ML031210857
| ML031210857 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/30/2003 |
| From: | Vicinie S First Energy Services |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML031210771 | List: |
| References | |
| IR-03-006 | |
| Download: ML031210857 (8) | |
Text
Tabular results from the Expanded Extent of Condition for CR 02-02202 ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE Micropipets 1. C.M.-4.52 1. Grease plunger Quality Control
- 2. C.M.-9.10 2. Replace instrument On-line pH Analyzers Quality Control Preventive 1. C.M.-4.72A 1. Soak 20% ammonium bio-flouride soln. (1 minute)
Maintenance 2. C.M.-4.72B 2. Procedure
- 3. C.M.-9.10A
- 3. Replace electrode Electronic 1. C.M.-4.72A 1. Procedure
- 2. C.M.-4.72B 2. Vendor Repair
- 3. C.M.-9.10A 3. Replacement instrument Dissolved Oxygen Preventive 1/2CHM-ANA-4.43C Per Procedure Analyzers (Portable) Maintenance Calibration 1/2CHM-ANA-4.33 Saturated sponge CL-17 C12 Analyzer Preventive C.M.-4.48E Per Procedure (Outfall 001) Maintenance 1 Mo. Maint. C.M.-4.48E Per Procedure 3 Mo. Maint. C.M.-4.48E Per Procedure 1 Yr. Maint C.M.-4.48E Per Procedure Unscheduled C.M.-4.48E Per Procedure Quality Control C.M.-9.10 Notify Chemistry Supervision Balance Preventive Maint. C.M.-9.10 Notify MT&E program lead Calibration MT & E Program MT & E Program Thermometers
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE I&C Program I&C Program I&C Program Flow Meter I&C Program I&C Program I&C Program Env. Panel Troubleshooting C.M/4.75 Procedure includes a table that provides direction for 03-04894 This Condition Report was written to revise ISCO 2700 Autosampler routine maintenance. However two steps of the table the procedure and appropriately capture the vendor refer the user to an apparently uncontrolled vendor manual (if it is still needed). Supervisor Comments in manual. the Condition Report require additional Corrective Actions to be written for the Environmental & Chemistry Section to evaluate whether other instrument procedures direct the user to an uncontrolled vendor manual, and to revise as necessary.
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE Preventive 1. 1/2-CHM-ANA-4.191 Replace electrode Lab pH Meters Maintenance 2. C.M.-4.19C
- 3. C.M.-4.19E
- 4. C.M.-4.19F
- 5. C.M.-4.19G
- 6. C.M.-4.19H
- 7. C.M.-9.10 Standardization 1. 1/2-CHM-ANA-4.19I 1. Replace electrode
- 2. C.M.-4.19C 2. Purchase known standard
- 3. C.M.-4.19E
- 4. C.M.-4.19F
- 5. C.M.-4.19G
- 6. C.M.-4.19H
- 7. C.M.-9.10 Quality Control 1. 1/2-CHM-ANA-4.19I 1. Replace electrode
- 2. C.M.-4.19C 2. Purchase known standard
- 3. C.M.-4.19E
- 4. C.M.-4.19F
- 5. C.M.-4.19G
- 6. C.M.-4.19H
- 7. C.M.-9.10 Electronic 1. 1/2-CHM-ANA-4.19I 1. Vendor repair
- 2. C.M.-4.19C 2. Replace instrument
- 3. C.M.-4.19E
- 4. C.M.-4.19F
- 5. C.M.-4.19G
- 6. C.M.-4.19H
- 7. C.M.-9.10 Temperature C.M.-9.10 Check against MT&E (Thermometer)
Compensator Check Calibration Curve 1. C.M.-9.10 1. Complete new curve UV Spectrophotometers 2. Per Analysis 2. Purchase new lot procedure Curve Check 1. C.M.-9.10 1. Complete new curve
- 2. Per Analysis 2. Purchase new lot procedure
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE Quality Control 1. C.M.-9.10 1. Complete new curve
- 2. Per Analysis 2. Purchase new lot procedure Performance 1. C.M.-9.10 Per Procedure
- 2. C.M.-4.25
- 3. C.M.-4.25A
- 4. C.M.-4.25C
- 5. C.M.-4.24E
- 6. C.M.-4.81 Preventive 1. C.M.-9.10 1. Reagant grade water Maintenance 2. C.M.-4.25 2. Soft cloth
- 3. C.M.-4.25A
- 4. C.M.-4.25C
- 5. C.M.-4.24E
- 6. C.M.-4.81 Temperature Check 1. C.M.-4.46 Replace Drying Ovens 2. 1/2-CHM-ANA-4.63
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE Various used to Various EPA standards Per Beta or contractor programs.
