IR 05000334/1998011

Insp Repts 50-334/98-11 & 50-412/98-11 on 981227-990206. Violations Noted.Major Areas Inspected:Operations,Maint & Plant Support

ML20207E112
Person / Time
Site:	Beaver Valley
Issue date:	02/25/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207E024	List: IR 05000334/1998011 ML20207E020 ML20207E076
References
50-334-98-11, 50-412--98-11, NUDOCS 9903100151
Download: ML20207E112 (21)

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L U. S. NUCLEAR REGULATORY COMMISSION

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REGION I  !

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l License No DPR-66, NPF-73 t Report No /98-11, 50-412/98-11 I

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Docket No , 50-412

Licensee: Duquesne Light Company I Post Office Box 4 J l Shippingport, PA 15077 Facility: Beaver Valley Power Station, Units 1 and 2 i- Inspection Period: December 27,1998 through February 6,1999 i i

i l W y ctors: D. Kern, Senior Resident inspector l G. Dentel, Resident hspector i

G. Wertz, Resident inspector Arpaved by: N. Perry, Acting Chief i fleactor Projects Branch 7 l

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9903100151 990225 PDR ADOCK 05000334 O PDR

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l L EXECUTIVE SUMMARY i

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Beaver Valley Power Station, Units 1 & 2 l NRC Inspection Report 50-334/98-11 & 50-412/98-11 l

l This inspection included aspects of licensee operations, maintenance, and plant support. The report covers a 6-week period of resident inspectio Ooerations L *

Poor procedures and human performance weaknesses resulted in an uncontrolled reduction of main condenser vacuum and subsequent Unit 1 reactor trip during i condenser waterbox cleaning. Poor procedures also caused an uncontrolled reduction

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- of vacuum and turbine trip during unit restart. (Section 01.2)  ;

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Unit 1 operators alertly initiated a manual reactor trip from 73% reactor power, when they l could not recover main condenser vacuum. The event review team and the nuclear l . safety review board comprehensively reviewed the event and identified appropriate

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corrective actions prior to restart. Corrective action implementation was adequate, yet j some related procedural deficiencies, which could cause event recurrence, were not j addressed until questioned by the inspectors. (Section O1.2) ]

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Equipment operability, material condition, and housekeeping associated with the Unit 1 l river water and emergency power systems were generally good. Minor housekeeping and materisi deficiencies were identified to the appropriate Nuclear Shift Supervisor and

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corrected in a timely manner. (Section 02.1)

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Off-Site Review Committee (ORC) meeting periodicity, content, and membership quorum met regulatory requirements. Extemal ORC member participation has improved the i quality of station chemistry and radiological audits. (Section 07.1)

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The Corrective Action Review Board (CARB) conducted comprehensive reviews of l condition report investigation responses, with a rejection or table rate of 20%. CARB l membership diversity contributed to noteworthy findings including a concem associated .

[ with the use of permanent caution tags and configuration control. (Section O7.2) l

While condition report investigation response quality has improved since May 1998, the Corrective Action Review Board rejection rate' continued to inc9te a performance weakness. (Section 07.2)

= Quality Services Unit personnel identified that procedures and practices may have been inadequate to assure technical specification (TS) surveillance requirements for L meteorological monitoring instrumentation were satisfied. investigation of the issue was

! incomplete and corrective actions were untimely. Absent NRC involvement, the licensee would not have recognized and reported several related violations of TS. These L < ' deficiencies represented a breakdown of the corrective action program across the h organization and resulted in a violation. (Section 08.1)

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' Enclosure 1

+. LThe condition report investigation backlog has decreased approximately 50% since May 1990.' The corrective action backlog, especially in the Engineering and Maintenance departments, remained high with over 1000 open items. Deficiencies continued to be identified and inputted into the corrective action system. (Section O8.3)

Maintenance  :,

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Poor material condition of the chlorination system prevented station personnel from

' routinely chlorinating the Unit 1 circulating water system to preclude marine fouling -

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. during the past sreveral monthsJ Main condenser performance significantly degraded, '

which necessitated condenser waterbox isolation and cleaning. This evolution led to an uncontrolled reduction of condenser vacuum requiring operators to manually trip the  !

reactor. (Section O1.2)~

l' .. . Three routine maintenance activities were prformed safely and in accordance with  !

l- . proper procedures. An emergent Unit 2 service water pump work activity was properly planned and implemented. The control room door was safely repaired due to good ' ]

h ll coordination between engineering personnel, operators, and maintenance planners.

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a Four surveillance tests were performed safely with effective field operator support.

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. Poor self checkirg, failure to perform a procedure in the sequence it was written, and insufficient post maintenance testing requirements resulted in the "B" Control Room Emergency Ventilation System train being unrecognized as inoperable for two day . (Section M1.3)

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The maintenance rule program continued to properly monitor the effectiveness of maintenance. The periodic program assessment demonstrated stiong system engineering involvement and monitoring of the program and individual systems. The effectiveness of corrective actions was generally good for systems evaluated under the (a)(1) category. (Section M2.1)

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In some cases, such as Unit 1 Iow head safety injection, safety related system unavailability was not effectively managed, due to work scheduling and coordination deficiencies. (Sections M1.2 and M2.1)

Plant Support

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Radiological maps and radiation area postings for the Unit 2 primary auxiliary building were accurate. A containment entry was safely performed. (Section R1.1)

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The security system design was robust and therefore was minimally impacted by the

_ storms in early January. Compensatory measures taken were appropriate.

