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Category:CORRESPONDENCE-LETTERS
MONTHYEARIR 05000412/19990071999-10-21021 October 1999 Refers to Special Team Insp 50-412/99-07 Conducted from 990720-29 & Forwards Nov.Two Violations Identified.First Violation Involved Failure to Implement C/A to Prevent Biofouling of Service Water System ML20217M1591999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates L-99-143, Informs That Subsequent Review of Approval Ltrs & SE for Relief Requests 1TYP-2-B5.40-1 (Rev 0),BV1-RV-AUG (Rev 1), BV2-RV-AUG (Rev 1),BV3-IWA-1 (Rev 1) & BV3-IWA-2 (Rev 1) Identified Erroneous Statements Which Dl Wishes to Correct1999-10-11011 October 1999 Informs That Subsequent Review of Approval Ltrs & SE for Relief Requests 1TYP-2-B5.40-1 (Rev 0),BV1-RV-AUG (Rev 1), BV2-RV-AUG (Rev 1),BV3-IWA-1 (Rev 1) & BV3-IWA-2 (Rev 1) Identified Erroneous Statements Which Dl Wishes to Correct L-99-152, Submits Relief Request BV3-N-533-1,rev 0,requesting Use of ASME Approved Code Case N-553-1, Alternative Requirements for VT-2 Visual Examination of Class 1,2 & 3 Insulated Pressure Retaining Bolted Connections1999-10-11011 October 1999 Submits Relief Request BV3-N-533-1,rev 0,requesting Use of ASME Approved Code Case N-553-1, Alternative Requirements for VT-2 Visual Examination of Class 1,2 & 3 Insulated Pressure Retaining Bolted Connections ML20217C6741999-10-0808 October 1999 Forwards RAI Re Licensee 970128 Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, . Response Requested within 60 Days of Receipt of Ltr L-99-151, Responds to NRC Re Violations Noted in Insp Rept 50-412/99-07.Corrective Actions:Condition Repts Were Written for Listed Issues So That Repts Could Be Addressed Using BVPS Corrective Action Program1999-10-0707 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-412/99-07.Corrective Actions:Condition Repts Were Written for Listed Issues So That Repts Could Be Addressed Using BVPS Corrective Action Program ML20217E0301999-10-0707 October 1999 Forwards Insp Repts 50-334/99-06 & 50-412/99-06 on 990809-13 & 990823-27.Violation Noted Involving Failure to Correctly Translate Design Change Re Pertinent Operating Logs & Plant Equipment Labeling ML20212M2661999-09-30030 September 1999 Forwards Order Approving Transfer of Licenses for Beaver Valley from Dlc to Pennsylvania Power Co & Approving Conforming Amends in Response to 990505 Application ML20212K8071999-09-30030 September 1999 Informs That on 990916,NRC Staff Completed mid-cycle Plant Performance Review (PPR) of Facility.Staff Conducted Reviews of All Operating NPPs to Integrate Performance Info & to Plan for Insp Activities at Facility ML20216J9621999-09-30030 September 1999 Forwards Insp Repts 50-334/99-05 & 50-412/99-05 on 990725-0904.Two Violations Noted & Being Treated as Ncvs.One Violation Re Failure to Follow Operation Manual Procedure Associated with Configuration Control Identified L-99-149, Informs NRC That Items Identified in 990629 Response to GL 98-01 Have Been Completed.Attached Table Submitted with Has Been Updated to Reflect Completion1999-09-28028 September 1999 Informs NRC That Items Identified in 990629 Response to GL 98-01 Have Been Completed.Attached Table Submitted with Has Been Updated to Reflect Completion L-99-148, Notifies NRC of License Withdrawal of M Linch,License SOP-11478 IAW 10CFR50.74.M Linch Resigned from Employment at Bvps,Effective 9908171999-09-24024 September 1999 Notifies NRC of License Withdrawal of M Linch,License SOP-11478 IAW 10CFR50.74.M Linch Resigned from Employment at Bvps,Effective 990817 ML20212G0601999-09-23023 September 1999 Forwards Answer of Duquesne Light Co to Petition to Waive Time Limits & Suppl Comments of Local 29, Intl Brotherhood of Electrical Workers.Copies of Answer Have Been Served to Parties & Petitioner by e-mail or Facsimile ML20212C5521999-09-21021 September 1999 Forwards for Filing,Answer to Firstenergy Nuclear Operating Co & Pennsylvania Power Co in Opposition to Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers L-99-144, Forwards NRC Form 536 Which Addresses Util Proposed Operator Licensing Exam Schedule,In Response to Administrative Ltr 99-031999-09-20020 September 1999 Forwards NRC Form 536 Which Addresses Util Proposed Operator Licensing Exam Schedule,In Response to Administrative Ltr 99-03 ML20212B3291999-09-16016 September 1999 Forwards for Filing,Petition to Waive Time Limits in 10CFR2.1305 & Supplemental Comments of Local 29,Intl Brotherhood of Electrical Workers Re Beaver Valley Power Station,Units 1 & 2 L-99-134, Provides Addl Info to Support 990617 LAR 127,proposing Mods to Heatup,Cooldown & Overpressure Protection Curves.Info Is Provided to Formally Docket Info Discussed During 990820 Telcon with NRC1999-09-15015 September 1999 Provides Addl Info to Support 990617 LAR 127,proposing Mods to Heatup,Cooldown & Overpressure Protection Curves.Info Is Provided to Formally Docket Info Discussed During 990820 Telcon with NRC ML20211Q3431999-09-0808 September 1999 Informs That During 990903 Telcon Between L Briggs & T Kuhar,Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant,Unit 1.Insp Planned for Wk of 991115 ML20211Q5601999-09-0707 September 1999 Forwards Insp Rept 50-412/99-07 on 990720-29.Three Apparent Violations Noted & Being Considered for Escalated Ea. Violations Involve Failure to Implement C/As to Prevent bio- Fouling of Svc Water Sys L-99-138, Forwards Rev 37 to Issue 4 for BVPS Physical Security Plan (PSP) (Base Plan,Safeguards Contingency Plan & Training & Qualification Plan).Changes to Plan Are Listed.Encls Withheld Per 10CFR2.790(d)1999-09-0303 September 1999 Forwards Rev 37 to Issue 4 for BVPS Physical Security Plan (PSP) (Base Plan,Safeguards Contingency Plan & Training & Qualification Plan).Changes to Plan Are Listed.Encls Withheld Per 10CFR2.790(d) L-99-136, Forwards Data Point Library (Dpl) Changes,Iaw Provisions of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6, Administrative Implementation Requirements. Ten Listed Dpls Have Specific Setpoint Values