L-97-043, Responds to NRC Re Violations Noted in Insp Repts 50-334/97-05 & 50-412/97-05 on 970818.Corrective Actions: Management Expectations Re Use of Current Programs for Troubleshooting Energized Equipment Have Been Reinforced

Responds to NRC Re Violations Noted in Insp Repts 50-334/97-05 & 50-412/97-05 on 970818.Corrective Actions: Management Expectations Re Use of Current Programs for Troubleshooting Energized Equipment Have Been Reinforced

ML20212A538
Person / Time
Site:	Beaver Valley
Issue date:	10/15/1997
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-334-97-05, 50-334-97-5, 50-412-97-05, 50-412-97-5, L-97-043, L-97-43, NUDOCS 9710240026
Download: ML20212A538 (5)

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{ y Vdey Power Statbn SNpptrigport. FW 15017 0 % 4 E N..u.re October 15, 1997 raxNU$N U"U.75.an L-97-043 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 50-334/97-05 and 50-412/97-05 Amended Reply to Notice of Violation On September 17,1997, Duquesne Light Company provided a response to a Notice of Violation (NOV) transmitted with the subject inspection report by NRC carrespondence dated August 18, 1997, Following discussion with NRC staff, it was I

decided to submit an amended response to address areas described within the NOV that were not properly addressed. A condition report has been written to evaluate the causes for the inadequate NOV response submitted to the NRC by letter dated September 17, 1997, Therefore, the attached amended response is provided which supersedes the September 17,1997 (letter number L-97-025) in its entirety.

If there are any questions concerning this response, please contact Mr. J. Arias at (412) 393-5203.

Sincerely, Sushil C. Jain Attachment t jb J !

c: Mr. D. M. Kern, Sr. Resident Inspector - I Mr. H. J. Miller, NRC Region I Administrator Mr. D. S. Brinkman, Sr. Project Manager Mr. P. W. Eselgroth, Chief, Reactor Projects Branch No. 7, Region 1 DMIVERING Q U All1Y 9710240026 971015 .'

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DUQUESNE LIGHT COMPANY Nuclear Power Divis'.cn l

Beaver Valley Power Station, Unit No. I and No. 2 Amended Reniv to Notice of Violation Integrated Inspection Report 50-334/97 05 and 50-412/97-05 Letter Dated August 18,1997 VIOLATION A (Severity Level IV, Supplement 1)

Description of Violativa (50-334(412)/97-05-05) 10 CFR 50, Appendix B, Criterion XVI,"Co:Tective Action," states in part," Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconfonnances are promptly identified and corrected.- In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."

Technical Specification 6.8.1.a requires that, " Written procedures shall be properly established, implemented, and maintained covering...the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Rev. 2, February 1978 "

Regulatory Guide 1.33 requires that " Maintenance activities that can affect the performance of safety-related equipment should be properly pre-planned and performed

- in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances..."

Contrary to the above, previous corrective actions were inadequate in that o i July 1, 1997, an unplanned engineered safety feature actuation, specifically, the P-12 High Steam Flow - Safety Injection Block Permissive Interlock, occurred during troubleshooting activities on th Unit 1 main condenser steam dump system due to inadequate work instructions and poor operator communications. Corrective actions taken to address inadequate control of troubleshooting that resulted in an inadvertent actuation of the Control Room Emergency Air Breathing Pressurization System on October 6,1996, and inadvertent opening of two Unit 2 atmospheric steam dumps during secondary process rack troubleshooting on February 3,1997, were ineffective in that they failed to preclude the July I event, y

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Reply _to Notice of Violation -

Inspection Report 50-334/97-05 and 50-412/97-05 Page 2 ,

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Reasons for the Vi61anqu Prior to the implementation of the CR Program, the site corrective action programs did I

- not provide a formal means of evaluating the extent of condition for plant problems, f

Without this extent of condition review, the corrective action programs did not :  !

- consistently assure that similar events were identified when developing corrective actions.

The reason for the July 1,- 1997, event was a human performance problem that resulted in )

the work package not containing adequate troubleshooting information necessary to - i remove the Unit 1 main condenser steam dump system from service without affecting other operating equipment. The existing work planning procedure (MPUAP 7.1) has an attachment which provides guidance on troubleshooting. This guidance was not fully utilized during the work planning process for the Maintenance Work Request (MWR)--  ;

generated for the work on the Unit I steam dump system on Ju'y 1,1997. In addition, H insufficient understanding and communication of the work activity between the Nuclear Shift Supervisor and the Reactor Operator contributed to the event.