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TABLE OF CONTENTS ,

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EXEC UTIVE S U M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .i TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii I . Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . 1 I O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Unit 1 Reactor Trip, Evaluation, and Restart . . . . . . . . . . . . . . . . . . . . . 1 O2 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . .

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...3 j O2.1 Engineered Safety Feature System Walkdowns . . . . . . . . . . . . . ... 3 1 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .l '

07.1 Off-Site Review Committee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 08 Miscellaneous Operations issues . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 6 08.1 inoperable Meteorological Tower Instrumentation . . . . . . . . . . . . . . . . , 6 08.2 (Closed) LER 50-334/98-29: Inadequate Meteorological Instrumentation Calibration Leads to Failure to Comply with Technical Specifications.. 9 08.3 Condition Report investigation and Corrective Action Backlogs. . . . . . 9 II . M aintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 M1 Conduct of Maintenance . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 M1.1. Routine Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . 10 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 M1.3 Inappropriate Surveillance Testing Results in Unit 2 Control Room l Emergency Ventilation System Unplanned inoperability . . . . . . . . . . 12 l M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . 13 .

M2.1 Periodic Assessment of the Maintenance Rule Program . . . . . . . . . . 13

! IV. Pla nt Support . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 i

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R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 14 I l .

R1.1 Walkdown of Unit 2 Radiological Areas and Containment Entry . . . . 14 l S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . 15 1 1 S2.1 Security Response to Winter Weather Conditions . . . . . . . . . . . . . . . 15  !

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! V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16  :

X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 l

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X2 Duquesne Light Company Management Changes . . . . . . . . . . . . . . . . . . . . 16 l l INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ,

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. ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17  ;

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. LIST OF ACRON YM S U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 l

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Report Detaif Summarv of Plant Status Unit 1 began this inspection period at 100% power. On Ja ory 23, operators manually tripped the reactor in response to an uncontrolled reduction of main condenser vacuum resulting from l maintenance on the condenser. The unit retumed to power operation on January 25. (Section 1 01.2)

Unit 2 beg'an this inspection period at 100% power and remained at or near full power throughout the inspection perio koperations 01 Conduct of Operations-01.1' General Comments (71707)

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Using inspection Procedure 71707, the inspectors conducted frequent reviews of

. ongoing plant operations, in general, the conduct of operations was professional and {

safety-conscious. Specific events and noteworthy observations are detailed in the

' sections belo ~ 01.2 Unit 1 Reactor Trio. Evaluation. and Restart . Inspection Scooe (71707. 92901. 93702)

On January 23, Unit 1 operators manually tripped the reactor from 73% reactor oowe r in response to an uncontrolled reduction of main condenser vacuum. The inspectors responded to the site and evaluated the cause of the trip, plant safety, readiness for I restart, and licensee actions to preclude recurrence.

! ' Observations and Findinas Poor material condition of the chlorination system prevented station personnel from routinely chlorinating the Unit 1 circulating water system to preclude marine fouling

~ during the past several months. Main condenser performance significantly degraded, !

which necessitated condenser waterbox isolation and cleaning. Design changes and j temporary modifications to upgrade chlorination system reliability were planned, but have 4 not been implemented. Early on January 23, operators reduced reactor load and isolated the "C" condenser waterbox for cleaning.. At 10:24 a.m., the nuclear shift supervisor (NSS) directed the reactor operetor to manually trip the reactor due to an j uncontrolled reduction of main condenser vacuum, which could not be corrected. The j inspectors responded to the site and verified that safety systems performed as designe !

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. Operators property stabilized the plant in Mode 3 (hot standby) and reported the event as

- required by 10 CFR 50.72. The inspectors determined that the NSS decision to

. manually trip the reactor was prudent. - Although condenser vacuum had not degraded to the value where procedures required a reactor trip, actions to halt the loss of vacuum were unsuccessful and loss of vacuum was imminent

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l The management review team was promptly assembled at the site to review the event.

[ - Station response to the trip was clearly discussed. Actions to evaluate the cause of the

- trip, correct minor equipment anomalies observed during the trip, and prepare for restart were assigned. The plant manager directed that an event review team (ERT) be formed to investigate the event, identify root causes of the trip, and provide recommendations for j actions required prior to unit restart and actions to preclude recurrenc ~

The ERT reconstructed the event as follows. Shortly after moming shift tumover, l maintenance personnel informod the NSS that waterbox inleakage precluded them from a i beginning the waterbox cleaning. Under the direction of the assistant NSS, operators

! - manually adjusted the "C" waterbox inlet valve to reduce the inleakage. The inlet waterbox inleakage decreased as intended. After observing the waterbox standpipe level indicator for about 10 seconds, operators concluded that level was satisfactory and stable, and they left the area. Unknown to the operating crew, the "C" waterbox level l was actually decreasing. Eventually the "C" waterbox outlet valve became uncovered, l allowing air from the open waterbox to pass across the shut outlet valve seat and enter i the condenser _ discharge piping. This caused condenser vacuum to decrease and 1 began to air bind the cooling tower pumps. For the next hour, the NSS observed 1 increasing condenser hotwell temperatures and a reduced condenser vacuum. . Turbine load was reduced accordingly. At 10:10 a.m., the turbine building operator heard a loud