Other Analytical Devices: analyze NPDES and and Beta Lab or There are analyses regulated waste contracted laboratory beyond the capability of samples (e.g., EPA procedures. Contract the BVPS Chemistry TCLP procedure for laboratory must provide Laboratory. Generally, metals) certification of these analyses are qualification during the performed by FENOCs procurement process.
Beta Laboratory-, ISO 9001 certified (ISO certification carries mandatory records management, procedures, and routine external audits).
NOTE: In the case where Beta Laboratory cannot perform the required analysis, the services are procured from a qualified laboratory.
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE 02-05301 For pH exceedance from the Unit 2 STP-Operating parameters 1-CHM-SAM-3.100H Neither plant has a preventive maintenance plan. Identified a need for an in-depth review of Unit 1 and Unit 2 Sewage evaluated by Repairs and maintenance are performed when a Treatment Plants 1-CHM-ADD-7.1 equipment and operating procedures was Environmental & condition is noticed, or when a component fails. needed by an experienced and qualified Chemistry sampling, 2-CHM-SAM-3.80C engineering firm.
- CA-05 was written to address that need, Certified Operator. 2-CHM-ADD-7.16 and is due 05/01/03/
When certain 02-08413 For hold tank overflow due to failure of lift parameters our found pumps at the Unit 2 STP, one corrective to be out of action was written to add surveillance specification, chemical steps to applicable procedures, and or mechanical another was written to address previous adjustments are made. ineffective corrective actions and address Physical Preventive power supply to the related warning Maintenance: There systems.
currently is no
- CA-02 Was written to add PM tour checks schedule for preventive for the Unit 2 STP. The action was maintenance on the completed on 2/25/03.
STPs or equipment.
- CA-5 was written for engineering to track the development of a conceptual design to address the identified power problems and potential re-routing of influent.
03-00540 For a release due to a frozen valve, mistakenly thought to be closed, thawed and caused a release to the Stormwater system at Unit 2 STP- the lack of PMs or mechanical verifications were identified as issues.
- CA-06 was written to add heat trace operability verification to the site winterization plan for both Unit 1 and Unit 2 STPs; due date is 4/21/03.
- CA-07 was written to have the PA DEP certified operator review current operating procedures review procedures and identify components, items, or issues that need to be routinely maintained, inspected, or surveilled. Additional corrective actions are expected to result.
ENVIRONMENTAL TABLE INSPECTION/
MAINTENANCE/ OUTSTANDING TESTING & MAINTENANCE ITEM GOVERNING PROCESS TESTING/MAINTENANCE/REPAIR PROCESS DOCUMENT CORRECTIVE ACTION(S)
TESTING TYPE Annual Inspection 1/2-ADM-0602 (Basis: Per procedure step, a Work Request for minor work Oil Tanks & Transformers 40CFR 112 & 25 PA would be generated for any deficiency noted.
Code) Documented on Transformers and oil tanks fall under BVPS operations 1/2-ADM-0602.F01 and maintenance programs. However, some of the oil tanks are further regulated by EPA and PA DEP- see additional requirements for them below.
Monthly Inspections 1/2-ADM-0602 (Basis: Per procedure step, a Work Request for minor work EPA & DEP Regulated 25 PA Code) would be generated for any deficiency noted. Any Storage Tanks Documented on 1/2- significant work on the tank, containment, or spill ADM-0602.F02 prevention must be contracted to a PA DEP Certified Tank Handler.
Operations Inspections 25 PA Code The Operations and In-Service inspections must be (Underground tanks) performed (contracted to) by a PA DEP Certified Tank and In-Service Handlers. The due dates for the inspections vary with Inspections type (AST, UST), and installation date. The due dates (Aboveground tanks) are provided by the PA DEP on the annual storage tank registration certificates. BVPS tracks the requirements and due dates currently via Condition Report 02-09959*.
The Corrective Actions include: 02-09959-17 (for UST) and 02-09959-22 (for AST).
- Some environmental tasks were previously tracked in the CATS system. Those items were identified and captured in CR-02-09959 upon retirement of CATS.
The FENOC Environmental Common Process team has agreed to use the Condition Report system (CREST) to continue task tracking until a final determination, throughout corporate FE, evaluates and provides guidance to perform the tracking elsewhere, e.g., SAP.
Security Table Area reviewed Procedure Acceptance Documentation? Comments/CR describing Criteria?
NRC Cornerstone NEI yes Yes- reviewed Performed an overview of process. Documents were IAW standards and the documents were traceable and in Indicators Guidelines proper storage as Sfgds Info. It is submitted to Reg Affairs and uses RAS-DR-011. RAS-DR-005 pg 25 of 31 is 99-02 rev2 the Protected Area Security Equip Performance Indicator.
