ML20042G976
| ML20042G976 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/08/1990 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005160360 | |
| Download: ML20042G976 (5) | |
Text
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Deavet V: ley Power St: tion Shippingport, PA 150/7-0004
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May 8, 1990 l
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U. S. Nuclear Regulatory. commission I
Attn Document control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334,. License No. DPR-66 l
BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report Nos. 50-334/89-80 and 50-412/89-80 centlemen:
The above referenced NRC Inspection Report for the Beaver-Valley Power Station special maintenance team inspection was transmitted by NRC correspondence dated February 26, 1990.
The Inspection Report discussed specific strengths and weaknesses of the BVPS maintenance program identified during the inspection. to the report provided a listing of the
[
identified weaknesses.
As requested, attached is our response l
concerning the actions we have taken or plan to take to address the areas where weaknesses were identified.
t If there are any questions concerning this response, please I
contact my office.
l Very truly yours, e
. D. Sieber Vice President Nuclear Group Attachment cc:
Mr. J. E. Beall, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator Mr. M. W. Hodges, Director, Division of Reactor Safety Mr. A. W. DeAgazio, Project Manager Mr. R. Saunders (VEPCO) r
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9005160360 900500 gDR A DOCK. 0500 4
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4 DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Units 1 and 2 Recly to Identified Maintenance Proaram Weaknesses Combined Inspection Report 50-334/89-80 and 50-412/89-80 WEAKNESS NO. 1 Lack of a unified and' comprehensive document that provides station wide guidance on the policy, objectives, structure and constraints on the maintenance functions.
Corrective Actions Taken or Planned A
new Nuclear Group Administrative Manual-(NGAM) ion.is currently
)
being developed for Beaver.
Valley Power Stat These j
procedures, when implemented, will replace the present Nuclear Group Directives (NGOs) and ' Site Administrative Procedures l
(SAPS).
Concerns identified during the team inspection will be resolved by June 30, 1990 with the implementation of these new procedures.
These Nuclear Group Administrative Procedures will J
indicate the site crganization and responsibilities of each group.
Detailed group work functions and interfaces with other groups will be contained in the administrative procedures of the various station groups.
Specific to maintenance, information contained in SAP 8A
' Maintenance",
SAP 8B
" Instrumentation &-
Control" and similar information for construction will be incorporated into one Maintenance Manual for control of maintenance activities.
In
- addition, the Maintenance Work Request (MWR) Program is being updated to include the responsibilities of the Nuclear i
Construction Department when they perform NWR activities and is scheduled to be issued by June 1, 1990.
HEAKNESS NO,_2 Lack of a graded response to failures to assure that a root cause analysis is performed before a
potentially serious event or multiple failures occur in a component.
Corrective Actions Taken or Planned Grading essentially involves reviewing the MWR cause of failure to determine if it requires immediate management attention or will have little impact if delayed until the quarterly review process evaluation (if applicable).
We concluded that a " lack of graded response" was directed at the lack of a
- formal, structured approach by which routine root cause analyses are performed on most MWRs.
. Recly to Identified Maintenance Proaram Weaknessig
, Combined Inspection Report 50-334/89-80 and 50-412/89-80 Page 2 To emphasize the importance of critical component failures, the MWR Program is being updated to require all priority 1 and priority 2
MWRs to receive an immediate independent management review via the incident reporting program.
This will involve filling out a
formal, structured, root cause analysis form which will guide the reviewer to the root cause versus a contributing
- cause, y
Priority 3 MWRs will continue to be reviewed for root cause by the cognizant maintenance supervisor.
Based upon his discretion, the same root cause analysis form may or may not be utilized in his evaluation.
Priority 4
- MWRs, by definition, reflect a condition that has no effect on the safe, reliable operation of the station.
Root cause analyses are usuall not policy will continue.y performed for Priority 4 MWRs and this Maintenance supervisors completed Kepner-Tregcc root cause analysis training in February 1990 to assist in developing proper root cause analyses.