, sucking sound from the "C" waterbox, indicating that the "C" waterbox outlet valve had l lost its water seal. Actions to stabilize condenser vacuum were unsuccessful and the i

reactor was manually trippe The ERT concluded that the primary cause for the uncontrolled reduction of condenser vacuum was inadequate procedures. The procedure for draining the condenser 1

- waterbox,~10M-10M-31 A.G," Isolating One Half of a Condenser," Rev.1, did not contain l sufficient precautions concerning the potential for air introduction to the cooling tower L pump suction or guidance for operators to verify satisfactory waterbox level after making

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= any adjustments which could change waterbox inventory. Contributing causes included -

a degraded vacuum priming system and operators' insensitivity to maintaining a water seal on the waterbox outlet valve. The ERT report was clearly presented to the N'iclear

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. Safety Review Board (NSRB). The NSRB agreed with the ERT findings with one i modification. The NSRB elevated the operator insensitivity (human performance) issue ,

to a root cause and directed that operator training prior to restart address this issue. The j inspectors determined that the ERT and NSRB comprehensively reviewed the event and  !

identified appropriate corrective actions prior to restart to preclude recurrence.

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Unit 1 was restarted on January 25. The inspectors noted that a deficiency in the turbine startup procedure led to an uncontrolled reduction of condenser vacuum and a manual l L turbine trip prior to turbine synchronization to the off-site power grid. The procedure was  !

! correctad and the unit was placed on-lin l

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l l The inspectors determined that operating crew briefings and training conducted i j regarding this event were good. An operator was locally assigned to monitor condenser

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waterbox level during waterbox cleaning. The inspectors observed that the operator was alert and clearly understood his dutie i Revisions to procedure 10M-31.4.G improved the procedure's quality. However, the '

inspectors identified additional vulnerabilities within the procedure which had not been i corrected. For oxample, maintenance personnel routinely place portable sump pumps in l the waterbox while cleaning, to control water level. The procedure did not address use

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of these pumps which could uncover the waterbox outlet valve during the time interval ;

l between operator waterbox level checks. Therefore, implementation of this procedure 1 l as revised, could still cause a loss of main condenser vacuum event. The inspectors i also noted that the NSS had authorized manipulation of two red danger tagged j components (the waterbox inlet and outlet isolation valves) during the January 23 event without fully communicating the potential consequences to the operating crew.

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L Operation of the red danger tagged components was authorized to facilitate planned !

maintenance schedule adherence. Although station procedures permit the NSS to l authorize operation of danger tagged components, the inspectors determined in this j case that the red tag barrier was bypassed prematurely. The inspectors discussed these -

l  : concerns with operations department management who initiated reasonable corrective i i actions.

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l Conclu4 ions Poor material condition prevented station personnel from routinely chlorinating the Unit 1 l

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circulating water system to preclude marine fouling during the past several month Main condenser performance significantly degraded, which necessitated condenser

.waterbox isolation and cleaning. Poor procedures and human performance weaknesses resulted in an uncontrolled reduction of main condenser vacuum during waterbox cleaning. Operators alertly initiated a manual reactor trip when they could not recover main condenser vacuum. The event review team and the nuclear safety review board comprehensively reviewed the event and identified appropriate corrective actions prior to restart. Corrective action implementation was adequate, yet some related procedural deficiencies which could cause event recurrence, were not corrected until questioned by the inspector Operational Status of Facilities aml Equipment O2.1 Enaineered Safety Feature System Walkdowns

! ' Insoection Scooe (71707)

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The inspectors performed walkdowns of the accessible portions of the following risk i - significant, safety related systems

• ' River Water System (Unit 1)

= Emergency' AC Power (Unit 1)

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4 Observations and Findinos Equipment operability, material conoition, and housekeeping were generally good. Minor

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housekeeping items and material deficiencies were discussed with the appropriate Nuclear Shift Supervisor and corrected. Leakage of the Unit 2 service water strainers, located in the intake structure cubicles, persisted through the inspection period. This deficiency flooded the "C" and "D" cubicles with approximately 1 inch of standing water.

Although this condition did not affect equipment operability, it was a material condition I problem and a potential personnel safety concern. Although operations personnel were aware of the leakage, no efforts to implement temporary measuies to minimize the amount of flooding were initiated until the inspectors expressed concer Conclusions  ;

Equipment operability, material condition, and housekeeping associated with the Unit 1 l

. river water and emergency power systems were generally good. Minor housekeeping ;

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and material deficiencies were identified to the appropriate Nuclear Shift Supervisor and corrected in a timely manner.

