View source for 05000334/LER-1988-013, Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued

{{Adams
| number = ML20154H712
| issue date = 09/12/1988
| title = Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued
| author name = Sieber J
| author affiliation = DUQUESNE LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000334, 05000412
| license number = 
| contact person = 
| document report number = NUDOCS 8809220099
| title reference date = 08-12-1988
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}
{{LER
| Title = Responds to NRC Re Violations Noted in Insp Repts 50-334/88-22 & 50-412/88-16.Corrective Actions:Replacement of Tray & Conduit Covers,Establishment of Action Plan to Correct Any Similar Situations & LER 88-013 Issued
| Plant = 
| Reporting criterion = 
| Power level = 
| Mode = 
| Docket = 05000334
| LER year = 2088
| LER number = 13
| LER revision = 
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

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I Td E m                                                                                                                                                                                            e m m.               )
September 12, 1988 l
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 Doch*at No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/88-22 and 50-412/88-16 Gentlemen:
In response to NRC correspondence dated August 12, 1988 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice                                                                                                                                                          !
of Violation included with the referenced inspection report.                                                                                                                                                                   ,
Your letter also asked that we describe our evaluation, including                                                                                                                                                    .
root causes and final corrective actions of a licensee identified                                                                                                                                                              ,
violation                     involving                                          the                                                                     failure   to   verify diesel      generator                           '
operability. This item is also addressed in our reply.                                                                                                                                                                         !
If        there are             any                                               questions                                                          concerning    this   response, please                          ('
contact my office.
Very truly yours,                              [
W l//f'b  b Group Vice President                                  i Nuclear                                           i Attachment                                                                                                                                                                                                                    f cci           Mr. J. Boall, Sr. Resident Inspector                                                                                                                                                                            !
Mr. W. T. Russell, NRC Region I Administrator                                                                                                                                                                    !
Mr. J. T. Wiggins, Chief Reactor ProjectJ Branch No. 3,                                                                                                                                                          (
Division of Reactor Projects, Region I                                                                                                                                                                      j Director, Safety Evaluation & Control (VEPCO)                                                                                                                                                                    ,
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         ',                                DUQUESNE LIGHT COMPANY Nuclcor Group BanvOr Volloy Powar Station, Unito No. 1 cnd No. 2 i
REPLY TO NOTICE OF VIOLATION Combined Inspection No. 50-334/88-22 and'50-412/88-16 Letter dated August 12, 1988 VIOLATION (Soverity Lovel IV, Supplement I)
Description of Violation (50-334/88-22-03; 50-412/88-16-02)
Titic 10 CFR Part 50, Appendix B, requires that activitics affecting quality shall be prescribed 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.
specification document BVS-3001 and Unit 2 specification Unit    1
:           document     2BV-931 impicment the applicable cable installation and separation requirements.
The     following     examples       of    inadequate                                                                cabic                                       separation  were identified:
A. Unit 1
: 1. BVS-3001, Section 1 (General), requires that where exposed cables of redundant circuits leave trays to enter s1 coves, they shall be grouped by each color and each group shall have at least six inches minimum betwcon outer periphery of the group of exposed cables.
Contrary    to    the    above,   the outer periphery of the cabic group   in   tray     1TC545 was not separated by at least six inches   minimum      from the outer periphery of the redundant cable group in     tray 1TC306B where the exposed cables entered cabic sleeves.
: 2. BVS-3001, Section 1 (General), requires that all horizontal cable trays shall have solid covers.
I                      contrary to the above,            in      several locations, horizontal cable tray covers were not maintained or were missing such that the required separation was not maintained.
B. Unit 2 2BV-931,    Appendix     M   (Electrical Color Separation of Cables and Raceways)    requires      that the minimum separation distance betwoon redundant      Class        1E     cables / raceways                                                                                        and               non-Class   lE cabics/ raceways     in    the   Cable Spreading Arcas                                                                                                       be  three  feet vertically.

