IR 05000334/1997011
| ML20249C486 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/18/1998 |
| From: | Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| 50-334-97-11, 50-412-97-11, NUDOCS 9806300123 | |
| Download: ML20249C486 (2) | |
Text
June 18, 1998
SUBJECT:
INTEGRATED INSPECTION 50-334/97-11, 50-412/97-11 L
Dear Mr. Cross:
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This letter refers to your April 16,1998 correspondence, in response to our March 17,1998 letter.
- Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
.Your cooperation with us is appreciated.
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Sincerely, ORIGINAL SIGNED BY:
Michele G. Evans, Chief Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-334; 50-412 J.
~gg w/o ev of Licensee Renconse Letter:
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- Sushil C. Jain, Senior Vice President, Nuclear Services Group
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R. Brandt, Vice President, Nuclear Operations Group and Plant Manager D
. R. LeGrand, Vice President, Operations Support Group
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- 8. Tuite, General Manager, Nuclear Operations Unit
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' W. Kline, Manager, Nuclear Enlgineering Department
- M. Perger, Acting Manager, Quality Services Unit '
. S. Hobbs, Director, Safety & Licensing Department g
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' J. Macdonald, Manager, Systein and Performance Engineering i
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cc w/cv of I In ma=== Rannonse Letter:
. M. Clancy, Mayor, Shippingport, PA Commonwealth of Pennsylvania N(Og
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State of Ohio
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State of West Virginia d! d4 IE01 e
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Mr. J. E.' Cross
Distribution w/cv of Licensee Raenonse Letter:
Region i Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
PUBLIC i
NRC Resident inspector H. Miller, RA/W.' Axelson, DRA
. M. Evans, DRP
~ N. Perry, DRP D. Haverkamp, DRP.
- C. O'Daniell, DRP -
- B.~. McCabe, OEDO R. Capra, PD1-2, NRR -
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D. Brinkman, PDI-2, NRR
- V. Nerses, PDl-2, NRR.'
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R. Correia, NRR j
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- F Talbot, NRR
-DOCDESK Inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: ' G:\\ BRANCH 7\\REPLYLTR\\bv9711.rpy s To sessfue e esem r of Wile sleeumont, ineeste in the hos:
"C' = Copy without ettechment/ enclosure
- E* = Copu with attachment / enclosure
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OFFICE Rl/DRP Rl/DRP lW
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l NAME-DHaverkamp4Y./#
MEvans DATE 4/4798 6//798 OFFICIAL RECORD COPY
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Teiephone (412) 393-6000
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Shippsngport. PA 15077-0004 April 16,1998 i
f L-98-074 U. S. Nuc! car Reguhtory Cc=ni::icn Attention: Document Control Desk Washington, DC 20555-0001 Subject:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 l Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Integrated Inspection Report 50-334/97-11 and 50-412/97-11
Reply to Notice of Violation
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In response to NRC correspondence dated March 17,1998, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
If there are any questions concerning this response, please contact Mr. J. Arias at (412)393-5203.
Sincerely, Ronald L. LeGrand
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Attachment c:
Mr. D. S. Brinkman, Sr. Project Manager
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Mr. D. M. Kem, Sr. Resident I_nspector Mr. H. J. Miller, NRC Region I Admmistrator
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p[C. W. Hehl, Director, Division of Reactor Projects, Region 1 j
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- 0 DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit No. I and No. 2
> Reniv to Notice of Violation Integrated Inspection Report 50-334/97-11 and 50-412/97-11 Letter Dated March 17,1998 VIOLATION A '(Severity Level IV, Supplement i)
Description of Violation (50-412/97.-l1-08)
'TS 6.8.1 requires that written procedures be properly established and implemented
' covering activities recommended in Appendix "A" of NRC Regulatory Guide (RG) 1.33, Rev. 2, February 1978. NRC RG 1.33 states, in part, that maintenance which can affect the ' performance of safety-related equipment should be properly pre-planned: and performed in accordance with written procedures and documented. instructions appropriate to the circumstances.