07 Quality Assurance in Operations 07.1 Off-Site Review Committu I i Inspection Scope (71707)

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The inspectors attended an Off-Site Review Committee (ORC) meeting on Januaiy 12-13,1999, to determine whether associated oversight requirements as stated in the i

, Updated Final Safety Analysis Report (UFSAR), Section 17.2, " Quality Assurance Program Description, Operations," were me : Observations and Findinos Meeting periodicity, content, and membership quorum met the requirements specified in ,

the UFSAR. Topics were discussed in appropriate detailincluding preparations for and l scope of the upcoming Unit 1 & 2 planned outages, various station backlogs (i.e.,

maintenance, engineering, procedure change requests, and corrective action implementation), and methodology used for preparation of a significant technical specification (TS) license amendment request. The inspectors noted two positive ORC i practices which went beyond the requirements of the UFSAR. Specifically, the ORC decided to review emergency preparedness activities and each external ORC member participates in two station performance audits annually. As a result, chemistry and radiological program audits have improved notabl As discussed below in Section O7.2, the CARB chairman briefed the ORC on CARB status. He noted that CR investigation response quality had improved, CARB CR investigation rejection rate was low, and if this trend continued for another two months he would recommend discontinuing the CARB. Licensee members of the ORC Operating

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Experience Subcommittee agreed with the CARB chairman stating that prolonged use of the CARB could become a crutch that station personnel would rely on. The extemal ORC members questioned whether the corrective action program was sufficiently sound to function well without the CARB. The inspectors noted that no altemative method to ensure CR investigation response quality and accountability was proposed. The inspectors concluded that the licensee had not sufficiently evaluated CR investigatinn performance or established altemate quality verification measures to support eliminating the CARB (see Section 07.2). Conclusions Off-Site Review Committee (ORC) meeting periodicity, content, and membership quorum met regulatory requirements. External ORC member participation has improved the quality of station chemistry and radiological audit .07.2 Corrective Action Review Boa.rd Insoection Scope (71707)

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Station management observed that problem report and condition report (CR)

investigation quality had been inconsistent in 1996 and 1997. The Corrective Action Review Board (CARB) was established in May 1998 to review CR investigations to ensure consistency, accuracy, and appropnateness of proposed corrective actions. The I inspectors reviewed station procedures, conducted interviews, and attended CARB i meetings to assess CARB effectivenes Observations and Findinos '

The CARB met weekly and reviewed category 1-4 CR investigation responses as required by Nuclear Power Division Administrative Procedure (NPDAP) 5.6, " Processing of Condition Reports," Rev. 2. Typically,25-50 CR responses were submitted each ,

week for CARB review. The inspectors attended a CARB meeting and observed that (1)

members had properly prepared for the meeting and were ready to discuss any concerns they had with the CR responses, (2) issues were discussed in appropriate detail, (3) CARB membership divt.rsity provided excellent background from which to evaluate the various CR responses, and (4) seven of the 22 CR responses reviewed

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. were tabled or rejected. . The inspectors concluded that the bases for CR response rejections at the CARB meeting were sound. Condition report statistics indicated that the CARB typically rejects or tables (places CR on hold awaiting additional informathn) 20%

of all CR investigations reviewed. CARB discussions surfaced a noteworthy concem >

regarding the station's use of permanent caution tags and potential adverse affects on system configuration control. Appropriate follow-up for this issue was initiate Based on a random sample of 50 recent CR responses, the inspectors determined that the quality of CR investigation responses improved since the CARB was establishe The CARE chairman discussed CARB status at the last Off-Site Review Committee meeting. He stated that the CARB had fulfilled it's original purpose, and may be i

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discontinued or modified in the near future. The inspectors noted that NPDAP 5.6 relies on the CARB for ceveral key aspects of the corrective action program. In addition, while CR investigation response quality has improved, the rejection rate continued to indicate a performance weakness. The inspectors discussed these observations with the CARB chairman and questioned what the basis was for determining that the CARB was no longer needed to ensure the quality of CR investigation responses. The CARB chairman agreed that the CARB continued to provide an important function within the corrective action program. He did not have specific data to justify eliminating the CARB and stated he would assess various effectiveness indicators prior to proposing major revisions to the CARB. Subsequent to this discussion, the chairman of the NSRB directed that the CARB continue in its current rol ,

1 Conclusions I The CARB conducted comprehensive reviews of condition report investigation responses, with a rejection or table rate of 205 CARB membership diversity contributed to noteworthy findings including a concem associated with the use of permanent cautioniags and configuration control. While condition report investigation response quality hau improved since May 1998, the rejection rate continued to indicate a performance weakne'.: Miscellaneous Operations issues i l

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08.1 Inocerable Meteoroloaical Tower Instrumentation Insoection Scope (71707. 91902. 92700)

On November 3,1998, Quality Services Unit (QSU) personnel identified that current l procedures and practices may be ina(equate to assure TS surveillance requirements for ;

the meteorological monitoring instrumentation were satisfied. The inspectors conducted ;

interviews, reviewed records, and observed various meetings to evaluate licensee !

response to this QSU identified issu Observations and Findinas QSU auditors identified that wind speed and wind direction sensors which had been property calibrated at a vendor facility, were in some instances stored on-site for extended time intervals (e.g., greater than 1 year) prior to installation on the

~ meteorological tower. During performance of the station's instrumentation channel calibration procedure, the sensors on the meteorological tower were replaced with the sensors which had been in storage. _Techr,ical Specification 4.3.3.4 requires that each :

= meteorological monitoring instrumentation channel, including the sensor, be calibrated semi-annually. The channel calibration procedure ver"ied equipment performance from

. the sensor to the processor module, but did not include the sensor. The vendor test facility calibration was credited for sensor calibration. On November 3,1998, OSU auditors initiated 9 Teterpretation request to the General Manager of Nuclear i

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' Operations, to clarify whether extended on-site sensor storage prior to installation satisfied the TS required semi-annual channel calibration frequenc ]

