvina and Decision Makina in Incident Assessments.
Phase I
of the pilot project identified the objectives and indicators of improvement.
Specifically DLC expects to refine incident root cause analysis, improve initial event analysis, improve tracking and close out of corrective actions.
This will be done by improved initial incident evaluation achieved through a revised program and evaluation techniques.
DLC shares the NRC's concerns over personnel errors and procedural and activity control deficiencies.
We will continue to pursue improvement in these and other areas which lead to a reduction in the number of incidents by any cause.
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