ML20052H636
| ML20052H636 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/16/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20052H634 | List: |
| References | |
| NUDOCS 8205210285 | |
| Download: ML20052H636 (9) | |
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'Af Teiopnenesi2ssse00 Nuclear Divisiott s'nSppIn'p' ort, PA 15077@04 g
Mr. R. C. Haynes, Pcgior.al Administrator Unitcri States Nuclear Regulatory Cmmission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Deaver Valley Power Station, Unit tb.1 Docket No. 50-334, License Ib. DPR-66 Systematic Assessment of Licensee Performance (SALP)
Gentlemen:
'Ihis letter forwards our response to the Systematic Assessment of Licensee Performance (SALP) for Beaver Valley Power Station, Unit No. 1.
This response addresses the concerns noted in the two functional areas categorized as Category 3 by the SALP Board. These functional areas in-clude Maintenance and Security and Safeguards.
We believe that we have made substantial progress during 1981 in improving our overall performance, and we are confident that the additional measures which we have taken, and plan to take, will result in significant additional inprovement. We have developed methods to nonitor our own progress and we are prepared to adjust our program as necessary to attain and maintain an excellent standard of performance.
If you have any questions regarding this response, do not hesitate to contact me.
Very truly yours,
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. J. Carey Vice President, Nuclear Attachment cc: Mr. D. A. Beckman, Resident Inspector United States Nuclear Regulatory Commission Beaver Valley Power Station, Unit No. 1 Shippingport, PA 15077 United States Nuclear Regulatory Conmission c/o Document Management Branch Washington, D. C. 20555 1
8205210285 820506 DR ADOCK 05000
DUQUESNE LIGIT CDMPANY Beaver Valley Power Station Unit No. 1 Reply to Systematic Assessment of Licensee Performance Maintenance (Peport Item #3)
RESPONSE
An evaluation of the Beaver Valley Maintenance Program was ini-tiatc4 during the Paport assessment period. 'Ihe evaluation was completed at about the mid-point of the assessment period and was reflectal in the establishment of the Nuclear Division in March 1981.
We revised maintenance organization reduced the span of responsi-bility of the Station Maintenance Supervisor and included addi-tional positions for technical and first line supervisors.
Organization
'Ihe revised maintenance organization includes electrical and mechanical maintenance with the instrumentation and control responsibility being placed under a new senior supervisor re-porting directly to the Station Superintendent.
The maintenance organization previously included seven foremen reporting to four naintenance engineers who in turn reported to the Station Maintenance Supervisor. We revised organiza-tion (maintenance and I & C) doubles the number cf foremen ard maintenance engineers which permits increased attention and involvement in a reducai area of responsibility.
The establishment of a conpletely separate instrument and control section has relieved the Station Maintenance Super-visor of this workload and thereby enables him to maintain greater control of the balanw of the on-going maintenance activities.
Increased staffing in the engineering organization has re-sulted in nore timely and thorough ergineering support of station problems.
While the new organization is not conpletely staffed, the addi-tional manning has produced benefits in the identification and response to instances of repetitive equipment failures and in managarent of the maintenance work load..-
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Beaver Valley Power Station Unit No.1 Reply to SALP Maintenance (Continued) t Identification and Evaluation of Repetitive Equipment Failures t
To provide better evaluation of repetitive equipment failures, j
trend analysis of safety-related equipnent failures will be performed by the technical advisory group.
j As a result of increased technical staffing in the maintenance section, it has been possible to obtain a nore indepth review
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of specific equipment failures during naintenance activities to insure proper corrective action has been taken.
The following actions have been taken in regards to the re-petitive failures identified in the draft Report.
1.
Vital bus inverters #3 and #4 are teing replaced during i
the second refueling outage. The performance will be 1,
conpared with the older inverters and appropriate action taken.
2.
A new motor was installed on the motor driven fire punp (FP-P-1) to increase reliability. Duquesne Light Coupany Engineering is presently re-evaluating the design and materials utilized in the underground piping system to preclude line breakage.
3.
Deficiencies in the degasifier system heat exchangers will be corrected by Design Change Package 539 which has determined the method of repair. Final' engineering will be started this nonth.
4.
h RCS Icop 1 flow ire.ument malfunctions were cW by a single faulty transmitter. ~The transmitter was replaced and satisfactory surveillance has been performed on RCS Icop 1 instrumentation.