The MWR Program will be updated by June 1, 1990.
An addendum containing the root cause analysis form and associated instructions will also be added to the Incident Reporting Program.
WEAKNESS NO. 3 Lack of rigor and consistency in the implementation of MWR process.
j Corrective Actions Taken or Planned Management at BVPS recognizes the importance for all Nuclear Group personnel to perform their daily tasks in a professional manner.
In an effort to demonstrate management awareness of, and commitment to, this
- issue, a
video presentation by the Vice President, Nuclear
- Group, was made to site personnel, reminding each individual of the importance to operate and maintain BVPS in a
- safe, efficient, and reliable manner, with particular attention to detail and procedure compliance.
I
' Recly to Identified Maintenance Procran Weaknesses j
. Combined Inspection Report 50-334/89-80 and 50-412/89-80 Page 3 i
In the specific area of the maintenance work request (MWR)
- process, two major improvements are being implemented.
The first involves the MWR Program which incorporates human factors concerns into the NWR program by establishing clearer lines of responsibilities and providing a
new MWR form which contains separate blocks for all key action requirements and information.
This update should be implemented by June 1, 1990.
Additionally, Operations Quality Control (OQC) now also reports those maintenance activity deficiencies which were immediately corrected in the field and had no significant impact on the task in progress.
This will enable management to monitor compliance problems and focus attention on specific areas requiring attention.
00C has been reporting deficiencies immediately corrected in the field to Maintenance since February 15, 1990.
i Taken collectively, these three measures reflect management's continuing commitment to monitor and improve daily work activities to ensure the safe, reliable operation of the station.
WEAKNESS NO. 4 Insufficient supervisory oversight on radiological work activities with cumbersome RWP package forms.
Corrective _Attions Taken or Planned
. eakness identified above was addressed by Duquesne Light The w
Company in our letter to the NRC dated February 15, 1990 in response to two violations (50-334/89-21-02 and 50-334/89-21-01) identified during the maintenance team inspection and cited in combined Inspection Report 50-334/89-21; 50-412/89-20.
As stated in that
- response, programmatic corrective actions to address the above violations are scheduled to be in place by September 1,
1990.
These actions will address the identified weakness.
I WEAKNESS NO. 5 Lack of formal procedures governing scope and material control in maintenance shop.
Corrective Actions Taken or Planned Maintenance will develop a new Maintenance General Work Practice to control work activities in the various maintenance shops.
This is expected to be completed by September 1, 1990.
, Recly to Identified Maintenance Procram Weaknesses Combined Inspection Report 50-334/89-80 and 50-412/89-80 Page 4 WEAKNESS NO. 6 1
Incomplete. coordination and work control in areas where multiple craftsmen are working on different NWRs.
Corrective Actions Taken or Planned The Planning and Outage Management Department pre-plans all outage MWR activities prior to the start of the outage and reschedules
- them, if necessary, as new MWRs are added.
In areas where i
congestion is anticipated such as RCF cubicles, the containment in
- general, and the turbine
- deck, a coordinator has been and will continue to be assigned to monitor individual MWR progress and resolve conflicting activities on the spot.
For other plant areas, work activities are discussed in the Shift Coordinator's meetings held daily throughout the outage.
Potential conflicts in those areas are analyzed and best efforts are made to avoid interfering with work activities as much as possible.
In some
- cases, a
special area coordinator is temporarily assigned to oversee major areas of MWR activity.
- However, sometimes MWRs are delayed, extended, or new MWRs quickly added such that conflicts arise unexpectedly in areas where a i
coordinator is either not assigned or is not in continual r
attendance.
To minimize the impact or not having a coordinator l
- assigned, Planning and Outage Management will increase their efforts to assign additional area coordinators as necessary when it appears overcrowding or conflicting tasks may be scheduled in the same period.
An additional effort will be made to ensure all work party leaders are aware of who in the area coordinator, when one is
- assigned, and where he may be contacted to resolve conflicts arising in areas where the coordinator is not physically present.
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