ML20065K777
| ML20065K777 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Beaver Valley |
| Issue date: | 08/31/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML082180535 | List:
|
| References | |
| FOIA-82-261 NUDOCS 8210080114 | |
| Download: ML20065K777 (16) | |
Text
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,c BEAVER VALLEY 1 Evaluation Period 9/1/79-8/31/80 1
~C I.
General A major reorganization is underway (in response to the December 1980 SALP and a NRC Management Meeting on March 19, 1981) to provide more management l
attention, resources, and capabilities to deal with problems. The licensee's l-recognition of the need for and initiation of this broad-based action is L
a necessary major step in improving long-term effective management ccntrol of licensed activities. The new organization, approved by the DLC Board E
of Directors on March 24, 1981, established a new Nuclear Division, I
consisting of four departments.
Each department has a manager reporting directly to the on-site Vice President, Nuclear. These managerial positions were filled on April 22, l
1981.
Several other senior staff assignments were made on June 16, 1981 j
(Plant Superintendent, Chief Engineer, Supervisor of Licensing and Compli-i ance) Progressive transfer of functional groups from the old to the new j
organization will continue through calendar year (CY) 1981.
The Nuclear i
Engineering Department, due to its complex nature, is expected to be complete after the Spring 1982 refueling outage.
The new organization will add about 60 new positions on the site staff, some of which are f
already filled. Continuing review of the licensee's reorganization efforts
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by the resident inspectors indicate substantial improvement of management.
j control has occurred.
g II.
Specific Rb.
i 3
Contention 1-
"The Beaver Valley 1 facility displayed eTidence of weaknesses in nine function areas.
These areas were plant operations, maintenance, surveillance, quality assurance, committee activities, fire protection, design changes and modifications, security, and management controls."
j These contentions are addressed as follows:
Plant Opbrations (See Contention F)
Maintenance (See Contention I)
Surveillance (See Contention J)
Quality Assurance (See Contention K)
Committee Activities (See Contention B)
Fire Protection (See Contention H) i l
Design Changes and Modifications (See Contention A)
Security (See Contention G)
Management Controls (See Contention A and C)
Contention A "A low corporate engineering staff manning level led to a lack of design control over some contractor activities."
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~ 8210080114 820712 PDR FOIA UDELLS2-261 PDR
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1.
Basis k
Inspections identified noncompliances and regulatory issues including inadequate as-built information, use of uncontrolled information for development of procedures for modified systems, inadequate turnover control for modified systems, failure to maintain procedures for modified systems, and inadequate safety evaluations for modified i
systems / equipment.
The licensee entered the outage with inadequate interface control procedures for the installation, testing and turnover of modified systems and as-built information.
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Three inspections and one investigation during the evaluation period addressed design and construction deficiencies. The recurrent
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identification of design deficiencies has frequently involved escalated NRC and licensee management attention to attain correction. These c,q issues have included:
- yl.', n T C1M Environmental qualification of Class 1E electrical equipment *;
dff.u. 4)
Construction deficiencies in safety-related tanks; Anomalous NDE data for the reactor containment;
.N.NfC LHSI Pump NPSH deficiencies; 9','*P; Containment Spray Chemical Addition deficiencies; ESF Equipment reset circuitry deficiencies; Seismic Analyses and As-built system deficiencies *.
2 :;
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(* Generic'to all licensees) qa:~{q
..y dg,6.N 9)
Inadequate management controls over and a lack of sufficieni. resources i q
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for licensed programs appeared to be a central factor in the licensee's problems in making design changes and modifications. However, the M"
licensee's planned corrective actions do appear to be capable of being developed and applied to future design changes, albeit at the
~
ij expense of outage extensions.
2.
NRC Action References
. An enforcement conference was held on September IE Report 50-334; 25, 1979 to address licensee implementation of 79-21, 80-14, the design control program. Two special inspec-81-07; tions were conducted to fully evaluate the '
6/26/80 NRC Regit licensee's Design Control and Modification pro-I letter gram. An Immediate Action Letter (80-18) was (IAL 80-18) issued on June 26, 1980 addressing construction deficiencies in the refueling water storage tank and the demineralized water storage tank. The I AL required the licensee to confirm the ade-quacy of construction of the containment liner and the Boron Recovery System Tanks because they were constructed by the same contractor as the deficient refueling water storage tank and de-mineralized water storage tank. The NRC con-tinues to monitor the effects of the licensee's
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management reorganization.
s
3.
Licensee Corrective Action References q i, The licensee revised Procedure No. 3.7.3, IE Report 50-334/
System Release Turnover Procedure,and Proce-80-09 s;
dure No. 2.3, Design Change Coordination,to N[s
_r ensure coordination and control of all station Licensee letters activities related to design changes.
In ad-of 8/16/80,
- " is dition, an individual has been assigned to 4/10/80,
.l coordinate and control system turnover to opera-6/30/80 k ?;
tions personnel.
A detailed design change con-
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trol and modification inspection conducted March IE Report 50-334/
3.,,,
LLM.
2 through 6, 1981 confirmed that changes imple-81-07 mented by the licensee were effective. A recently di 1:
initiated reorganization incorporating a new
[p.9 Nuclear Engineering Department is expected to L Q]/yu improve the licensee's in-house engineering and t-his capability for contractor control.
kM Contention 8 f
M "The onsite safety review committee was overburdened and some reviews
- y5g were inadequate."
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$d 1.
Basis References
%g M.
The Onsite Safety Committee was overly burdened M
by both routine and non-routine review tasks.
During the weeks of November 3 and November 10,-
[M 1980, the committee was in several marathon gg sessions to review numerous procedure changes
/.E4 and other issues necessary to support plant re-IQhM start.