Removed,Per Unit 2 Dpls1999-09-0202 September 1999 Forwards Data Point Library (Dpl) Changes,Iaw Provisions of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6, Administrative Implementation Requirements. Ten Listed Dpls Have Specific Setpoint Values Removed,Per Unit 2 Dpls L-99-098, Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods1999-09-0202 September 1999 Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods L-99-137, Forwards Issue 3,rev 3 to Bvps,Unit 1 Inservice Testing Program for Pumps & Valves. Encl 1 Provides Summary of IST Program Changes Which Have Been Incorporated Into Issue 3, Rev 31999-08-31031 August 1999 Forwards Issue 3,rev 3 to Bvps,Unit 1 Inservice Testing Program for Pumps & Valves. Encl 1 Provides Summary of IST Program Changes Which Have Been Incorporated Into Issue 3, Rev 3 L-99-022, Forwards Issue 2,Rev 1 to Bvps,Unit 2 Inservice Testing (IST) Program for Pumps & Valves. Summary of Changes,Encl1999-08-31031 August 1999 Forwards Issue 2,Rev 1 to Bvps,Unit 2 Inservice Testing (IST) Program for Pumps & Valves. Summary of Changes,Encl L-99-012, Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B1999-08-30030 August 1999 Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B L-99-037, Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change1999-08-30030 August 1999 Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change L-99-132, Forwards fitness-for-duty Program Six Month Rept for 990101-990630 for Bvps,Units 1 & 21999-08-26026 August 1999 Forwards fitness-for-duty Program Six Month Rept for 990101-990630 for Bvps,Units 1 & 2 05000412/LER-1999-007, Forwards LER 99-007-00, Forced Shutdown Due to Inoperable EDG, Per 10CFR50.73(a)(2)(i).Rept Is Delayed Due to Util Needing Addl Three Days to Address Event Issues on Reportability & Provide Addl Safety Implications Info1999-08-19019 August 1999 Forwards LER 99-007-00, Forced Shutdown Due to Inoperable EDG, Per 10CFR50.73(a)(2)(i).Rept Is Delayed Due to Util Needing Addl Three Days to Address Event Issues on Reportability & Provide Addl Safety Implications Info ML20211A5111999-08-18018 August 1999 Forwards Insp Repts 50-334/99-04 & 50-412/99-04 on 990613- 990724.One Violation Noted & Treated as Non-Cited Violation Involved Failure to Maintain Containment Equipment Hatch Closed During Fuel Movement L-99-127, Provides Response to NRC Ltr Requesting Review & Comment of NRC Reactor Vessel Structural Integrity Database by 990901.Inconsistencies Noted in Way Data Characterizes Condition of Reactor Vessel1999-08-17017 August 1999 Provides Response to NRC Ltr Requesting Review & Comment of NRC Reactor Vessel Structural Integrity Database by 990901.Inconsistencies Noted in Way Data Characterizes Condition of Reactor Vessel L-99-124, Requests Withdrawal of Editorial Changes That Do Not Pertain to Transfer of Operating Authority or Plant Ownership That Are Proposed in LARs 269 & 144.Revised mark-up License Pages Reflecting Changes,Attached1999-07-30030 July 1999 Requests Withdrawal of Editorial Changes That Do Not Pertain to Transfer of Operating Authority or Plant Ownership That Are Proposed in LARs 269 & 144.Revised mark-up License Pages Reflecting Changes,Attached L-99-121, Submits Data Point Library (Dpl) Changes,Iaw Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,rev 1,Section 3.6, Administrative Implementation Reqiurements1999-07-28028 July 1999 Submits Data Point Library (Dpl) Changes,Iaw Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,rev 1,Section 3.6, Administrative Implementation Reqiurements L-99-118, Forwards Response to NRC AL 99-02,request for Info Re Estimate of Number of New Licensing Actions Expected to Be Submitted in Fy 2000 & 20011999-07-25025 July 1999 Forwards Response to NRC AL 99-02,request for Info Re Estimate of Number of New Licensing Actions Expected to Be Submitted in Fy 2000 & 2001 L-99-120, Forwards Annual Rept of Facility Changes,Tests & Experiments for BVPS Unit 1,IAW 10CFR50.59.Rept Provides Brief Description of Each Facility & Procedure Change & Summary of Safety Evaluations1999-07-22022 July 1999 Forwards Annual Rept of Facility Changes,Tests & Experiments for BVPS Unit 1,IAW 10CFR50.59.Rept Provides Brief Description of Each Facility & Procedure Change & Summary of Safety Evaluations L-99-119, Forwards Rev 17 to UFSAR for Beaver Power Station,Unit 1. Submittal Reflects Changes to Facility & Procedures as Described in UFSAR That Were Completed During Annual Reporting Period Endinig 9901221999-07-20020 July 1999 Forwards Rev 17 to UFSAR for Beaver Power Station,Unit 1. Submittal Reflects Changes to Facility & Procedures as Described in UFSAR That Were Completed During Annual Reporting Period Endinig 990122 L-99-113, Forwards Final,Typed TS Pages for LARs 262 & 135,previously Submitted with Editorial Changes Identified by1999-07-15015 July 1999 Forwards Final,Typed TS Pages for LARs 262 & 135,previously Submitted with Editorial Changes Identified by L-99-111, Forwards Revised Final Typed Pages for LARs 109 & 115, Previously Submitted by 990615 & 28 Ltrs.Revised Pages Replace Those Previously Provided for LARs 109 & 115.With Summary of Editorial Changes1999-07-15015 July 1999 Forwards Revised Final Typed Pages for LARs 109 & 115, Previously Submitted by 990615 & 28 Ltrs.Revised Pages Replace Those Previously Provided for LARs 109 & 115.With Summary of Editorial Changes L-99-112, Responds to NRC Questions Made During 990518 Meeting with Util Re LARs 220 & 88,for Bvps,Units 1 & 2.Copy of Ltr DLC-99-743,which Is non-proprietary Version of DLC-96-310 & Westinghouse Technical Bulletin ESBU-TB-96-07-R0 Also Encl1999-07-14014 July 1999 Responds to NRC Questions Made During 990518 Meeting with Util Re LARs 220 & 88,for Bvps,Units 1 & 2.Copy of Ltr DLC-99-743,which Is non-proprietary Version of DLC-96-310 & Westinghouse Technical Bulletin ESBU-TB-96-07-R0 Also Encl L-99-110, Forwards Changes to ERDS for Unit 1,IAW Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.61999-07-14014 July 1999 Forwards Changes to ERDS for Unit 