IR 05000334/1998001
| ML20249C488 | |
| 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 | |
| 50-334-98-01, 50-334-98-1, 50-412-98-01, 50-412-98-1, NUDOCS 9806300126 | |
| Download: ML20249C488 (2) | |
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June 18, 1038 l
Mr. J. President
. Generation Group Duquesne Light Company
- Post Office Box 4 i
Shippingport, Pennsylvania 15077 l
SUBJECT:
INTEGRATED INSPECTION 50-334/98-01, 50-412/98-01
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Dear Mr.' Cross:
This letter refers to your May 22,1998 correspondence, in response to our I
April 22,1998 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.
Sincerely,
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ORIGINAL SIGNED BY:
Michele G. Evans, Chief Projects Branch 7 Division of Reactor Projects Dock'et Nos.: 50-334; 50-412
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cc w/o cv of Licensee Resoonse 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 i
l R. LeGrand, Vice President, Operations Support Group
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-- B. Tuite, General Manager, Nuclear Operations Unit
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' W. Kline,' Managar, Nuclear Engineering Department M. Pergar, Acting Manager, Quality Services Unit
~ S. Hobbs, Director, Safety & Licensing Department J. Macdonald, Manager, System and Performance Engineering h
cc w/cv of Licensee Renoonse Letter:
gO M.'Clancy, Mayor, Shippingport, PA Commonwealth of Pennsylvania
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State of Ohio'
State of West Virginia
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9906300126 990618 i
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l POR ADOCK 05000334 S
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Mr. J. Distribution w/cv of Licensee Resoonse Letter:
Region i Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC WRC 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 D. Brinkman, PDI-2, NRR V. Nerses, PDI-2, NRR R. Correia, NRR F. Talbot, NRR DOCDESK Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\bv9801.rpy Ta,eceive a copo of thne document, andcate in the bar: "C" = Copy without ettschment! enclosure
- E" - Copy with attachment /encionure
- N' = No copy OFFICE Rl/DRP Rl/DRP Q
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NAME DHaverkampg/f MEvans l
DATE 4//7/98 o /1998
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OFFICIAL RECORD COPY
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MM Of 0**"er Valley Power Station
B Shippingport, PA 15077 0004 SUSHIL C. JAIN (412) 393 5512 Senior Vice President Fax (724) 643 8069 Nuclear Services Nuclear Power Division May 22,1998 L-98-105 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Subject:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Integrated Inspection Report 50-334/98-01 and 50-412/98-01 Reply to Notice of Violation In response to NRC correspondence dated April 22,1998, 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 conceming this response, please contact Mr. J. Arias at (412) 393-5203.
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Attachment c:
Mr. D. S. Brinkman, Sr. Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Ms. M. G. Evans, Chief, Project Branch 7, Division of Reactor Projects DEllVEliNG QUAlliV ENERGV 4,e clovao
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DUQUESNE LIGHT COMPANi Nuclear Power Division Beaver Valley Power Station, Units No. I and No. 2 Reniv to Notice of Violation
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Integrated Inspection Report 50-534/98-01 and 50-412/98-01 l
Letter Dated April 22,1998 VIOLATION A (Severity Level IV, Supplement I)
Description of Violation (50-334(412)/98-01-03)
l 10 CFR 50, Appendix B, Criterion XVI (Corrective Action), requires, in part, that l
measures shall be established to assure that conditions adverse to quality, such as l
failures, deviations, defective material and equipment, and nonconformances are promptlyidentified and corrected.