1 Corrective Actions Taken and Results Achieved Management expectations regarding the use of current programs -for troubleshooting - l energized equipment have been reinforced with planners, instrument & control (I&C) and electrical technicians. This item is complete.

The CR Program, which was implemented on January 1,1997, now provides a fonnal graded approach of evaluating plant problems. An extent of condition review is required Lfor condition reports that have been categorized as a Level 3 or above.

? Management expectations for the Nuclear Shift Supervisor / Assistant Nuclear Shift Supervisor (NSS/ANSS) review and approval of MWRs were issued to _ Unit 1 1 L NSS/ANSSs on September 22,1997, via night orders. The NSS/ANSSs were instmeted to use in-depth questioning of the work party leader prior to approval of the MWR. If the work instructions are vague or ofinsufficient detail, then approval of the work is to

' be refused.

Corrective Actions to Prevent Further Violations i Details of the July 1,1997, event were discussed in a maintenance training brief, which was prepared and distributed to planners, I&C and electrical technicians and supervisors.

This training brief described the July 1,1997, event and instructed personnel that when working on energized equipment, they must assure themselves that they fully understand

l' u , . g, a Reply to Notice of Violation

-Inspection Repon 50-334/97-05 and 50-412/97-05 L Page 3 . >

L - what the effects of the activity will bc . 'i the plant.- This training was completed by - J September 30,1997.

With regard to the February 3,1997, event,'it was determined that Beaver Valley Unit 2 has three uniquely designed 7300 cards installed in the process racks f or the atmospheric-steam dump valves [2SVS-PCV101 A,B,C). Due to the unique design of these cards, it is

possible that an inadvenent actuation of the atmospheric steam dump valves could occur during a restoration of power to these controller cards. Therefore, warning labels have -

been placed near the cards to caution plant personnel of the potential for inadvertent )

actuation of the atmospheric steam dump valves.- In addithn, the applicable Operating -l Manual procedures for restoring vital bus power have been cevised to address the potential for inadvedent actuation of these valves.

i In addition, it was recently discovered that some of the work instructions perfonned

-during the February 3,1997, event were not retained in the work package. Cendition Report 971788 was written on October 10,1997, to evaluate this problem.

The Operating Manual (1/2 OM-48.1.D.P) was revised effective October 9,1997, to include NSS/ANSS responsibilities for the review and approval of MWRs. This revision

-incorporated the management expectations for NSS/ANSS review of MWRs provided by -

the September 22 1997, night orders and a requirement to inform the Reactor Operator -

of the authorization of an MWR which could affect plant equipment under the control of the Control Room Operators.

A self assessment of the site troubleshooting process was completed on September 29, 1997. As a result of this self assessment, a new site administrative procedure (NPDAP) will be developed that defines the systematic approach for troubleshooting. This new procedure _will proside for:

. establishing levels for troubleshooting activities and defme the appropriate management reviews and approvals for each level

. use of a troubleshooting checklist e requirements for developing a troubleshooting plan and work instructions

. - documenting sources ofinformation used to develop the troubleshooting plan

' including the review of applicable drawings

• performingjob pre-briefings the responsibilities of the site organizations involved in the troubleshooting activity including Operations review and approval and notifications of the operating crew.

A troubleshooting control fonn will be developed and implemented by November 1, 1997. This fonn will be included with the troubleshooting work package and will

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1 Reply to Notice of Violation inspection Report 50 334/97-05 cnd 50-412/97-05 Page 4 ,

provide a plan for troubleshooting activities and include control room staff notification and sign-off.

The General Manager, Maintenance Program Unit issued a letter on October 13,1997, to maintenance rupervision derming troubleshooting and the extent of reviews to be

--accomplished prior to perfonning troubleshooting activities.

An effectiveness review of the troubleshooting program will be performed in the second quarter of 1998. Deficiencies identified as a result of this effectiveness review will be evaluated by the Condition Report Program.

Date When Full Comoliance Will Be Achieved A troubleshooting control form will be implemented by November 1,1997.

l. The NPDAP on troubleshooting will be developed and approved by December 31,1997.

Training on the new troubleshooting NPDAP will be completed by Januaiy 31,1998.

V The effectiveness review of the troubleshooting program will be perfonned by June 30, 1998.

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