1,IAW Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6 ML20209G5701999-07-12012 July 1999 Discusses Closure of TACs MA0525 & MA0526 Re Response to RAI Concerning GL 92-0,Rev 1,Suppl 1, Rv Structural Integrity. Info in Rvid Revised & Released as Ver 2 as Result of Review of Response ML20207H6621999-07-0808 July 1999 Forwards RAI Re Util 981112 Response to IPEEE Evaluations for Plant,Units 1 & 2.RAI Was Discussed During 990628 Telcon in Order to Ensure Clear Consistent Understanding by All Parties of Info Needed L-99-105, Forwards Response to NRC 990420 RAI Re Previous Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves1999-07-0808 July 1999 Forwards Response to NRC 990420 RAI Re Previous Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20209D8191999-07-0707 July 1999 Forwards Insp Repts 50-334/99-03 & 50-412/99-03 on 990502- 0612.No Violations Noted.Program for Maintaining Occupational Exposures as Low as Reasonably Achievable (ALARA) & for Training Personnel,Generally Effective L-99-109, Forwards Inservice Insp Ninety-Day Rept Bvps,Unit 2 Outage 7,Year 1999, IAW ASME Boiler & Pressure Vessel Code,Section Xi,Article IWA-62301999-07-0707 July 1999 Forwards Inservice Insp Ninety-Day Rept Bvps,Unit 2 Outage 7,Year 1999, IAW ASME Boiler & Pressure Vessel Code,Section Xi,Article IWA-6230 L-99-108, Requests Withdrawal of Change Proposed for TS Bases Page B 3/4 2-2 from LARs 1A-262 & 2A-135,originally Submitted by Licensee to NRC1999-07-0707 July 1999 Requests Withdrawal of Change Proposed for TS Bases Page B 3/4 2-2 from LARs 1A-262 & 2A-135,originally Submitted by Licensee to NRC L-99-104, Responds to GL 98-01,Suppl 1, Y2K Readiness at Nuclear Power Plants. Disclosure Rept Encl1999-06-29029 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness at Nuclear Power Plants. Disclosure Rept Encl L-99-093, Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.51999-06-25025 June 1999 Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.5 L-99-102, Forwards Typed,Final TS Pages for LARs 259 & 131.Summary of Description of Plant Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages,Encl1999-06-22022 June 1999 Forwards Typed,Final TS Pages for LARs 259 & 131.Summary of Description of Plant Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages,Encl L-99-101, Submits Response to NRC Oral RAI Concerning Qualifications for Senior Nuclear Executive Ref in 10CFR50.80 Submittal1999-06-22022 June 1999 Submits Response to NRC Oral RAI Concerning Qualifications for Senior Nuclear Executive Ref in 10CFR50.80 Submittal L-99-062, Forwards Final TS Pages for LARs 262 & 135,including Summary Description of Plants Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages1999-06-17017 June 1999 Forwards Final TS Pages for LARs 262 & 135,including Summary Description of Plants Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARL-99-152, Submits Relief Request BV3-N-533-1,rev 0,requesting Use of ASME Approved Code Case N-553-1, Alternative Requirements for VT-2 Visual Examination of Class 1,2 & 3 Insulated Pressure Retaining Bolted Connections1999-10-11011 October 1999 Submits Relief Request BV3-N-533-1,rev 0,requesting Use of ASME Approved Code Case N-553-1, Alternative Requirements for VT-2 Visual Examination of Class 1,2 & 3 Insulated Pressure Retaining Bolted Connections L-99-143, Informs That Subsequent Review of Approval Ltrs & SE for Relief Requests 1TYP-2-B5.40-1 (Rev 0),BV1-RV-AUG (Rev 1), BV2-RV-AUG (Rev 1),BV3-IWA-1 (Rev 1) & BV3-IWA-2 (Rev 1) Identified Erroneous Statements Which Dl Wishes to Correct1999-10-11011 October 1999 Informs That Subsequent Review of Approval Ltrs & SE for Relief Requests 1TYP-2-B5.40-1 (Rev 0),BV1-RV-AUG (Rev 1), BV2-RV-AUG (Rev 1),BV3-IWA-1 (Rev 1) & BV3-IWA-2 (Rev 1) Identified Erroneous Statements Which Dl Wishes to Correct L-99-151, Responds to NRC Re Violations Noted in Insp Rept 50-412/99-07.Corrective Actions:Condition Repts Were Written for Listed Issues So That Repts Could Be Addressed Using BVPS Corrective Action Program1999-10-0707 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-412/99-07.Corrective Actions:Condition Repts Were Written for Listed Issues So That Repts Could Be Addressed Using BVPS Corrective Action Program L-99-149, Informs NRC That Items Identified in 990629 Response to GL 98-01 Have Been Completed.Attached Table Submitted with Has Been Updated to Reflect Completion1999-09-28028 September 1999 Informs NRC That Items Identified in 990629 Response to GL 98-01 Have Been Completed.Attached Table Submitted with Has Been Updated to Reflect Completion L-99-148, Notifies NRC of License Withdrawal of M Linch,License SOP-11478 IAW 10CFR50.74.M Linch Resigned from Employment at Bvps,Effective 9908171999-09-24024 September 1999 Notifies NRC of License Withdrawal of M Linch,License SOP-11478 IAW 10CFR50.74.M Linch Resigned from Employment at Bvps,Effective 990817 ML20212G0601999-09-23023 September 1999 Forwards Answer of Duquesne Light Co to Petition to Waive Time Limits & Suppl Comments of Local 29, Intl Brotherhood of Electrical Workers.Copies of Answer Have Been Served to Parties & Petitioner by e-mail or Facsimile ML20212C5521999-09-21021 September 1999 Forwards for Filing,Answer to Firstenergy Nuclear Operating Co & Pennsylvania Power Co in Opposition to Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers L-99-144, Forwards NRC Form 536 Which Addresses Util Proposed Operator Licensing Exam Schedule,In Response to Administrative Ltr 99-031999-09-20020 September 1999 Forwards NRC Form 536 Which Addresses Util Proposed Operator Licensing Exam Schedule,In Response to Administrative Ltr 99-03 ML20212B3291999-09-16016 September 1999 Forwards for Filing,Petition to Waive Time Limits in 10CFR2.1305 & Supplemental Comments of Local 29,Intl Brotherhood of Electrical Workers Re Beaver Valley Power Station,Units 1 & 2 L-99-134, Provides Addl Info to Support 990617 LAR 127,proposing Mods to Heatup,Cooldown & Overpressure Protection Curves.Info Is Provided to Formally Docket Info Discussed During 990820 Telcon