Contrary to the above, conditionr, adverse to quality were not promptly corrected in that from November 1993 to March 1998, Duquesne Light Company failed to correct a
, known Unit I and Unit 2 Technical Specification (TS) deficiency (TS degraded voltage setpoints) in a ti nely manner. The TS degraded voltage setpoints were non-conservative in that the setpoints were not sufficient to maintain uninimum voltage requirements for safety-related equipment. The licensee failed to submit a TS amendment request to l
correct the setpoints. In addition, station procedures were not prcperly revised to assure
- that the emergency diesel generator would receive an automatic start signal at or above the' bus voltage required by design. - Specifically,1) the reference in the procedure identified the TS values (which were non-conservative) and not the detennined design l
basis values; 2) the procedure did not have explicit acceptance criteria that the setpoints would be within the design basis values as listed in a procedural attachment; 3) the step
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to notify the shift supervisor that the relay was below allowable values identified the
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non-conservative TS value rather than the design basis value.
l Reason for the Violation l
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The reason for the violation was inadequate corrective actions following the design l
process that established new design values for the degraded voltage Setpoints and
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Allowable Values,.which also concluded that the existing values in the Technical
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Specifications (TS) were non-conservative. The inadequate administrative controls were the result of an incomplete translation of the design documentation into the plant l
surveillance procedures. The administrative controls continued to be used during the l
. period the violation existed because various ongoing technical issues were being
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addressed in the determination of the " final" degraded voltage Setpoints and Allowable Values.
In each case, submittal of a Technical Specification Amendment Request
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' Reply to Nctice of Violadon
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Inspection Report 50-334/98-01 and 50-412/98-01
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(TSAR) was delayed pending resolution of each separate issue since each issue had the potential to change these design values and require an additional TS change.. Continued pursuit of the resolution of each technical issue prior to submittal of a TSAR led to the failure to submit any TSAR in a timely manner.
Corrective Actions Taken and Results Achieved 1.. Using the data from readily retrievable completed surveillance, a maintenance history review was performed of the as-found surveillance data for the degraded
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- voltage setpoints from April 1995 to the present for Unit I and from October 1996 to the present for Unit 2.
While not covering the entire period of the Notice of Violation, the results should be reasonably representative of the surveillance results for the entire period. The review discovered one instance where the as-found setting was below the design analysis value. The design analysis value corresponds to a TS Allowable Value. In this case, the as-found setting was approximately 0.1 volt below its design analysis value. The relay was then re-calibrated to the proper tolerance and
- retumed to s'ervice. The Nuclear Engineering Department (NED) has evaluated this -
instance and has detemuned the safety significance of this occurrence to be mini==1 In every other instance reviewed, the as-found values met the required design analysis values.
2. As a result of this Notice of Violation, the NED has performed additional reviews which have identified an additional instance of an inadequately administratively controlled TS, for which a TSAR was not submitted to the NRC. This instance-involves Reactor Protection and Engineered Safety Feature (ESP) Setpoints and
Allowable Values. As a result of this additional finding, a Multi-Disapline Analysis
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Team (MDAT) has been formed to evaluate the extent of this condition.
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Corrective Actions That Will Be Taken to Avoid Further Violations 1. The Maintenance Surveillance Procedures used to perform the TS required surveillance of the degraded voltage Setpoints at each Unit are currently being revised'to address the concerns identified in this Notice of Violation.
These procedure revisions.will be completed at each Unit prior to that Unit entering
Mode 4. The TS ESF degraded voltage function is applicable in Modes I through 4
at both Units 1 and 2.
I 2. The design analysis documentation for the degraded voltage setpoints will be updated l
to incorporate the resolution of an outstanding technical issue which has the potential to affect the design basis value for the degraded voltage setpoints at each Unit. This l
Lwill be completed at each Unit by the NED prior to that Unit entering Mode 4 from the present outage. Should this technical resolution require additional revisions to the l
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Reply to Notice cf Vi:lati:n Inspection Report 50-334/98-01 and 50-412/98-01
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Page 3 existing' administrative controls to ensure adequate degraded voltage setpoints are maintained, this will also be completed at each Unit prior to that Unit entering Mode 4 from the present outage.
3. Following resolution of this outstanding technical issue including revisions to the technical analysis documentation, a Technical Speci6 cation Amendment Request (TSAR).will be submitted to the NRC for the degraded voltage Setpoints and
^ Allowable Values at each Unit.
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4. The MDAT will continue the review of the Reactor Protection and ESF Setpoints and
- Allowable Values to determine whether additional corrective actions are necessary.
The MDAT will investigate the site processes and procedures used to identify and implement administrative controls for Technical Specification related items.