. Although the channel calibrations at the site were performed routinely at 4 month l intervals, the procedures contained no requirements to assure that the wind speed and '

wind direction sensor calibration performed at the vendor facility was current. Auditors identified three occasions during the past year, where wind speed and direction sensors with calibration dates more than 6 months old were installed on the meteorological towe After receiving no response to the TS interpretation request for six weeks, QSU auditors !

initiated CR 982223 to address their concem. The corrective action process ultimately l determined that this was a TS violation and was reportable to the NRC. The TS i interpretation request'was answered on January 12,199 j

'l On January 13,1999, the NSRB performed the final review of Licensee Event Report l (LER) 50-334/98-29, " inadequate Meteorological instrumentation Calibration Leads to I Failure to Comply with TS," prior to submittal to the NRC.' The NSRB discussed the I event and identified that minor LER revisions were needed. The LER specifically reported that maintenance practices failed to ensure that the meteorological monitoring sensors in operation met the TS 4.3.3.4 calibration surveillance test requiremen ' inspectors' observations over the past 18 months indicated that the meteorological monitoring instrumentation had a poor performance record, requiring operators to frequently apply TS limiting conditions of operation (LCO) Corrective actions to improve instrument reliability have not fully been effective, and are ongoing. Based on this knowledge, the inspectors determined that it was highly probable that the missed TS surveillance requirements, and resulting inoperable instrument channels, had reduced

. the number of operable instrument channels below that permitted by TS. This condition  !

would not have been recognized by operators in the past. Neither the LER nor the l NSRB discussion addressed the operability of the effected instruments or whether '!

related TS requirements and LCO actions for the meteorological monitoring instrumentation had been violated. The inspectors determined that additional TS l requirements were likely to have been violated and questioned the NSRB regarding operability of the currently installed instrument At the conclusion of the NSRB meeting, the inspectors questioned whether the licensee had fully evaluated the above listed concems. The NSRB members acknowledged that these issues had not been considered, but indicated that they were con.; dent that the j currently installed instruments were properly calibrated. Station personnel were then t directed to assess the instrument operability impact associated with the missed TS l surveillances. Maintenance record reviews identified that one of the currently installed !

wind direction sensors exceeded its required TS channel calibration periodicity, seven radwaste gas decay tank effluent discharges were conducted during the past 15 months without the minimum required operable meteorological monitoring instrumentation as specified in TS 3.3.3.4, and special reports had not been submitted to the NRC as required by TS 3.3.3.4. The seven effluent discharges were monitored for radiological

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The inspectors independently reviewed station records, conducted interviews, c.nd -

identified numerous deficiencies. Each issue was discussed with appropriate station '

personnel who acknowledged the problems and initiated their reviews for resolutio The more noteworthy deficiencies are listed below.

l Response to the TS interpretation request was untimely (70 days). The issue

was relatively simple, yet was not acted upon promptly. Applicable TS .

i requirements were not fully evaluated and the determination of reportability to the NRC was delayed. This demonstrated inadequate sensitivity to TS requirements ,

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j ' Nuclear shift supervisors failed to adequately question the potential effect of CR !

! 982223 on installed meteorological monitoring equipment operability. This -

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permitted the TS required channel calibration surveillance interval for installed j: wind direction sensor number 414 to expir ,

' Upon reviewing the category 3 condition report (CR 982223), station

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. management did not question why the TS interpretation request, potentially affecting current equipment operability, had not been answered for over 6 weeks.

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In this instance, management accepted low performance standards regarding TS j compliance.

! Maintenance personnel made errors while reviewing sensor calibration dates in i response to CR 982223. This permitted the TS channel calibration surveillance

interval for wind direction sensor 414 to expire, despite advance notice.

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j- The LER presented to the NSRB, failed to address operability of the effected instruments or recognize that TS 3.3.3.4.a and TS 3.3.3.4.b had bee violated on multiple occasions. This demonstrated incomplete CR investigd . e,d event reportability assessment by various station department . The NSRB failed to recognize the LER deficiencies stated in paragraph number 5 above. This demonstrated a lack of questioning attitude, most notably from the operations perspective regarding equipment operability and TS implication The inspectors concluded that the above stated deficiencies represented a broad

' breakdown of the corrMive action program with regard to evaluating and resolving the )

QSU identified instrument calibration issue.10 CFR 50, Appendix B, Criterion XVI,

" Corrective Action," requires in part that measures be established to assure that l'

conditions adverse to quality are promptly identified and corrected. The inspectors concluded that investigation of the issue was incomplete, corrective actions were .

untimely, and absent NRC involvement, the licensee would not have recognized and

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reported several related violations of TS. This was a violation of NRC requirements (VIO 50-334(412y98-1141).