Contrary to the above, from January 26 to February 4,1998, repair activities for the 2-1
- station battery were not properly pre-planned and implemented. Specifically, the work instructions contained in. maintenance' work requests (MWR) 69496 and 69526 were
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inadequate in that_they did not provide sufficient detail to assure intercell connectors
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. were properly controlled; Further, a supplemental work instruction for jumpering cell
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- 40 from the 2-1 station battery was not properly controlled in that it did not_ receive
= appropriate reviews as part of the MWR planning and authorization process. Inadequate tightening of an intercell connector.resulted in a high impedance location within the battery which had the potential to cause significant battery damage during a full capacity-
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discharge test on January 31.
Reason for the Violation
-.NPDAP 7.5, " Processing of a Maintenance Work Request," does not provide a clear standard for work package content or preclude the excessive use of supplemental work instructions in lieu of an approved procedure.
In ' addition, the field-personnel performed work outside of the scope of the work
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P l instructions..
The job should have been stopped and additional supervisory input requested, in accordance with existing maintenance standards.
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Q Reply to Notice of Violation
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Inspection Report 50-334/97-11 and 50-412/97-11
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- Page 2 Corrective Action Taken an' Results Achieved d
.l. 'The supplemental work instruction that was not properly controlled was removed from the work package.
2. The loose intercell connector was properly secured and a post maintenance discharge :
test was successfully performed. The battery was returned to an operable status on February 4,1998, after recharging.
Corrective Actions to Prevent Further Violations 1. A written communication.will be issued to Maintenance Programs Unit (MPU)
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personnel by A,ril 30,1998, which:
reinforces maintenance standards for review of work packages, including the e'
need to ensure that the work instructions provide sufficient detail for the scope
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of work to be performed reinforces that-the job should be stopped if the. work instru' tions are not e.
c adequate, and that no work is permitted to be performed outside of the scope of the work instructions provides guidance for determining when a procedure change. should be
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considered, instead of providing supplemental MWR work instructions.
2. The Work Planner Desktop Guide describes the planning process and provides information on the available site references to be used. It also provides some limited guidance on the level of detail required in.the work instructions for various tasks. In order to improve the work planning standards and guidance provided, the Work Planner Desktop Guide will be revised by May 30,1998 to:
establish standards for. work package technical. content in order to provide e
consistency in work package quality
.e provide guidance for work package review within the work planning section, and also for wo'k package review by field personnel for initial work-r instructions and also for supplemental instructions added after work has begun.
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3. Training on the revised Work Planner Desktop Guide will be provided to
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maintenance planning personnel by June 30,1998.
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- Reply.to Notice of Violation Inspection Report 50-334/97-11 'and 50-412/97-11
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Page 3 4.: ' NPDAP 7.5 " Processing a Maintenance Work Request" will be revised by July 15,
- 1998, to strengthen the controls for work package content, and provide guidance on.
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when an approved procedure is required in lieu of supplemental work instructions.
5. : The maintenance standards will be reinforced with active duty MPU craft personnel by July 15,1998.
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6. The station bittey corrective maintenance prccedure will be revised by July 15, 1998, to provide more details for replacing battery components, including enhanced n
- controls over fastener configurations.
7.~ An effectiveness review of the above corrective actions will be completed:by
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December 11,1998.
8.L A self-assessment will be completed by July 15,1998, to:
review the use of MWR work instructions to supplement existing procedures e
review the level of detail provided in various types of equipment maintenance e
procedures by reviewing a sampling of procedures; review MPU pre-job briefing and shift turnover practices e
review the adequacy of post maintenance testing
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- The findings of this self-assessment will be addressed under the corrective action i
program.
Date When Full Compliance Will Be Achieved The 2-1 station battery was returned to operable status on February 4,1998.
The letter to MPU personnel will be issued by April 30,1998.
The' Work Planner Desktop Guide will be revised by May 30, 1998. Training on the revised Work Planner Desktop Guide will be completed by June 30,1998.
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NPDAP 7.5 will be revised by July 15,1998.
. The maintenance standards will be reinforced with active duty MPU craft personnel by July 15,1998.
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. The station battery corrective. maintenance procedure will be revised Sv July 15,1998.
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27, Reply to Notice of Violation-H -
. Inspection Report 50-334/97-11 and 50-412/97-11 L.
Page 4 p.
The~self-assessment described above will be completed by July 15,1998.
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1 The effectiveness review will be completed by December 11,1998.
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Reply to Notice of Violati_on
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" Inspection Report 50-334/97-11 and 50-412/97-11 Page 5 -.