with NRC1999-09-15015 September 1999 Provides Addl Info to Support 990617 LAR 127,proposing Mods to Heatup,Cooldown & Overpressure Protection Curves.Info Is Provided to Formally Docket Info Discussed During 990820 Telcon with NRC L-99-138, Forwards Rev 37 to Issue 4 for BVPS Physical Security Plan (PSP) (Base Plan,Safeguards Contingency Plan & Training & Qualification Plan).Changes to Plan Are Listed.Encls Withheld Per 10CFR2.790(d)1999-09-0303 September 1999 Forwards Rev 37 to Issue 4 for BVPS Physical Security Plan (PSP) (Base Plan,Safeguards Contingency Plan & Training & Qualification Plan).Changes to Plan Are Listed.Encls Withheld Per 10CFR2.790(d) L-99-136, Forwards Data Point Library (Dpl) Changes,Iaw Provisions of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6, Administrative Implementation Requirements. Ten Listed Dpls Have Specific Setpoint Values Removed,Per Unit 2 Dpls1999-09-0202 September 1999 Forwards Data Point Library (Dpl) Changes,Iaw Provisions of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6, Administrative Implementation Requirements. Ten Listed Dpls Have Specific Setpoint Values Removed,Per Unit 2 Dpls L-99-098, Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods1999-09-0202 September 1999 Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods L-99-137, Forwards Issue 3,rev 3 to Bvps,Unit 1 Inservice Testing Program for Pumps & Valves. Encl 1 Provides Summary of IST Program Changes Which Have Been Incorporated Into Issue 3, Rev 31999-08-31031 August 1999 Forwards Issue 3,rev 3 to Bvps,Unit 1 Inservice Testing Program for Pumps & Valves. Encl 1 Provides Summary of IST Program Changes Which Have Been Incorporated Into Issue 3, Rev 3 L-99-022, Forwards Issue 2,Rev 1 to Bvps,Unit 2 Inservice Testing (IST) Program for Pumps & Valves. Summary of Changes,Encl1999-08-31031 August 1999 Forwards Issue 2,Rev 1 to Bvps,Unit 2 Inservice Testing (IST) Program for Pumps & Valves. Summary of Changes,Encl L-99-037, Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change1999-08-30030 August 1999 Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change L-99-012, Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B1999-08-30030 August 1999 Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B L-99-132, Forwards fitness-for-duty Program Six Month Rept for 990101-990630 for Bvps,Units 1 & 21999-08-26026 August 1999 Forwards fitness-for-duty Program Six Month Rept for 990101-990630 for Bvps,Units 1 & 2 05000412/LER-1999-007, Forwards LER 99-007-00, Forced Shutdown Due to Inoperable EDG, Per 10CFR50.73(a)(2)(i).Rept Is Delayed Due to Util Needing Addl Three Days to Address Event Issues on Reportability & Provide Addl Safety Implications Info1999-08-19019 August 1999 Forwards LER 99-007-00, Forced Shutdown Due to Inoperable EDG, Per 10CFR50.73(a)(2)(i).Rept Is Delayed Due to Util Needing Addl Three Days to Address Event Issues on Reportability & Provide Addl Safety Implications Info L-99-127, Provides Response to NRC Ltr Requesting Review & Comment of NRC Reactor Vessel Structural Integrity Database by 990901.Inconsistencies Noted in Way Data Characterizes Condition of Reactor Vessel1999-08-17017 August 1999 Provides Response to NRC Ltr Requesting Review & Comment of NRC Reactor Vessel Structural Integrity Database by 990901.Inconsistencies Noted in Way Data Characterizes Condition of Reactor Vessel L-99-124, Requests Withdrawal of Editorial Changes That Do Not Pertain to Transfer of Operating Authority or Plant Ownership That Are Proposed in LARs 269 & 144.Revised mark-up License Pages Reflecting Changes,Attached1999-07-30030 July 1999 Requests Withdrawal of Editorial Changes That Do Not Pertain to Transfer of Operating Authority or Plant Ownership That Are Proposed in LARs 269 & 144.Revised mark-up License Pages Reflecting Changes,Attached L-99-121, Submits Data Point Library (Dpl) Changes,Iaw Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,rev 1,Section 3.6, Administrative Implementation Reqiurements1999-07-28028 July 1999 Submits Data Point Library (Dpl) Changes,Iaw Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,rev 1,Section 3.6, Administrative Implementation Reqiurements L-99-118, Forwards Response to NRC AL 99-02,request for Info Re Estimate of Number of New Licensing Actions Expected to Be Submitted in Fy 2000 & 20011999-07-25025 July 1999 Forwards Response to NRC AL 99-02,request for Info Re Estimate of Number of New Licensing Actions Expected to Be Submitted in Fy 2000 & 2001 L-99-120, Forwards Annual Rept of Facility Changes,Tests & Experiments for BVPS Unit 1,IAW 10CFR50.59.Rept Provides Brief Description of Each Facility & Procedure Change & Summary of Safety Evaluations1999-07-22022 July 1999 Forwards Annual Rept of Facility Changes,Tests & Experiments for BVPS Unit 1,IAW 10CFR50.59.Rept Provides Brief Description of Each Facility & Procedure Change & Summary of Safety Evaluations L-99-119, Forwards Rev 17 to UFSAR for Beaver Power Station,Unit 1. Submittal Reflects Changes to Facility & Procedures as Described in UFSAR That Were Completed During Annual Reporting Period Endinig 9901221999-07-20020 July 1999 Forwards Rev 17 to UFSAR for Beaver Power Station,Unit 1. Submittal Reflects Changes to Facility & Procedures as Described in UFSAR That Were Completed During Annual Reporting Period Endinig 990122 L-99-111, Forwards Revised Final Typed Pages for LARs 109 & 115, Previously Submitted by 990615 & 28 Ltrs.Revised Pages Replace Those Previously Provided for LARs 109 & 115.With Summary of Editorial Changes1999-07-15015 July 1999 Forwards Revised Final Typed Pages for LARs 109 & 115, Previously Submitted by 990615 & 28 Ltrs.Revised Pages Replace Those Previously Provided for LARs 109 & 115.With Summary of Editorial Changes L-99-113, Forwards Final,Typed TS Pages for LARs 262 & 135,previously Submitted with Editorial Changes Identified by1999-07-15015 July 1999 Forwards Final,Typed TS Pages for LARs 262 & 135,previously Submitted with Editorial Changes Identified by L-99-112, Responds to NRC