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, Conclusions Quality Services Unit personnel identified that procedures and practices may have been inadequate to assure technical specification (TS) surveillance requirements for 4

. meteorological monitoring instrumentation were satisfied. Licensee investigation of the issue was incomplete and corrective actions were untimely. Absent NRC involvement, the licensee would not have recognized and reported several related violations of T These deficiencies represented a breakdown of the corrective action program across the organization and resulted in a violatio .2 (Closed) LER 50-334/98-29: Inadequate Meteorological Instrumentation Calibration Leads to Failure to Comply with Technical Specification The inspectors performed an onsite review of the LER. The LER cdequately described '

the issue. Ti'e verification of the completeness of corrective actions will be addressed l through VIO 98-11-01 (see Section 08.1). The inspectors noted that the report date was i incorrect and should have been January 18,1999. This issue was communicated to the license ,

08.3 Condition Report Investioation and Corrective Action Backloos Inspection Scope (71707)

The inspectors reviewed the Safety and Licensing Department's quarterly report on condition reports (the corrective action system) to identify adverse trends. The )

inspectors also evaluated condition report initiation, initial assessment, and categorization through daily control room evaluations and management meeting 9bservation l Observations and Findinos i l

Condition report investigation backlog has decreased from a high of 416 open investigations in May 1998 to 215 open investigations in December 1998. The corrective '

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action backlog increased during the Unit i and Unit 2 extended outages and has ;

appeared to plateau at approximately 1050 open corrective action items. The majority of the items are assigned to the Engineering and Maintenance Departments. The high backlog of work itams in the Engineering Department was discussed in the ORC meeting The engineering manager stated that backlog was being monitored and that i reductions in the backlog would not likely occur until the upcoming Unit 2 refueling outage and the Unit 1 surveillance outage are completed. The inspectors did not identify l any safety concem ' Based on daily control room walkdowns and management meeting observations, the inspectors concluded that deficiencies continued to be identified, inputted into the corrective action system, and appropriate departr'cnts were assigned for investigation and evaluation. ' Categorization of the condition reports was appropriate. Additional i

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. Conclusions

The condition report investigation backlog has decreased approximately 50% since May

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1998. The corrective action backlog, especially in the Engineering and Maintenance

! Departments, remained high with over 1000 open items. Deficiencies continued to be

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. identified and inputted into the corrective action system, t 11. Maintenance

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M1 Conduct of Maintenance M1.1 Routine Maintenance Observations ' Inspection Scooe (62707)

. The inspectors observed four selected maintenance activities on important systems and components. - The maintenance work requests (MWRs) observed and reviewed are listed below:

• MWR 075583 Control Room Door Repair

MWR 076679 Alternate intake Structure Bay Cleaning

'* - MWR 074295 Replacement of Ladders and Handrails in Altemate intake Structure

• MWR 076647 Unit 2 Service Water Pump "B" Lift Adjustment

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b. - Observations and Findinas Routine maintenance activities observed were performed safely and in accordance with proper procedures. Emergent ladder and handrail replacement work in the alternate intake structure was well planned and implemented within the original schedule. The Unit 2 service water pump lift adjustment was an emergent work activity that was well p!anned and implemented. It restored the pump to original petformance parameter .

Engineers properly reviewed the control room door repair including the effects on the control room boundary and technical specification entries. The work was completed

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.afely due to a good briefing, security and operations personnel support, and detailed work instruction Conclusions Three routine maintenance activities were performed safely and in accordance with proper procedures. An emergent Unit 2 service water pump work activity was properly planned and implemented. The control room door was safely repaired due to good coordination between engineering personnel, operators, and maintenance planners i

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iM1.2 Routine Surveillance Observations

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. The inspectors reviewed selected surveillance tests through field observation, attendance at briefings, and interviews with operators. Operational surveillance tests

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(OSTs) and inspections reviewed by the inspectors are listed below.

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~ 2 OST-1.12C " Safeguards Protection System Train B CIB/ Spray Actuation Test," Rev.10

• - 2 OST-26.1 p " Turbine Throttle, Governor, Reheat Stop and

Intercept Valve Test," Rev.14

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1PMP-11SI-P-1 A-1 B-1M " Safety injection Pump Control Rod Seal Inspection," Re !

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2 OST-3 ." Service. Water Pump [2SWS*P218] Test," Re .i l Observations and Findinas  !

i l The four surveillances observed by the inspectors were performed safely. Operators in i the fiold were aware of their requirements and responsibilities. The proper TSs were entered and TS surveillance requirements were satisfie !

, The inspectors noted that the low head safety injection (LHSI) pump inspection was an

! annual inspection with a very short duration (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />). The inspection and clearance restoration resulted in the LHSI system being out of service for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. -The inspectors questioned the system engineer conceming the benefit of taking the pump out of service

! for a shift to perform a single activity versus minimizing the out of service time and l coordinating the activity with other maintenance for that pump. The system engineer j stated that the preventive maintenance (PM) should have been combined with other PMs l

(such as oil changes) to minimize unavailability. The system engineer indicated that the PM optimization program has not received sufficient effort due to other station needs and in particular the LHSl system PM optimization was not completed. Condition report i

. 990239 documented this lack of PM optimization progress. The hspectors reviewed the l maintenance rule goals for the LHSI system and noted that they were being me '

The surveillance test on the Unit 2 service water pump did not meet acceptance criteria and the pump was declared inoperable. A good plan was devised and implemented which adjusted the pump lift (see Section M1.1) and replaced the flow transmitters. The pump was restored to it's original performance parameter Conclusions p

' Four surveillance tests were performed safely with effective field operator support. Unit

. 1 low head safety injection pump inspections were not effectively coordinated with other 1- - maintenance activi'aes to minimize planned safety related equipment unavailability.