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VIOLATION B (Severity Level IV, Supplement I)
Description of Violation (50-334/97-11-02)
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- TS 6.8.1 requires that written procedures be _ properly established and implemented
' covering activities recommended in Appendix "A" of NRC Regulatory Guide (RG) 1.33,
Rev. 2, February 1978. NRC RG 1.33 states, in part, that administrative procedures
should cover shift and relief turnover and log enities.
Licensee procedures 1/2OM-48.5.A, " Logs and Reports," Rev.10, and 1/2OM-48.1.C,
" Shift Turnover and Relief," Rev. 2 implement shift and relief turnover and log entry
requirements. Specifically,1/2OM-48.5.A requires that entering and exiting TS action i
statements, limiting condition of operations and action numbers are recorded in operating d
logs. In addition,1/20M-48.1.C requires that the nuclear shift supervisor and assistant
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nuclear shift supervisor certify that their narrative and tour logs are accurate, clear, i
. concise and complete.
Contrary to the above, on January 21, operators failed to log TS 3.3.1.1'and TS 3.0.3
. limiting condition of operation entry and exit in response to identified isolation of
- feedwater flow channels and a resultant inoperable reactor protective system reactor trip
< function. In addition, the nuclear shift supervisor and assistant nuclear shift supervisor failed to recognize the incomplete log entries during shift turnover.
Reason for the Violation i
The on duty operations shift personnel failed to complete the logging requirements'in s procedures:1/2OM-48.5.A " Logs and Reports" and 1/2OM-48.1.C " Shift Turnover and Relief" due to cognitive personnel error.
Corrective Action Taken and Results Achieved i
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1. The Nuclear Shift Supervisor and the Assistant Nuclear Shift Supervisor involved
!with the event were counseled on February 11,1998, concerning the failure to meet operations logging standards.
-2.- Condition Report 980290 was written on February 12,1998,' to document the failure
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to properly log the entry and exit into Technical Specification 3.0.3 on January 21,
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~ 1998.1 This condition report was reviewed by the active licensed operations staff and i
Shift Technical Advisors (STAS) by March 23,1998.
3. 'The General Manager of the Nuclear Operations Unit re-emphasized management expectations for log keeping and shift turnover during discussions with all' active duty j
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- Reply to Notice of Violation
- Inspection Report 50-334/97-11 and 50-412/97-11
- Page 61 licensed personnel and STAS in the Operations Department. These discussions were
- held between February 22,1998, and March 10,1998.
l4. Beaver Valley. Unit 'l Licensee Event Report (LER) 98-002-00 was issued on February 20,.1998, and L reported the conditions ' prohibited by the technical
' specifications as_ a result of the inadequate recovery from a calibration of the
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.feedwater flow transmitters. Included in the LER analysis of the event was: 'a discussion of the. entries into: Technical Specifications 3.3.1.1 and 3.0.3, and the failure to log the entry and exit of Technical Specification 3.0.3.
Corrective Action to Prevent Further Violations
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1, Operating ' Manual. procedure 1/2OM-48.1.I, " Technical Specification Compliance"
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was issued on February 9,1998. - This procedure provides instructions for assessment of entered' technical spe.cifications and recommended actions, in the form of a
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checklist,: to take 'upon entering a technical specification action statement that requires a unit shutdown. This. checklist includes specific guidance on operator log
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-2. Technical Specification ~ Coinpliance : Training is currently being conducted' for designated site personnel including licensed operations personnel. The purpose of
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the trammg is to baseline the understanding of the technical specifications, including i
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ownership and management standards'and expectations for. full compliance. Topics covered include'the relationship of technical specifications in the overall licensing
_ process, specific examples of proper technical specification compliance and examples of past non-compliances with technical specifications. Management standards for the
. logging of technical ~ specification entries and exits are also being reviewed. This training will be completed for designated perroanel prior to entry into Mode 4 from
' the! current' outage at 'either unit. Designated personnel who do not successfully complete this trainmg will be restricted from independent technical specification
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related duties until remediated.
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Date When Full Comoliance Will Be Achieved LFull compliance was achieved with the reporting of the conditions. prohibited by the
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technical specifications by LER 98-002-00 dated February 20,1998, which documented
. the technical specification entries and exits on January 21,'1998, as a result of this event.
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.The completion of the Technical Specification Compliance Training for designated personnel will be completed prior to entry into Mode 4 for either unit.
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