Questions Made During 990518 Meeting with Util Re LARs 220 & 88,for Bvps,Units 1 & 2.Copy of Ltr DLC-99-743,which Is non-proprietary Version of DLC-96-310 & Westinghouse Technical Bulletin ESBU-TB-96-07-R0 Also Encl1999-07-14014 July 1999 Responds to NRC Questions Made During 990518 Meeting with Util Re LARs 220 & 88,for Bvps,Units 1 & 2.Copy of Ltr DLC-99-743,which Is non-proprietary Version of DLC-96-310 & Westinghouse Technical Bulletin ESBU-TB-96-07-R0 Also Encl L-99-110, Forwards Changes to ERDS for Unit 1,IAW Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.61999-07-14014 July 1999 Forwards Changes to ERDS for Unit 1,IAW Requirements of 10CFR50,App E,Section VI.3.a & NUREG-1394,Rev 1,Section 3.6 L-99-105, Forwards Response to NRC 990420 RAI Re Previous Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves1999-07-0808 July 1999 Forwards Response to NRC 990420 RAI Re Previous Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves L-99-108, Requests Withdrawal of Change Proposed for TS Bases Page B 3/4 2-2 from LARs 1A-262 & 2A-135,originally Submitted by Licensee to NRC1999-07-0707 July 1999 Requests Withdrawal of Change Proposed for TS Bases Page B 3/4 2-2 from LARs 1A-262 & 2A-135,originally Submitted by Licensee to NRC L-99-109, Forwards Inservice Insp Ninety-Day Rept Bvps,Unit 2 Outage 7,Year 1999, IAW ASME Boiler & Pressure Vessel Code,Section Xi,Article IWA-62301999-07-0707 July 1999 Forwards Inservice Insp Ninety-Day Rept Bvps,Unit 2 Outage 7,Year 1999, IAW ASME Boiler & Pressure Vessel Code,Section Xi,Article IWA-6230 L-99-104, Responds to GL 98-01,Suppl 1, Y2K Readiness at Nuclear Power Plants. Disclosure Rept Encl1999-06-29029 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness at Nuclear Power Plants. Disclosure Rept Encl L-99-093, Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.51999-06-25025 June 1999 Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.5 L-99-102, Forwards Typed,Final TS Pages for LARs 259 & 131.Summary of Description of Plant Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages,Encl1999-06-22022 June 1999 Forwards Typed,Final TS Pages for LARs 259 & 131.Summary of Description of Plant Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages,Encl L-99-101, Submits Response to NRC Oral RAI Concerning Qualifications for Senior Nuclear Executive Ref in 10CFR50.80 Submittal1999-06-22022 June 1999 Submits Response to NRC Oral RAI Concerning Qualifications for Senior Nuclear Executive Ref in 10CFR50.80 Submittal L-99-062, Forwards Final TS Pages for LARs 262 & 135,including Summary Description of Plants Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages1999-06-17017 June 1999 Forwards Final TS Pages for LARs 262 & 135,including Summary Description of Plants Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 ML20195H4651999-06-16016 June 1999 Forwards for Filing Answer of Firstenergy Corp in Opposition to Petition for Leave to Intervene of Local 29, Intl Brotherhood of Electrical Workers. Copies of Answer Have Been Served Upon Parties & Petitioner by e-mail ML20195J5221999-06-16016 June 1999 Forwards Answer of Duquesne Light Co to Petition to Intervene of Local 29,International Brotherhood of Electrical Workers in Listed Matter.With Certificate of Svc L-99-100, Forwards Typed,Final TS Pages for LAR 109 Re Rcs.Summary Description of Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages Is Provided in Attachment B-1091999-06-15015 June 1999 Forwards Typed,Final TS Pages for LAR 109 Re Rcs.Summary Description of Editorial Changes Incorporated in Addition to Those Addressed in Previously Provided marked-up Pages Is Provided in Attachment B-109 L-99-095, Provides Addl Info to Support LARs 262 & 135,in Response to NRC 990527 Verbal Request.Info Describes Performance of Unit 1 Rod Position Indication Sys & Provides Some Background Info Re Normal Operation of Sys1999-06-15015 June 1999 Provides Addl Info to Support LARs 262 & 135,in Response to NRC 990527 Verbal Request.Info Describes Performance of Unit 1 Rod Position Indication Sys & Provides Some Background Info Re Normal Operation of Sys L-99-099, Requests Partial Withdrawal of LAR 120,which Requested Review of USQ Due to Increased Calculated Doses for Locked Rotor Event & Use of Unapproved Methodology for Evaluating Small Break LOCA Doses Involving W Natl Safety Advisory Ltr1999-06-14014 June 1999 Requests Partial Withdrawal of LAR 120,which Requested Review of USQ Due to Increased Calculated Doses for Locked Rotor Event & Use of Unapproved Methodology for Evaluating Small Break LOCA Doses Involving W Natl Safety Advisory Ltr ML20195H3731999-06-0303 June 1999 Forwards Petition to Intervene of Local 29,Intl Brotherhood of Electrical Workers in Matter of Firstenergy Nuclear Operating Co,For Filing L-99-090, Forwards Summary Review Completed to Verify Adequacy of Design Basis Accident Thermal Overpressure Protection for BVPS Unit 2 Containment Penetrations,Per Request1999-06-0202 June 1999 Forwards Summary Review Completed to Verify Adequacy of Design Basis Accident Thermal Overpressure Protection for BVPS Unit 2 Containment Penetrations,Per Request L-99-086, Forwards Bvps,Unit 2 SG Exam Rept for Aug 1998.Rept Provided to Document Results of SG Eddy Current Exams Performed in Aug 1998.Summary of Insps Provided in Encl 11999-05-28028 May 1999 Forwards Bvps,Unit 2 SG Exam Rept for Aug 1998.Rept Provided to Document Results of SG Eddy Current Exams Performed in Aug 1998.Summary of Insps Provided in Encl 1 L-99-089, Forwards Annual Financial Repts,Including Certified Financial Statements,Of Dqe,Firstenergy Corp,Ohio Edison Co,Pennsylvania Power Co,Cleveland Electric Illuminating Co & Toledo Edison Co,Iaw 10CFR50.71(b)1999-05-28028 May 1999 Forwards Annual Financial Repts,Including Certified Financial Statements,Of Dqe,Firstenergy Corp,Ohio Edison Co,Pennsylvania Power Co,Cleveland Electric Illuminating Co & Toledo Edison Co,Iaw 10CFR50.71(b) L-99-084, Forwards Revised marked-up TS & UFSAR Pages to 990303 LARs 259 & 131 Which Revised Qualifications