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M1.3 Inaooropriate Surveillance Testino Results in Unit 2 Control Room Erneroency

. Mentilation System Unolanned Inocerability IDagection Scope (62707)

On January 6, the Unit 2 Control Room Emergency Ventilation System (CREVS) was unexpectedly declared inoperable during performance of Beaver Valley Test (GVT)

2BVT 1.44.2, " Control Room Emergency Air Cleanup and Pressurization System Flow and Filter Efficiency Test," Rev. 5. The inspectors reviewed the maintenance, testing activities, and TS surveillance testing requirements associated with the unplanned LC Observations and Findinos The Unit 2 CREVS is tested in accordance with TS 4.7.7.1.d which requires that at least once per 18 months, a charcoal sample is removed and laboratory tested for radioactive iodine removal efficiency. When the charcoal tray was placed back into the ventilation system on January 4, it was not properly aligned and a 3/16-inch gap allowed ventilation system flow to bypass the charcoal tray. This condition rendered the "B" CREVS train inoperable. Operators did not recognize that the "B" CREVS train was inoperable until 2 days later, when the filter mechanical efficiency test was performed. Multiple barriers to preclude this condition from occurring failed. Corrective maintenance and system restoration were completed within the time specified by T The inspectors reviewed the MWR and noted that it did not have explicit . ;tructions for installation of the charcoal tray. The mechanical technician was not aware that the tilter could be installed with sufficient misalignment to create a gap. Poor self checking by the maintenance technician failed to identify this deficiency. The mechanical technician felt that the MWR was being used to support the system engineer in performance of obtaining a charcoal sample. The system engineer was present for the sample collection but left the ventilation room before the tray was reinstalle The procedure used by the system engineer for sample collection was 38VT 11.60.8,

"In-Place Filter Monitoring," Rev.3. It contained a detailed checklist which specified a visual verification of proper filter adjustment and gasket compression following charcoal .

tray reinstallation, after the charcoal sample has been obtained. However, the checklist was performed out of the sequence specified in the procedure and prior to the charcoal tray being removed. Therefore, the verification that the charcoal tray was correctly installed was inadequat ' Fo! lowing the charcoal replacement, post maintenance testing (PMT) was performed

'4 usirig 20ST-44A.3, " Control Room Ver.tiisaon Systern Test - Train B," Rev. 5 which verifies that the system provides the proper flow. However, this system flow test cannot

' verify the existence of filter bypass flow and is inadequate as a PMT following filter

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maintenance. On January 4,1999, cperators inappropriately declared the "B" CREVS

)- train operable, based on the results of this PMT.

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Two days after the charcoal sample was taken, the "B" train of CREVS failed ic meet 2BVT 1.44.2 acceptance criteria as a result of the improperly aligned charcoal tray. The inspectors noted during their review that the "B" train control switch was placed in the

" auto" position when the system was declared inoperable. This situation could have ,

resulted in additional control room personnal radiation exposure during a design basis event, since the charcoal filter was bypassing some of control room ventilatio Discussions with the NSS and Technical Assistant to the General Manager of Nuclear Operations indicated the need for additional questioning by the operators during degraded equipment condition The inspectors reviewed the corrective actions for the unracognized inoperable CREVS and determined that they were appropriate. The corrective actions included counseling

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the mechanical technician and training the mechanical division on the event. The procedure will be revised to add the mechanical efficiency test as a post maintenance testing requirement after the charcoal sample is obtained, enhance information for .

Installation of the tray and provide operators with guidance for actions taken if the test fail The inspectors determined that improper maintenance, inadequate MWR instructions,

. failure to adhere to the procedure, and insufficient PMT requirements resulted in an unrecognized and inoperable safety related CREVs train. Technical Specification 6.8.1.c, requires that, " Written procedures shull be properly established, implemented, and maintained covering... surveil!ance and test activities of safety related equipment."

Failure to properly perform 3BVT 11.60.8 and establish appropriate PMT criteria to verify cystem operability following maintenance was a violation of TS 6.8.1.c. The licensee identified this condition and took immediate corrective actions to declare the CREVS inoperable. The licensee initiated condition report 990042 and the corrective actions were appropriate and comprehensive. Therefore, this non-repetitive, licensee-identified, and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1'of the NRC Enforcement Policy (NCV 50-412/98-11-02). Conclusions l Poor self checking, failure to perform a procedure in the sequence it was written, and insufficient post maintenance testing requirements resulted in the "B" Control Room Emergency Ventilation System train being unrecognized as inoperable for two day M2 Maintenance and Material Condition cf Facilities and Equipment

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M2.1 Periodic Assessment of the Maintenance Rule Proaram a. ' Inspection Scooei37551. 62707)

System engineers completed their periodic assessment of the maintenance rule program for the period April 1997 to October 1998. The inspectors evaluated the assessment

with respect to the requirements of 10 CFR 50.65(a)(3). The inspec+ ors examined the licensee evaluation of performance / condition monitoring and associated goals and

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, performance objectives. The inspectors also reviewed the status of corrective actions from the previous periooic assessment, the current recommendations, and the i effectiveness of corrective actions for systems in the 10 CFR 50.65(a)(1) category.

