ML20247H860
| ML20247H860 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/11/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909200123 | |
| Download: ML20247H860 (5) | |
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Sept. 11, 1989 U. S. Nuclear Regulatory Commission Attn:
Document Control Deck Washington, DC 20555
Reference:
Beaver Valley Power Station,. Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 EV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/89-12 and 50-412/89-13 Gentlemen:
In. response to NRC correspondence dated August 11, 1989 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation included with the referenced inspection report.
Our. reply to Violation B indicates corrective actions taken for Unit
~No.
1.-
We have also reviewed this concern for impact on Unit
.No.
2 activities.
Duquesne Light has budgeted considerable capital and ' manpower for 1990 to implement a Site Procedure Upgrade Program.
~ Unit' 2'
procedures will be revised to address this concern as a part L
of.this program.
If there are any questions concerning this response, please contact my office.
Very truly yours, I
D
.)
J.
D. Sieber Vice President Nuclear Group Attachment cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr. Edward C.
Wenzinger, Chief Reactor Projects Branch No.
4, Division of Reactor Projects, Region I Director, Safety Evaluation & Control (VEPCO)
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.DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Units 1 & 2 L
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i9 Reply to Notice of Violation f
Combined Inspection Report 50-334/89-12 and 50-412/89-13 Letter Dated August 11, 1989 J
VIOLATION A (Severity Level IV, Supplement I)
Description of Violation (50-334/89-12-01) 10' 'CFR Part 50,. Appendix B,
. Criterion XVI requires that measures shall be established to assure that for ' conditions adverse to 11
- quality, the cause of the condition is determined and corrective action is taken to preclude repetition.
' Contrary to the above,.the licensee's corrective actions in response to. findings identified by NRC in Inspection Report 88-22, Detail 10,
'regarding inadequate separation of safety related electrical cable were not adequate.. Several similar discrepancies were identified by NRC on. July 7, 1989.
Adequate cable separation still does not exist l
in the Unit 1 Cable Mezzanine.
Discussion of Violation As a
result of the instances of inadequate separation of safety related cables identified by the NRC in-Inspection Report 50-334/88-22, Duquesne Light conducted inspections of all accessible BV-1. areas for cable separation deficiencies.
These inspections were broad in scope and were conducted on an area basis.
Following the recently identified discrepancies, we conducted a root
-ause. analysis of the cable separation problem.
This review of our
-inspection plan indicated that the inspection by area rather than by conponent' was not adequate to identify all potential deficiencies.
.In order to correct
- this, a
more systelnatic inspection plan to resolving this problem was recommended.
Corrective Action Taken A
comprehensive plan was developed and implemented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
-the.NRC identification of the discrepancies.
This plan provides for a
systematic approach for inspecting Category 1E cables and raceways in Unit 1
to assure that installations will meet the original installation criteria. and that identified deficiencies will be appropriately resolved.
The four color separation concerns identified by' the NRC on July 7, 1989 were resolved.
At present, walkdown teams continue to perform color separation inspections while a
-resolution team is concurrently determining the appropriate corrective action to be taken for each deficiency.
4
_Reolv to Notice of Violation Combined Inspection Report 50-334/89-12 and 50-412/89-13 Page 2 Violation A, (Continued)
Action Taken to Prevent Recurrence The cable color separation deficiencies identified as the result of the new inspection program are associated with cables which appear to have been installed during the construction phase of Unit 1 or during early design change installations.
The present day practice of 100%
Quality Control (QC) inspection for Category 1E cables provides assurance that all new 1E installations will meet the installation criteria.
In
- addition, we will incorporate into our process installation standards the requirement for all future non-1E cable installations to be inspected by QC to confirm installation separation criteria are met.
Date of Full Comoliance Walkdowns and evaluations are still continuing, therefore, we have not determined a completion schedule at this time for inspections and corrective actions in all areas.
Since Unit 1 is currently shut down for refueling, we will complete the inspections and correction of any deficiencies within the Unit 1 containment prior to startup.
The process installation standard for. inspection of non-1E cable installations vill be revised by October 2, 1989.
We will provide a status and schedule for completion of the remaining ccrrective actions by October 18, 1989.
VIOLATION B (Severity Level IV, Supplement I)
Description of violation (50-412/89-13-01)
Technical Specification 6.8 requires that written procedures be established, implemented and maintained covering activities listed in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
Maintenance Surveillance Procedure 2MSP-26.01-I 2 MSS-P446 First Stage Pressure Protection Channel III Test,Section I,
Initial Conditions, specifies that the above test should not be performed if the at-power, low pressurizer pressure reactor trip is actuated.
Contrary to the
- above, on May 27,
- 1989, the licensee performed 2MSP-26.01-I with the at power low pressurizer pressure reactor trip actuated.
This resulted in a reactor trip.
Corrective Action Taken Following the May 27, 1989 reactor trip, Incident Critiques, ISEG Root Cause Analysis and Human Performance Evaluation System meetings were conducted with the personnel involved.
Reply to Notice of Violation Combined Inspection Report 50-334/89-12 and 50-412/89-13 Page 3 Violation B (Continued)
Based on information gathered at those meetings, it was determined the May 27, 1989 Unit 2 trip was caused by:
A.
Personnel error on behalf of the Shift Supervisor and Instrument and Control (I&C) Foreman B.
Ineffective communications C.
Possible inadequate alertness due to working long periods of night shift by the I&C Foreman.
D.
Ineffective procedural warnings Initial Corrective Actions Taken:
A.1 A critique was conducted with the I&C Personnel.
A.2 The Operations and I&C personnel participated in a Root Cause Analysis with the Independent Safety Evaluation Group.
A.3 The Operations and I&C personnel involved were interviewed utilizing the Human Performance Evaluation System.
Action Taken to Prevent Recurrence A.4 The procedure adherence policy was reinforced with all personnel involved.
Emphasis was placed on stopping work if the procedure states
- such, or if the procedure is not explicit or completely understood.
(This was accomplished during interviews identified in Action B-1)
A.5 The
- Event, its cause and corrective actions, will be reviewed during Operator License Retraining with special emphasis on procedure compliance (November and December of 1989).
A.6 Training on procedure initial conditions and revisions will be incorporated into I&C Continuing Training scheduled to begin December 1989.
A.7 Reactor protection permissives, interlocks and their system interactions will be covered in I&C training classes.
Reactor Protection Trip Logic Training will be conducted in September 1989 with Foremen and Supervisors.
In addition, Protection and Control System Overview Training will be conducted with Technicians and Foremen starting in December 1989.
-_- _ _O
t
~
to Notice of Violation Penly Combined Inspection Report 50-334/89-12 and 50-412/89-13 Page 4 B.1 The I&C Procedure Supervisors are conducting interviews with all L
technicians and their supervisors to enhance procedure writing l
through direct feedback.
B.2 All 1&C surveillance procedures affecting the reactor protection system will be revised prior to use to require joint review by I&C and operations prior to performance for specific status l
light deviations.
C.1 Foremen work schedules have been developed for the current refueling outage to comply with overtime limits and will be established for future outages.
l C.2 Nuclear Group working hour limitations have been
- assessed, I
clarified and emphasized through management meetings with the Vice President, Nuclear Group.
D.1 The Initial Condition sections of Unit 1 Reactor Protection procedures, that could affect Protection
- Systems, are being revised to clearly specify the mode dependency of the procedure.
Revisions will be complete prior to procedure use.
Date of Full Comoliance The actions identified above will be completed by December 29, 1989.
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