for Operations Mgt & Incorporated Generic Position Titles in Ts.Encl Pages Incorporate NRC Requested Changes,Per Recent Telcon1999-05-27027 May 1999 Forwards Revised marked-up TS & UFSAR Pages to 990303 LARs 259 & 131 Which Revised Qualifications for Operations Mgt & Incorporated Generic Position Titles in Ts.Encl Pages Incorporate NRC Requested Changes,Per Recent Telcon L-99-082, Dockets Licensee Plan for Bvps,Unit 1,safety-related Small Bore Piping Evaluation Project Discussed in NRC 990311 Public Meeting at BVPS1999-05-17017 May 1999 Dockets Licensee Plan for Bvps,Unit 1,safety-related Small Bore Piping Evaluation Project Discussed in NRC 990311 Public Meeting at BVPS L-99-071, Notifies of License Withdrawal for J Scott,License SOP-11481,due to Resignation from Employment at BVPS1999-05-12012 May 1999 Notifies of License Withdrawal for J Scott,License SOP-11481,due to Resignation from Employment at BVPS 1999-09-03
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I J
ver Valley Power Station SNppingport PA 15077 0004 s .
Senior Vice President Fax 4) 64 -8 9 h we Division March 29, 1999 L-99-053 U. S. Nuclear Regulatory Commission
/ A ttention: Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 NRC Inspection Report 50-334/98-11,50-412/98-11 Reply to a Notice of Violation l
In response to NRC correspondence dated February 25,1999, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
Please contact Mr. Mark S. Ackerman at (412) 393-5203 if there are questions concerning this response.
Sincerely, b ,
Sushil C. Jain i c: - Mr. D. S. Collins, Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. W. D. Lanning, Director, Division of Reactor Safety, Region I
[' j Mr. H. J. Miller, NRC Region I Administrator 9904060123 990329 DEllVERING PDR ADOCK 05000334 g PDR _ g ggg79 ENERGV 0G0047
i -
l DUQUESNE LIGHT COMPANY Nuclear Power Division l Beaver Valley Power Station, Unit No.1 and No. 2 Reply to a Notice of Violation NRC Inspection Report 50-334/98-11, 50-412/98-11 Letter Dated February 25,1999 VIOLATION (Severity Level IV Supplement 1) l Description of the Violation l l
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from November 3,1998, until January 13,1999, the licensee failed to promptly identify and correct a condition adverse to quality in that investigation ofimproperly calibrated meteorological instrumentation channels was incomplete, corrective actions were untimely, and absent NRC involvement, the licensee would not have recognized and reported several related violations of technical specifications (TSs.) Specifically, on three occasions between April 22 and November 6,1998, wind speed and direction sensors were not calibrated as required by TS 4.3.3.4 (which required the sensors to be calibrated semi-annually.) On seven occasions during this same period, gaseous ;
effluent releases were performed in violation of TS 3.3.3.4.a (which required that radiological gaseous releases be suspended.) In addition, the prolonged instrument inoperability was not reported to the NRC as required by TS 3.3.3.4.b (which required a special report to be submitted to the NRC.) Past and current equipment inoperability was not properly evaluated until questioned by the inspectors on l January 13,1999. As a result, the licensee failed to identify and report the violations of TS 3.3.3.4.a and TS 3.3.3.4.b in a timely manner. Corrective actions for this issue failed to preclude recurrence, and on January 14,1999, wind direction sensor number 414 exceeded its required calibration frequency.
This is a Severity Level IV Violation Supplement 1.
f L
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Be!.ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 2 Discussion of the Violation The February 25,1999 Notice of Violation accurately characterizes the events related to the violation of 10 CFR 50 Appendix B Criterion 'GI " Corrective Action."
The Beaver Valley Power Station Quality Services Unit (QSU) performed an audit (BV-C-98-13) on the meteorological monitoring program from September through November 1998. Among several other observations, the QSU auditor determbed that 3 work orders may have installed wind sensors that had not been calibrated within the last 6 months as required by the techuical specifications.
The QSU auditor initiated a Technical Specification Interpretation (TSI) request on November 3,1998, to determine whether or not the technical specifications allowed for "on the shelf" storage without penalty against the semi-annual calibration time requirement. The TSI responder believed that the isue was purely historical and did not affect current operability. He also believed that QSU or the Safety and Licensing Department (SLD) would follow-up on reportability from a historical standpoint. Because the need for an answer did not appear urgent (no due date had been specified by QSU and none was required by procedure NPDAP 7.1 " Technical Specification Control Program"), the TSI responder elected to work on other TSIs that he considered a higher priority. !
The QSU auditor prepared and issued condition report (CR) 982223 on i December 18,1998, that identified the sensor calibration issue end stated that a l TSI had been previously submitted The CR did not clearly document that the TSI request and issue were now 6 weeks old.
The CR was hand carried to the unit Nuclear Shift Supervisor (NSS) at both units.
Each NSS asked if the situation affected operability of the current installation and the auditor replied, in essence, that he believed that current operability was not affected but it was not his responsibility to make the final determinatio...
Throughout the communications there was an uriderlying belief that the currently installed wind speed sensors were operable because a recent design change package (DCP 2166) had replaced the wind speed sensors and because calibration j documentstion associated with the work was checked by the Instrumentation and ]
Controls (I&C) supervisor and confirmed to be current. The NSS did not probe !