! b.- Observations and Findinos j i

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The maintenance rule steering committee approved the maintenance rule periodic assessment on February 3,1999. The assessment concluded that the maintenance rule s program was functioning effectively. The inspectors concluded the following abco! the maintenance rule program: (1) items were appropriately dispositioned from category (a)(2) to (a)(1) ar.d visa versa; (2) corrective actions for category (a)(1) items were j generally appropriate and effective; (3) system engineer involvement and monitoring of the aystem has been effective; and (4) actual overall system, structure, and component (SSC) availability and reliability was hig System engineers identified set mal recommendations including improving communication and coordination regarding unavailability incurred when SSCs are removed from service for maintenance. This recommendation resulted from several systems exceeding their unavailability linaits including the Unit 1 fuel pool cooling. the Unit 2 service water and standby service water systems, and the Unit 2 emergency );

switchgear ventilation system. The PM optimization project continued within the system engineering department to maximize reliability and minim!ze unavailability. The project is currently 50% completed and is scheduled to be completed July 31,1999. The inspectors observed that there continued to be instances where PM tasks were not i optimally scheduled to minimize unavailability (see Section M1.2). l _Qonclusions The maintenance rule program continued to properly monitor the effectiveness of maintenance. The periodic program assessmen'. demonstrated strong system engineering involvement and monitoring of the program and individual systems. The effectiveness of corrective actions was generally good for systems evaluated under the (a)(1) category. In some cases, system unavailability was not effectively managed, due to work scheduling and coordination deficiencie ;

IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls

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R Walkdown of Unit 2 Radioloaical Areas and Containment Entry i inspection Scope (71750)

The inspectors examined the mdiological controls in the Unit 2 primary auxiliary building-(PAB) and for a Unit 2 containment entry. The controls were evaluated against 10 CFR 20 and licensee procedules including NPDAP 3.3, " Reactor Containment Entries,"

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15 Observations and Findinas The inspectors independently verified that the radiological maps for a sample of the .

Individual cubicles in the Unit 2 PAB were current and accurate. Workers observed in

. the field were wearing the correct dosimetry.. High radiation areas were properly posted and barriers were in place. Locked high radiation areas were properly controlle ,

Personnel were cognizant of the radiological and safety requirements for a Unit 2 containment entry to evaluate the inoperable personnel air lock door.- The safety contrd.3 were comprehensive for the entry into the subatmospheric containmen '

Additional oxygen and breathing apparatuses were available. A work party communicator and two rescue personnel were available. -The requirements of NPDAP 3.3 were satisfie i

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Radiological maps and radiation area postings for the Unit 2 primary auxiliary building were accurate. A containment entry was safely performe .S2 Status of Security Facilities and Equipment

- S Security Response to Winter Weather Conditions

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l Inspection Scooe (71750)

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.The inspectors reviewed the effects of the early January storms (snow, ice, and freezing l

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l rain) on the security system and resulting compensatory measures taken. . Security personnel were interviewed and walkdowns of the perimeter fences were performe l Observations and Findinas l

The snow, ice, and freezing rain had minimal impact on the security system. Additional l security guards were posted at several parameter zones for short time periods during  ;

heavy precipitation or during snow removal. However, the total out of service time for ,

this period was normal compared to mild weather conditions. Compensatory measures I (posting of personnel) were appropriate. Security camras were also minimally impacted due to the robust design which includes a heated enclosure for the camera.

t ' Conclusions .

l - The security system was minimally impacted by the storms in early January. The

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i performance was attributed in part to the robust design of the system. Compensatory measures taken were appropriate.

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V. Mananoment Meetinos )

X1 Exit Meeting Summary The inspectors presented the inspection results to members of plant management at the conclusion of the inspection on February 16,1999. The licensee acknowledged the I findings presente The licensee did not indicate that any of the information presented at the exit meeting j was proprietar X2 Duquesne Light Company Management Changes I

Mr. Richard D. Brandt resigned as Vice President of Operations Support, effectiv .

February 4,1999. His responsibilities were assumed by Mr. James E. Cross, President l

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- Generation Group and Chief Nuclear Officer, and Mr. Sushil C. Jain, Senior Vice President, Nuclear Services Grou )

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750 Plant Support IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Follow-up - Operations IP 92902: Follow-up - Maintenance IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-334(412)/98-11-01 VIO Corrective Action Breakdown Regarding Meteorological Monitoring Instrument Channel Calibration Deficiencie (Section 08.1)

Opened and Closed 50-334(412)/98-11-02 NCV inadequate Maintenance and Post Maintenance Test on i 1 "B" Control Room Emergency Ventilation System Train l Charcoal Filter. (Section M1.3)

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Closed 50-334/98-29 LER Inadequate Meteorological Instrumentation Calibration Leads to Failure to Comply with TS. (Section 08.2)

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LIST OF ACRONYMS USED C -

BVT.- Beaver Valley Test CARB . Correction Action Review Board CFR Code of Federal Regulations

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CR Condition Report CREVS- Control Room Emergency Ventilation System i ERT Event Review Team LCO Limiting Condition of Operation LER Licencee Event Report-LHS! Low Head Safety injection MWR Maintenance Work Request NCV Non-Cited Violation NPDAP Nuclear Power Division Administrative Procedures NRC Nuclear Regulatory Commission e NSRB Nuclear Safety Review Board NSS Nuclear Shift Supervisor ORC Off-Site Review Committee OST Operational S veillance Test PAB Primary Auxiliary Building PDR - Public Document Room PM Preventive Maintenance PMT Post Maintenance Testing QSU Quality Services Unit RP&C Radiological Protection and Chemistry SSC System, Structure and Ccmponent TS Technical Specification UFSAR Updated Final Safety Analysis Report VIO Violation l

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