Corrective actions to revise the processes and procedures that are identi6ed as part of the MDAT review will be implemented at each Unit prior to that Unit entering Mode 4 from the present outage.
5. The NED: Management will review the open NED backlog for other Technical Speci6 cation related items and take appropriate corrective sctions as necessary'at each Unit prior to that Unit entering Mode 4 from the present outage.
Date When Full Comoliance Will Be Achieved i
Full compliance for the specific issues of this Notice of Violation will be achieved at
each BVPS Unit after completion of all required surveillance revisions, submittal of a Technical Specification Amendment Request (TSAR) for the degraded voltage Setpoints
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and Allowable Values, and approval of the TSAR for each Unit by the NRC. Adequate administrative controls will be established and maintained at each Unit for the degraded l
voltage Setpoint and Allowable Values pending approval of a TSAR by the NRC.
l The establishment and innintenance of adequate administrative controls for the degraded
voltage setpoints at each BVPS Unit prior to that Unit entering Mode 4 coupled with
timely submittal of a TSAR will allow BVPS to meet the intent of full compliance pending NRC review and approval of the proposed TS AR.
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Reply to Notice of Violation Inspection Report 50-334/98-01 and 50-412/98-01
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VIOLATION B (Severity Level IV, Supplement I)
Description of Violation (50-412/98-01-05)
l 10 CFR 5.0, Appendix B, Criterion III (Design Control), requires, in part, that desip changes shall be subject to desip control measures commensurate with those applied to the original design.
Contrary to the above, on February 18,1998, design control measures for a modification to the Unit 2 emergency diesel generators (EDGs) ground overcurrent trip isolation l
feature were inadequate. Specifically, the failure mode analysis for this design change did not fully evaluate failures of the quality assurance category 2 ground switch and resistor. The failure mode analysis also did not identify or evaluate an additional failure mode which had the potential to damage the EDG during surveillance testing if a fault occurred on the 4 kV line.
Reason for the Violation I
The reason for the violation was datanniaed to be an insufficient analysis and an l
inadequate understanding of the design bases by the engineers performing the i
l modification. After the modification was implemented, it was determined that (1) a new I
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failure mode had been created, and (2) the modification was not needed in order to meet l_
the design basis requirements.
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Corrective Actions Taken and Results Achieved 1. Technical Evaluation Report (TER) 11704, Revision 1,' was issued on March 7,1998, i
to change the design of the emergency diesel generator ground protection back to its original design configuration. The revised TER also included a Failure Modes and Effects Analysis and QA Category Determination Worksheets which documented that the non-safety related QA classification of the motor operated ground switch and resistor are acceptable.
2. TER 11704, Revision 1, was installed to restore the emergency diesel generator ground protection back to its original design configuration. This was completed sia MWR 070402 for EDG 2-1 on March 8,1998, and via MWR 070403 for EDG 2-2 f on March 9,1998.
3. The emergency diesel generator ground protection issue was presented during Nuclear Engineering Department _(NED) Engineering Support Personnel (ESP)
Specific training to reinforce management expectations regarding the need to
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thoroughly understand the design and licensing bases requirements before making
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Reply to Notice of Vi:lation l
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March 31,1998.
- 4. The Manager, Nuclear Engineering Depiuhuent issued a letter (NDIMNE:8107 dated
. April 28,' 1998) to all NED personnel to reinforce management expectations regarding the need to thoroughly understand the design and licensing bases requirements before making any modifications.
Corrective Actions That Will Be Taken to Avoid Further Violations Nuclear Engineering Department Engineering Standard ES-E-003 will be revised by December 31, 1998, to document the design basis of the Unit 2 emergency diesel generator motor operated ground switch as it relates to compliance with Regulatory Guide 1.9, and to add a reference to TER 11704, Revision 1, which documented the QA Category determination.
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Date When Full Comnliance Will Be Achieved
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Full compliance was achieved when the emergency diesel generator (EDG) ground protection for-both EDGs was returned to its original design configuration via implementation of TER 11704, Revision 1 on March 9,1998.
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