, the issue further or request to personally review calibration dams for verification.
l l
\
4 Beaver Velley Power Station, Unit No. I and No. 2 NRC Inspection Report 50 334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 3 The Unit 1 NSS then contacted SLD to discuss ! mediate reportability. SLD in iurn contacted I&C supervision and received assurance that the currently installed sensors were operable. No immediate reporting (i.e., per 10 CFR 50.72) was required. The CR was assigned to a SLD engineer for a ret.srtability determination and LER/special report preparation as necessary.
On December 31,1998, the assigned SLD engineer reviewed CR 982223 and determined the meteorological tower instrumentation in use prior to November 1998 had not met the technical specification criteria for calibration frequency.
Because this constituted a failure to perform a technical specification surveillance in the past, this was reportable as a condition prohibited by the plant technical specifications in accordance with Technical Specification Bases 4.0.3 and 10 CFR 50.73(a)(2)(i)(B). I&C was then requested to provide an expedited CR response to support the development of the associated LER submittal.
1 The CR response was completed on January 8,1999. The respon',e addressed the fact that the purchase order for the vendor did not specify sensor calibration frequency requirements and that the maintenance surveillance procedures needed to be revised to ensure that the sensors were calibrated within 60 days prior to installation. The CR response did not fully address previous inoperability/
reportability, and due to a date review error by the investigator, the response failed to detent that the calibration for one of the newly installed sensors (#414) was about to expire. The LER preparer used the CR response as the main source of information and thus also did not independemly add ess previous inoperability/
repertability. l On January 12,1999, Operations responded to the QSU auditor's TSI request by stating that an interpretation was not required due to the clarity of the calibration frequency requirement as stated in the technical specifications.
On January 13,1999, the I UR was presented to the Nuclear Safety Review Board (NSRB). The required qumum was present; however, an Operations representative and the CR investigator were not present, nor were they required to attend. The LER did not address potential violations of Technical Specification 3.3.3.4 action statements during the time frame when the wind speed sensors were inoperable due to expired calibrations. The NSRB suggested some minor changes )
but did not detect that there was a potential second basis for making this issue reportable per 10 CFR 50.73 for a condition prohibited by plant technical
Belver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 4 specifications. Questions from the NRC senior resident inspector following the meeting pro.mpted the NSRB members to request additional investigation to determine if Technical Specification 3.3.3.4 Action Statement "a" (prohibits gas decay tank discharges) or Action Statement "b" (requires a special report) had been violated when there were less than the required number of operable meteorolm,ical :
instruments.
The follow-up review by the SLD engineer identified seven instances during l which gas decay tank discharges were perfonned without the required number of j technical specification meteorological wind speed sensors being operable. At the time of tl'e discharges (prior to November 1998), the plant would not have been aware that the requirements were not met because the sensor calibration frequency issue had 'ot been ide itified.
The mow-up review also detected that sensor inoperability met requirements for submitting a special report to the NRC; however, no reports were submitted (again due to the condition not being detected.)
r ;
LER 1-98-029 was subsequently revised, reviewed by the NSRB, and submitted to I the NRC on January 18,1999. l l
On March 19,1999, a new condition report was written to document our discovery I that installed wind sensors were not calibrated over their entire wind speed service range but instead relied on an extrapolation assumption for part of the range. The !
sensors are currently inoperable due to this new issue. '
Reason for the Violation The violation occurred because of a failure to fully implement the corrective action program. The identified weaknesses include: i 1
a) promptness ofidentification and threshold for initiating a CR b) clarity of the issue as documented within initiated CRs c) condition report investigation completeness, including current and past operability and reportability implications d) initial corrective actions
Be:ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11,50-412/98-11
, Reply .to a Notice of Violation Page 5 l
The effects of these weaknesses were amplified by a less than desirable plant staff sensitivity to implications of technical specification requirements. The supporting details of these weaknesses as causes for the violation are given in the following discussion.
A. Condition Identification Delay The approximate 6 week delay in identifying the meteorological tower calibration problem in a condition report was caused by failure of plant staff to recognize the significance of the meteorological tower calibration question and initiate a ,
condition report. Although many of the individuals involved (QSU acting manager, I&C supervisor, I&C director, Maintenance manager) had attended technical specification training, the issue of the wind sensor calibration was not immediately recognized as a problem, in part, due to comfort with past practices.
The involved individuals from these groups failed to use their knowledge to relate the sensor calibration practice to a compliance issue.
In addition, the identification delay was partially caused by procedures that were not adequate for the situation. Specifically, clear direction was not provided in NPDAP 5.2 " Initiation of Condition Reports" on the proper thresheld for initiating a CR. In this case, the proper concern resolution path should have been tne condition report process, not the technical specification interpretation process. I A contributing factor was the absence of clear direction in NPDAP 7.1 " Technical Specification Control Program" for establishing appropriately prioritized due dates i based on issue significance. The procedure did not require the Technical ,
Specification Interpretation (TSI) request initiator to immediately write a condition I report if the request involved a suspected operability issue. Finally, NPDAP 7.1 !
did not require direct communication between the TSI request originator and an on-duty NSS when questioning the operability of existing systems, structures, or components. Supervisor involvement and communication were not aggressive enough to compensate for the procedural weaknesses (e.g., site management reviewing the quality services condition report did not immediately question the six week time period between issue discovery and condition report initiation.)
Also contributing to the identification delay was a mistaken belief by the plant staff that ti e as a historical issue with:t the potential to impact current s
operabilit, inis belief was, in part, becue 9CP 2166 had recently replaced the meteorological tower wind rpeed sensors. Finny, there was a lack of i
+
g Beav:r Vciley Power Station, Unit No. I and No. 2 )
NRC Inspection Report 50-334/98-11,50-412/98-11 1
, Reply.to a Notice of Violation Page 6 accountability because of enclear system ownership and inadequate priority on the meteorolog'.ical tower because ofits perceived low safety significance. ;
B. Condition Recurrence QSU identified the issue in a condition report on Decenber 18,1999. Once identified, the corrective action program failed to prevent recurrence, in part, because the Nuclear Shift Supervisor (NSS) was comfor.able with information ]
regarding DCP 2166. The NSS did not believe the condition report documented a current operability issue and, therefore, relied on the reports of others and did not request that the specific calibration dates or supporting documentation be provided to him. It is not uncommon for the NSS to rely on reports from others; however, a stronger questioning attitude on the part of the on-duty NSS on this issue could have identified the pending expiration of a sensor (#414) calibration.
