ML19282A830

Responds to NRC 790110 Ltr Re Violations Noted in IE Insp Rept 50-334/78-34.Corrective Actions:Immediate Confirmation That Relays for Both Diesel Generator Field Flash Circuits Were Properly Positioned

ML19282A830
Person / Time
Site:	Beaver Valley
Issue date:	01/30/1979
From:	Dunn C DUQUESNE LIGHT CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19282A828	List: ML19282A830
References
NUDOCS 7903070145
Download: ML19282A830 (3)

Text

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'Af (412) 471 4300 435 Sixth Avenue Pmsburgh, Pennsylvania 15219 January 30, 1979 United States Nuclear Regulatory Commission Attention: Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 78-34

Dear Mr. Brunner:

In response to your letter of January 10, 19/9 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violation was the failure to incorporate and implement a procedure revision.

If you have any questions concerning this response, please contact my office.

Very truly yours,

,i . . . -

C. N. Dunn Vice President, Operations Attachment 7903070l'I.T

DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 78-34 Letter Dated January 10, 1979 Description Of Infraction (78-34-01)

Technical Specification 6.8.1 requires, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972...."

Appendix A of Regulatory Guide 1.33 recommends that procedures for

".. 4. Procedure Adherence and Temporary Change Method..." be established.

The Beaver Valley Power Station Operating Manual, (BVPS OM), Chapter 48, Section 1.48.E, " Review, Revision and Approval of Procedures", provides for revising Operating Procedures by way of an Operating Manual Change Notice (OMCN) which is to be inserted in the appropriate chapter of the controlled Operating Manuals in the control room.

The BVPS OM, Chapter 48, Section 1.48.G, " Adherence to Operating Procedures",

states, in part, " Operating procedures are written to cover a reasonable number of normal, abnormal, emergency, and casualty operations..." and "....The potential consequences of incorrect action, and the inherent complexity of the plant make it imperative that written, carefully reviewed, and approved procedures are used for operation of the plant, except where emergencies or casualties require immediate action...."

Operating Surveillance Test OST 1.36.2, Diesel Generation No. 2 Monthly Test, Revision 10, was revised on October 30, 1978 by Operating Manual Change Notice (OMCN) No.78-206. This OMCN required, in part, that the Field Flash Cutout Relay Temporary Monitoring Circuit be observed for proper relay contact position to ensure reliable generator field flash capability for automatic diesel generator starts.

Contrary to the above, OST 1.36.2, Revision 10, was performed on December 1 and December 4, 1978, without having OMCN 78-206 properly incorporated in the procedure copies used to perform the test and without having documented the performance of the actions required by the OMCN.

Reply to Notice of Violation Inspection Ks. 78-34 Letter Dated January 10, 1979 Page Discussion of Infraction OMCN 78-206 had been issued with the controlled copies of the procedure.

Procedure copies used for performance and documentation of the test on the dates noted, however, apparently did not have OMCN 78-206 incorporated.

Corrective Action As noted in the inspection report, upon notification of this finding, it was immediately confirmed that the rela /s for both Diesel Generator Field Flash circuits were in proper position to support an automatic start.

Action Taken to Prevent Recurrence The operators will no longer keep spare copies of the OSTs. When an OST is to be performed, the operators will make any needed working copies from a controlled copy of the Operating Manual which contains all procedure changes incorporated via OMCNs. All spare copies of OSTs have been removed from the Control Room files.

Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.