5.
The BWST level instrument drift problem appeared to have been caused by inproper venting of the transmitters low pressure process connection. The proper. vent plug was.
installed. The transmitters were calibrated satisfac.
torily and appear to be operating properly. ~These transmitters will be nonitored to determine if the problem has been corrected.
Beaver Valley Power Station Unit No. 1 Reply to SALP Maintenance (Continued) 6.
Velan check valves were experiencing binding of the discs. A design change was initiated and is being worked at this time. The design change will be cmplete by the end of the 1982 outage.
7.
The out-of-service indicators and annunciators in the control room were given a higher priority by I & C supervision. The number of indicators and annunciators out-of-service has been significantly reduced.
Management Control of the Maintenance Work Management control of the maintenance workload was inproved by assigning additional staff to the maintenance organizations.
This enabled the station staff to better define the workload and associated problems.
1.
A new position of Senior Instrument and Control Cali-bration Engineer with two Instrument and Control Foremen reporting to him was created. This allowed one branch of the new instrument and control group to devote full time to reviewing and scheduling instrument calibrations.
This work was previously done by the Instrumnt Engineer on a low priority basis.
2.
To provide management with a nore accurate and up-to-date status of maintenance and control work, it was necessary to inprove the Canputer Backlog Report. The method of reporting completion information for updating the backlog report was changed and backlog updates are now performed on a weekly basis.
Use of the backlog report by management as a means to periodically assess maintenance and instrument and con-trol progress has been inplemented to provide better l
control of maintenance work load. The backlog report is l
reviewed on a quarterly basis to assess performance.
During extended outages the backlog report is reviewed by each discipline with planning and scheduling on a weekly
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basis.
Increased emphasis on cmpletion of maintenance tasks has resulted from use cf the backlog reports. -
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Beaver Valley Power Station Unit No.1 Reply to SALP Maintenance (Continued) 3.
Because of concerns with long times between non-category I instrument recalibration, a list of non-category I instruments used by the operator in response to abnormal and emergency procedures was made. Procedures were prepared and calibrations have been performed on most of these instruments. The as-found data has verified that over 90% of the instruments did not have significant errors in the cperating range.
It is expected that all the instruments on this list will be calibrated prior to plant start-up. Additional enphasis has been placed on the timely calibration of non-safety related instru-mentation.
During the past six months, increased enphasis of the importance of quality in naintenance activities has been initiated by station management including training provided by the Quality Assurance Department in the revised CA Training Program provided to all station enployees. Increased awareness and sensitivity to quality issues will continue through use of bulletin board presentations and work group meetings.
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Beaver Valley Power Station Unit No.1 Reply to SALP Security and SafeguarC.s (Report Item #7)
DEFICIE2CIES Routine and special inspections during the period identified the need for additional management attention to:
1.
Guard force training and performance as factors in incidents and violations.
2.
Security caputer and computer auxiliaries, software problems, system capacity problems, and system debugging.
(Note: Overall system performance has inproved since the end of assessment period but chronic problems e.g. uniterruptible power supply performance and software problems, persist) 3.
Inproper implementation of conpensatory measures when intrusion detection and surveillance equipment is degraded.
4.
Contractor guard force nanagement policies for personnel disciplinary problems, overtime work, and attrition.
RESPONSE
1.
We have given additional managenent attention to guard force training and performance as factors in incidents and violations.
The unsatisfactory performance noted in the report can largely be attributed to the quality and content of the security training program. Duquesne Light Company and its security contractor have taken positive steps to inplement significant improvements in the security program, a)
The Duquesne Light Conpany Security Staff has been increased from one to three. We Duquesne Light Company organization includes a Director of Security, a Security Assistant and a Security Training and Procedures Coordinator. W is provides total overview and control of the security contractor's operation.
b)
Since August of 1981, the Security Training Department has acconplished the following tasks:
1)
Formulated professional lesson plans depicting the requirements delineated in the Training and Qualification Plan ('IQP).
Prior to August the-Security Training Department taught from ten (10)
Lesson Plans. Today, lessons are given using forty-seven (47) plans. L
Beaver Valley Powcr Station Unit No. 1 Reply to SALP Security and Safeauards (Continued) 2)
Training has shifted from an unorganized training schedule to a Module System of testing.
3)
Audio visual use and word picture testing have upgraded the quality of the program.