        . Reply to Notice of Violation Combin';d In:pecticn No. 50-334/88-22 cnd 50-412/88-16 Lottor dotcd Auguct 12, 1988 Page 2 Description of Violation (cont.)
Contrary to the above, redundant Class 1E cables in conduit lino 2CC94000M and tray 2TC403P did not meet the three foot niinimum separation distance from non-Class lE cable 2NNSANC457.
Corrective Action Taken Walkdowns   woro conducted by Engincoring and Construction personnel of those areas identified by the Inspector as having examples of inadequate cable separation. As a result of those walkdowns, various tray covers and conduit fitting covers were observed to have bocn removed,   thereby reducing the cable separation criteria to below minimums as established within the BVS-3000 and 2BV-931 installation specifications. These covers were immediately replaced to rostore an acceptabic separation.
An action plan was established to walkdown all raceways in accessibic safety related areas in both Unit 1 and Unit 2 to identify and correct any similar situations. Presently, this action plan is still in progress due to the magnitude of effort involved.
l Action Taken To Prevent Recurrence As an interim measure, the Construction Department has revised their procedure NCAP 5.6 "Identification of Temporary Installation and Temporary    Removals"    to   specifically    address the removal and reinstallation of tray covers for modification work.
j         Engineering will establish a practice to use fire blankets, which will permit tray covers to remain off during cable installation, and still maintain the separation criteria during unattended periods of l         work on cable trays.
Date of Full Compliance r         The expected completion date for the action plan described above is December 16, 1988. Following internal review of the results of these walkdowns, a supplemental report will be issued to address the actions to prevent recurrence.
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                                       , ,7 , Reply to Notice of Violation Combin d Inspection No. 50-334/88-22 cnd 50-412/88-16 Lottor dotcd August 12, 1988 Page 3 Licensco Identified Violation                                                                                                                Involving  Failure    to  Verify Diosal Generator Operability At  1156 hours on 7/7/88, with Unit 1 at 100% reactor power, Emergency
<                                                                          Dioscl Generator Number 1 (EE-DG-1) was removed from service for air lino cleaning.                In accordance with ACTION Statomont A of Technical Specification (TS) 3.8.1.1, the operability of the other emergency AC power supplica snould be verified within one hour by starting EE-DG-2 from ambient and performing an offsite to onsite breaker alignment check. However, these actions woro not performed within the required time frame,   as was discovered at 1438 hours after questioning by the relieving shifts foreman. Upon recognition of the omission, EE-DG-2
,                                                                          was immediately started while the breaker verification was performed
  !                                                                        by 1450 hours 7/7/88. No safety implications resulted from the evant 4
since the redundant emergency AC power sources were always physically available to supply any required loads. This event was caused by a
:                                                                          cognitivo error on the part of Senior Reactor Operators, who did not
 !                                                                         properly   recall or verify all required Technical Specification
 ;                                                                         actions associated with removing an Emergency Diesel Generator from service.
Corrective Actions i
i                                                                           -
LER 88-013 was issued.
l Disciplinary action was taken for                                                                                                                  those licensed Control Room personnel involved in this event.
                                                                            -  This event will be reviewed by all licensed operating personnel.
l                                                                           -
The Emergency Safety Features (ESF) Checklist will be revised to explicitly mention that,                                                                                                           if       an Emergency Dioscl Generator is
 ;                                                                             removed form service, the redundant train dicsci is started and l                                                                             the appropriate offsite-to-onsite breaker alignment verification (cither OST 1.36.7 or                                                                                       1.36.8) is performed within the diesel generator one-hour timo limit of TS 3.8.1.1.a.
Tts  procedure for removing a Diesel Generator from service has boon  revised in order to require verification of the other DG's operability as an initial condit.on.                                                                                                        4 The  ESF  Checklist will be revised to require a verification of the   actions              necessary                                                                                               for        compliance    to    the Technical Specifications.              This will provido a more positive assurance that supervision is not making errant assumptions regarding compliance to the Technical Specifications.
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