No action required Protected Area Security RAS-DR-005 Yes Yes- reviewed Reviewed with the Equipment Maintenance Coordinator (EMC).
Equip Performance Also ref The EMC was very knowledgeable of the process and immediately produced all documentation requested. The Indicator. Physical Sec indicators IDS comp hrs records were stored IAW the guiding document (Non QA records) for a min of 3 yrs Plan Green- good CCTV comp hrs Any comp time is recorded in CAS along with the times and comp measures.
White- bad They are reviewed by the EMC, tracked and stored via two different media.
They are reviewed by the Mgr of Security then sent to Licensing for input to the PI plan. Negative trend noted in 99 has reversed and has been green No action required Explosive Detectors SP 5.1 yes Yes- reviewed Reviewed procedure and documentation. PM is established IAW vendor recommendations..
(vertical slice) No formal process exists for initiating a PM task other than review of operation by EMC or PAF post. Most times these are performed ahead of need to take equip OOS. Equip is designed as fail-safe. There are reporting requirements in the Sec plan and required notifications. Equipment is routinely monitored (rqmnts were reviewed but are sfgds info)
No action required Intrusion Detection SP 6.2 yes Yes- reviewed Reviewed procedure and documentation. Calibration procedures are developed via ADM. 90 day calibrations are Systems (IDS) performed. No formal PM. The cal has visual checks for obvious items to clean/repair. Equipment is routinely (vertical slice) monitored (rqmnts were reviewed but are sfgds info) Cals are performed to screen out potential for equip to fall out Perifeld, E-field, of spec. Equip is Alarm/fail safe. Guidance is in place for comp measures. Every alarm, test, maintenance OOS is microwave, CCTV tracked in CAS along with the appropriate testing criterion. IDS (the perimeter) is the primary focus of Security.
There are other systems that support security. This is the primary.
No action required Other equipment PSP yes Yes- NOT Other misc security equipment is in use at the plant and Owner controlled property. Those systems are reviewed commercial systems and a lot of new equipment has been recently purchased. All are in the PS Plan.
Doors, turnstiles barriers, There are not any specific guidelines on this maintenance yet. No official training, spare parts gates etc. recommendations or PMs. EMC or N/S supv gives limited tribal knowledge/guidance or a vendor is called.
CR 03-05017 Recommendation that future use of SAP could be used to schedule repetitive tasks. Need for development of spare parts lists and establishment of document control of vendor manuals.
Commercial Process Eval DEER 0017 yes Yes- reviewed Design Exclusion Evaluation Request was approved 10/30/01 This has essentially evaluated the exclusion of the entire BVPS plant security system from the Design Control Program Concerns/risks. Over an extended period, when commercial changes are made to the system, control of the systems as built configuration must be steadfastly maintained or configuration control could be lost. DEER process is not clear that the owner holds similar responsibility for processes formerly performed under engineering process controls.
Concern over prints, repair parts listing, doc controls and stocked items. See below. CR 03-05145 addresses this issue.
Yes-reviewed Concern over prints, maintenance PMs, repair parts listing, training and recommended spare parts listing.
PO 7096886 for No driving document or hooks to do this when reviewing the P.O. CR 03-05017 addresses this issue.
Perimeter upgrade Condition reports CR-992637 Yes-reviewed Untimely/inappropriate Corrective Actions. CR 03-05145 addresses this issue.
Quality Assurance Verification Table EXTENT OF CONDITION FOR 02-02202: NQA-INITIATED CRs FOR SELECTED PROGRAMS / RISK SIGNIFICANT SYSTEMS NQA AUDITS AUDITING SCAQ [1,2] / CAQ [3,4] (CA or above) category CRs VERIFICATION CAs DATES [FINDINGS] COMPLETE 1 1997-Environmental 9/4-10/14/97 97-1578 (4), 97-1579 (4), 97-1580 (4), 97-1604 (4), 97-1605 (4) Could not be verified through CREST 1998-Environmental 3/12-5/11/98 98-1046 (4), 98-1047 (3), 98-1048 (4) Could not be verified through