4)
Tasks are taught with professionalism and the level of instruction has increased significantly.
c)
February 1, 1982, the training program began for the revised 'IQP.
In addition to tne task oriented training, Supervisors are given forty (40) hours additional Supervisory Training in Comnunication Skills.
d)
November 9,1981, Security inplemented a training consultation for individuals who demonstrated poor performance. This empleted a tie between site deficiencies and possible training deficiencies.
e)
During October of 1981, the Division c.nd Contractor Management began to conduct personal interviews to discuss performance and deficiencies.
f)
While the Beaver Valley Security Plan has been inplemented, a total review by the Duquesne Light Conpany Security Staff is now in progress. This review will require several nonths and should identify any weaknesses or deficiencies in the plan as it now relates to the new Division organization.
2.
Additional attention has been given in the area of mcurity 7
computer and conputer auxiliaries, software problems, syster capacity problems, and system debugging.
(Note: Overall system performance has inproved since the end of assessment period but chronic problems, e.g. uninterruptible power supply performance and software problems, persist) l a)
Late December of 1981, the memor; plus was installed on the security cocputer. Since that time, the conputer capacity has increased and problems have almost ainamared.
b)
System debugging has been gaing on since installation l
during February 1981. During the nonth of December, training was conducted for station personnel on the proper use of the key card.
c)
Duquesne Light has increased the level of understanding and connunications with Johnson Controls Inc. (JCI). In October of 1981, a procedure was written and inplemented for inputting software dianges into the conputer. This procedure consisted of testing and sign-off acceptance which inforcai Quality Control. In addition, to the procedure, JCI was restricted in the nanner in which they inputted into the corputer. Each input change is now being conducted as a single input, not a nass input, and tested before p:xx:eeding to the next change..
I Beaver Valley Powcr Station Unit No. 1 Reply to SALP o
Security and Safeguards (Continued) d)
Considerable engineering effort has been expended to resolve the uninterruptible power supply (UPS) problem.
1)
We have conductal an examination of output of the UPS voltage wave form using an oscilloscope. No abnornalities or noise superinposed on the output wave shape have been detected.
2)
Since the problem has been one of numerous alarms, the analysis of this problem has been directed to supervisory alarm circuitry. Noise could affect the supervisory alarm continuity check by inposing a nomentary loss of voltap signal. Timing of the supervisory alarm sensing devices has been evaluated to determine whether these devices are set too sensitive. Duration of a spurious voltage signal due to noise of over 64 milliseconds (0.064 seconds) could result in alarns.
3)
Tests indicate that the problem is caused by noise, but isolating the noi source has not been achieved.
4)
Isolating transformers were installed in the nultiplexer circuits to filter out noise. No inprovement was seen.
o 5)
Grounding and shielding have also been evaluated.
Some RF noise has been found in the nultiplexer circuiting and further tests are in progress.
3.
As a result of inproper inplementation of compensatory measures when intrusion detection and surveillance equip-ment is degraded, we have acconplished the following:
a)
An increased number of personal interviews with security personnel have m en performed.
b)
Training has been conducted relative to inproper implenentation of procedures.
c)
In July 1981, Duquesne Light Conpany contracted a procedures writer. Since his enployment in July, he has written 98 post orders, instructions cnd/or procedures. These written oormunications have inproved security awareness and reinforced the importance of proper procedure inplenen*,ation.
4.
The following steps have been taken concerning contractor guard force nanagement policies for personnel disciplinary problems, over tim work, and attrition.
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O Beaver Valley Power Station Unit No. 1 Reply to SALP i
Security and Safeguards (Continued) a)
h Contractor has inplemented a c'isciplinary action procedure to ensure problems are handled uniformly.
j Contractor personnel have been made aware of the
" rules" and consistency in enforcement has been applied based on the new disciplinary philosophy.
It is believed inprovements in guiding and directing behavior in a positive nanner will be achieved.
b). The contractor labor agreement does not allow denial of overtine; however, the contractor recognizes his responsibility to ensure his work force is alert. As a result, the contractor has already tracked overtime i
hours, and in some instances denied overtime due to 1
excessive hours and fatigue.
c)
Attrition has been reduced considerably and is only 20% of the attrition rate experienced during the 1980-1981 report period.
Duquesne Light Company believes the above corrective actions denonstrate management involvement and are substantial enough to result in considerable inprovement in the Security Program at Beaver Valley.
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