Inadequate attention to detail and self-checking functions performed by Maintenance caused a subsequent incomplete condition report investigation. The condition report investigator missed information in the current calibration i documentation that should have caused him to detect that an installed sensor
(#414) calibration was nearing expiration.
C. Historical Operability and Reportability Reviews l
The historical operability (and corresponding reportability) reviews were inadequate because these responsibilities were not clearly delineated in station procedures.
l Corrective Actions Taken and Results Achieved i i
CR 990345 was written on February 16,1999, to document the overall condition
~
in the corrective action ptogram and to provide a rollup document referencing related corrective actions.
The original issue of the meteorological tower wind speed instrumentation calibration periodicity has been resolved. However, the meteorological tower wind speed instnimentation is currently inoperable due to additional issues discovered by the plant staff.
m ~w
E Beaver Valley Power Station, Unit No. I and No. 2 NRC Inspection Re. srt 50-334/98-11,50-412/93-11
, Reply,to a Notice of %1ation Page 7 Preventive actions to avoid further violations and to address the broader scope of the corrective action program issues are provided in the following section.
Corrective Actions to Avoid Further Violations A. Completed Actions
- 1. A review session has been conducted with the QSU staff to clarify management expectations concerning the prompt initiation of condition reports during ongoing quality services audits.
- 2. A " lessons learned" meeting was held within SLD to discuss the need to identify all criteria under which an event is reportable and to ensure historical (" backward look") reportability reviews are performed when necessary.
- 3. Condition report categorization and assignment duties are now performed by the Condition Assignment Board (CAB.) This format supports more thorough discussion of condition reports.
- 4. Maintenance procedures (IMSP-45.17-I and IMSP-45.17A-I) have been revised to require separate verification that the meteorological tower sensor calibration dates meet requirements.
B. Planned Actions
- 1. A memorandum will be issued to the plant staff to clarify management expectations regarding the need for a low threshold for initiating condition reports and for thorough investigations. The letter will emphasize the importance of the corrective action program and sensitivity to implications of technical specification i requirements.
- 2. A multi-discipline team review, under direction of the Sr. Vice ;
President, Nuclear Services, is in progress to examine the broader aspect of site sensitivity to technical specifications and effective use of the corrective action program. The focus of the review is the plant's:
a) sensitivity to implications of technical specification requirements, b) threshcld for writing condition reports, and,
Beaver Valley Power St2 tion, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11,50-412/98-11 j I
, Reply,to a Notice of Violation Page 8 c) thoroughness and completeness of condition report evaluations and corrective actions.
This will be done, in part, by: ,
a) analyzing Corrective Action Review Board (CARb) ejection ,
data b'l performing a sampling ofinvestigations and corrective actions for accuracy and completeness, paying special attention to condition reports related to technical specification issues c) reviewing technical specification interpretations and the Operations backlog for adequacy and significance d) reviewing the Operations logs for technical specification action statement entries to determine if condition reports were written as necessary e) performing a sampling of engineering memoranda related to technical specification issues, assessing sensitivity to technical specification compliance, and assessing whether condition reports were written when appropriate i f) conducting interviews with site personnel, assessing their un lerstanding of when to write condition reports and sensitivity to technical specification compliance g) conducting interview s with management to assess the extent of their involvement in the corrective action program h) reviewing corrective actions associated with response to this Notice of Violation i) providing causes, corrective actions, and recommendations to management for final closure of this issue 1
- 3. NPDAP 5.2 " Initiation of Condition Reports" will be revised to more clearly communicate management expectations for when it is I appropriate to initiate a condition report rather than using other mechanisms (e.g., a TSI request) to address an issue.
- 4. NPDAP 7.1 " Technical Specification Control Program" will be revised to require Operations to track technical specification
n Ber.ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11
, Reply, to a Notice of Violation Page 9 interpretation requests and establish requirements for prioritization and response times. As an added precaution, the revision will require a cendition report to be written and direct communication with an on-duty NSS when the operability status of existing systems, structures, or components is in question.
- 5. NPDAP 8.13 " Nuclear Safety Review Board" will be revised to require an Operations representative and the associated condition report investigator to attend NSRB meetings when LERs and NOVs are reviewed.
- 6. 'NPDAP 5.6 " Processing of Condition Reports" will be revised to clarify responsibilities for historical operability and reportability reviews associated with condition reports.
- 7. Department managers (QSU, Chemistry, Health Physics, Maintenance, Operations, System and Performance Engineering, and Nuclear Engineering) and the Condition Assignment Board (CAB) will present this event as a communications meeting case study. The focus of the meetings will be proper use of the corrective action program, technical specification compliance sensitivity, and the relationship of the meteorological tower to technical specifications and the emergency plan. !
- 8. This event will be reviewed as a case study with licensed Operations personnel as part oflicensed requalification training, with focus on responsibilities and expectations regarding Operations' role in condition report reviews, technical specification sensitivity, and use of the corrective action program.
- 9. Clear meteorological tower system ownership will be assigned to the System and Performance Engineering Department.
- 10. An assessment of technical specification systems will be performed to check for clear assignment of system ownership.
- 11. The NSRB Chairman will conduct a meeting with NSRB members and alternates to discuss LER and NOV review expectations.
w~.-
Beaver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11
, Reply to a Notice of Violation Page 10
- 12. QSU procedures will be revised, and training provided, to reflect management's expectations regarding the prompt initiation of condition reports during ongoing quality services audits.
- 13. ' Auditors fmm quality services will be provided technical specification training.
- 14. A review will be performed to identify additional groups to receive technical specification training.
- 15. A review team will evaluate the broader scope ofinstrumentation in the calibration program for similar issues to those identified with the meteorological tower wind speed sensors.
p_ qts When Full Compliance Will Be Achieved The original issue of the meteorological tower wind speed instrumentation calibration periodicity has been resolved. However, the meteorological tower wind speed instrumentation is currently inoperable due to additional issues discovered by the plant staff.
Preventive actions to avoid further violations and to address the broader scope of the corrective action program issues are in progress. The site memorandum to clarify Management expectations regarding condition report initiation and investigation will be issued by April 2,1999. The communications meetings to present this event as a case study will be completed by April 30,1999. The remaining corrective actions are scheduled to be completed by July 30,1999.
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