- nonradiological CREST 1998-Environmental 9/30-12/30/98 98-2096 (4), 98-2097 (4), 98-2110 (3), 98-2111 (4), 98-2116 (3), Could not be verified through 98-2130 (4), 98-2144 (3), 98-2222 (4), 98-2223 (3) CREST 1999-Environmental 9/8-10/27/99 99-2455 (4), 99-2468 (4), 99-2648 (4), 99-2652 (4), 99-2768 (4), Verified by QA -by CREST Review 99-2847 (3), 99-2987 (4) 2000-Environmental 4/12-5/30/00 00-1557 (3B), 00-1664 (3B), 00-1665 (3A), 00-1666 (3A), Could not be verified through
- nonradiological 00-1700 (3B), 00-1703 (3A), 00-1704 (3A), 00-1758 (3A), CREST Review 00-1772 (3B) 2001-Environmental 10/16-10/29/01 No SCAQ or CAQ condition reports. N/A 2002-Environmental 4/1-4/30/02 02-02958 (CA), 02-02962 (CA), 02-02967 (CA), 02-03027 (SB), Verified through CREST Review
- nonradiological 02-03118 (CA), 02-03271 (CB), 02-03326 (CB), 02-03327 (CA),
02-03339 (CA) 2 1997-EPP 2/4-4/9/97 97-0711 (3), 97-0712 (3), 97-0713 (3), 97-0714 (3), 97-0715 (3), Could not be verified through 97-0716 (3), 97-0403 (4), 97-0717 (3), 97-0718 (3), 97-0719 (3), 97-0720 (3), 97-0721 (4), 97-0722 CREST Review (4), 97-0723 (3) 1998-EPP 1/29-3/20/98 98-0707 (3), 98-0708 (4), 98-0709 (4), 98-0706 (4), 98-0480 (4), 98-0481 (4) Could not be verified through CREST Review 1999-EPP 1/22-3/18/99 99-0848 (4), 99-0849 (4), 99-0847 (4), 99-0784 (4), 99-0779 (4), 99-0280 (4) 99-0847 and 99-0079 could not be verified through CREST 2000-EPP 2/2-3/3/00 00-0612 (2), 00-0613 (2), 00-0614 (3A), 00-0615 (3B), 00-0612 could not be verified 00-0616 (3B), 00-0617 (3B), 00-0618 (3B), 00-0633 (3A), through CREST 00-0716 (3C), 00-0798 (3A), 00-0799 (3C) 2001-EPP 1/15-2/23/01 01-0380 (CA), 01-0557 (CA) Could not be determined from Not marked for QA follow-up CREST review 2002-EPP 1/7-1/31/02 No SCAQ or CAQ condition reports. N/A 3 1997-Security 1/29-3/18/97 97-0405 (3), 97-0475 (3), 97-0476 (4), 97-0526 (4) Could not be verified through CREST 1998-Security 2/3-3/12/98 98-0201 (4), 98-0470 (4), 98-0509 (4) Could not be Verified through CREST 1998-Security and 2/3-3/12/98 No SCAQ or CAQ condition reports. N/A Access Authorization 1999-Security 1/28-3/16/99 No SCAQ or CAQ condition reports. N/A 2000-Security and 1/31-3/15/00 00-0160 (3B), 00-0251 (3A), 00-0320 (3B), 00-0491 (3C),
Access Authorization 00-0492 (3A) 2001-Security 1/24-3/16/01 01-0708 (CA) 2002-Security and 1/14-2/1/02, No SCAQ or CAQ condition reports.
Access Authorization 3/1-3/28/02 4 2nd Qtr 2002 NQA Assessment 5/13-6/30/02 FIRE PROTECTION SYSTEM: 02-04777 (CB), 02-04779 (CA), 02-04780 (CR), 02-04443 (CA), 02- No QA follow-up on CR 02-04777,
Report 04445 (SB), 02-04629 (CB), 02-05375 (CB) as listed in the CREST database. 1 CAs of all other listed CRs either verified, rejected. or are Open 2 5 3rd Qtr 2002 NQA Assessment 7/1-9/30/02 FIRE PROTECTION SYSTEM: 02-04778 (CA), 02-04779 (CA), 02-05983 (CB), 02-06162 (CB) No QA follow-up on CR 02-04778, Report as listed in the CREST database. 1 No QA follow-up on automatic closure (W.O.) for CA 02-05983-02 3
CAs of all other listed CRs verified or are Open 6 4th Qtr 2002 NQA Assessment 9/30-12/31/02 BORIC ACID PROGRAM: CR 02-10228 (CA), 02-10342 (CA) CAs of listed CRs verified, Hold Report or are Open 7 ORP00205a: Clearance / 4/1/02-4/1/03 CLEARANCE PROGRAM Element: 15 QFOs generated by NQA. No QA follow-up on CR 02-08560.
Tagging CR 02-07889 (NA), CR 02-08560 (CA) Investigation not QA approved.
CAs NOT verified. 3 CAs of listed CRs verified or are Open 8 EEN00418: Boric Acid 4/1/02-4/1/03 BORIC ACID Element: 8 QFOs generated by NQA. No CRs were generated as CA or above N/A Corrosion Control category/evaluation.
9 OOP00104: Reactivity 4/1/02-4/1/03 REACTIVITY MANAGEMENT Element: 3 QFOs generated by NQA. No CRs were generated as N/A Management CA or above category/evaluation.
Issues that could not be verified through CREST Review will be addressed by CR 03-04788.