Such lengthy sessions were not uncommon Il Mi and removed key station supervision from their normal duties.
The committee appeared to shoulder the primary burden of problem resolution and op-erational reviews with less than adequate techni-cal support, again resulting in removal of plant-supervision from their normal tasks to support 7
committee activities.
I w.
In two cases (IEB 80-06 and IEB 79-27) the IE Report 50-334/
quality of Onsite Safety Review Committee re-80-24; view and oversight was deficient, and resulted Licensee letters in inadequate bulletin implementation by the of 3/4/80, licensee.
Inspection 80-24 identified 10 CFR 10/21/80, 50.59 safety evaluations which were deficient 6/4/80, due to the failure to recognize the need for TS 7/31/80 revisions thus invalidating the original safety evaluations.
2.
NRC Action
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The resident inspectors communicated their findings and concerns to
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plant management through formal meetings throughout the evaluation I
period.
e N
(v Resident inspectors have noted a reduction in overall committee
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workload since the 1979-1980 outage and increased licensee sensi-tivity to obtaining necessary technical support for committee acti-vities.
,/ M4 3.
Licensee Corrective Action References n
3 The Offsite Review Committee was reorganized in 2/11/81 (TS Amenf SMQ early CY 1979 as part of the organizational ment #39); Li-W changes discussed in Contention C. The Onsite censee letters E M@
Safety Committee was reorganized in CY 1980.
of 4/10/81 and
,M q 6/30/81
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The licensee reorganization appears to acknow-2 ledge and provide for improvement in this func-
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tional area. Permanent positions providing full-time
- b...g direction and support of committee activities have Z-been provided. Interim licensee measures regarding com-
'lf*M3 mittee/ subcommittee composition have also improved the Q g.; fj j
situation.
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?O' Contention C ynM[ik
" Management control problems involved control of routine activities, 4
resolution of technical and regulatory concerns, correction of deficient
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areas, implementation of security plan requirements, and scheduling of
- 1,i required surveillance activities."
mu A7 1.
Basis Referances pest f * '-j!
Several inspections resulted in four items of IE Reports 50-339 L
noncompliance and one deviation.
The noncom-79-21, 80-04, i
j' pliances and unresolved technical issues in this 80-21, 80-26 and related functional areas (plant operations, security and :,afeguards, etc.) were communicated
.to the licensee during three management meetings.
IE Reports 50-334.
Indicated management control weaknesses were:
80-12,.79-20, s
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80-09, 79-24,
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Technical problems and regulatory issues 80-20, 80-16, l,
appear to require detailed attention from key 80-18 senior personnel.
Even with this attention,-
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numerous problems still resulted in enforcement action, management meetings with IE/NRR, and enforcement conferences.
Key managers (Plant Superintendent, Dir-ector of Nuclear Operations, Superintendent of Licensing and Compliance) frequently had to take personal control to ensure that safety concerns or regulatory requirements are properly addressed. The failure of sup-port and engineering organizations to produce
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acceptable results without detailed and per-(
sonal attention from these managers placed 6
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the licensee's management in a reactive role, diluting their ability to plan and implement J
their activities.
Examples are resolution of outstanding IEB 79-14 seismic issues to support. outage restart, resolution of Rod cM Position Indication anomalies, implementation T*)sj of TMI Lessons Learned items, Physical Se-
'i'a curity Plan modifications and program imple-
,.4 mentation.
.xi The ' licensee failed to implement com-WQ 5.;,
mitments to the NRC on time. Specific M;
examples include:
h.
Review / reanalyses required by IEB 10/30/79 Licensee
[U 79-14 were not completed prior to letter
' q:3 completing the 1979-80 outage as A
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stated by a DLC letter of October g
30, 1979.
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$f; Equipment installations required by 7/21/80 NRC Region
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the Physical Security Plan for compli-I letter (IAL 11 ance with 10 CFR 73.55 were not com-80-22) p%
6 pleted on schedule as required by an 10/30/80 Licensee E&
IAL dated July 21, 1980. Construction letter dM
' ectivities were to be essentially com-plete by November 1, 1980; NRC was noti-bg::
fh'3 fied of the schedule slippage by a DLC
}{y 1etter.
Design changes in fire protection sys-12/23/80 NRC Md tems were not submitted for NRR review letter
'l prior to their implementation as're-quired by commitments documented in the NRC Safety Evaluation Report.
. Licensee preventive action commitments IE Report 50-334/
to track maintenance surveillance test 79-20 records were not implemitnted as re-quired.
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' Commitments for implementation of 10/31/80 NRC K
NUREG 0578, Category "A" TMI Lessons Region I letter Learned items (Reactor Subcooling (IAL 80-46)
Instrumentation and PORV Acoustical Monitoring System) were incompletely implemented, resulting in the issuance of IAL 80-46.
Commitments made pursuant to IEB IE Report 50-334/
l 79-01B during an inspection and in a 80-12 l
licensee submittal were not imple-mented.
Limit switches which provide post accident equipment control func-
l
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tions but wijich are not qualified for harsh environments were not replaced as committed.
Two incidents during the evaluation period indi-
- !A.
cated a need for additional management attention
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M; to operator performance, training and professional
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attitude.
e.L A Operator errors and administrative LER 79-46 7 /M control breakdowns disabled both f;.3.M^;)..ffd.
11/27/79 and HHSI subsystems in November 1979.
NRC Orders of f
12/5/79 W.,
- s 4:
ph.,
e'3?qj[c A second incident in April 1980 re-
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i:"l. Mk.l suited when a licensed operator per-j formed a safety-related valve manipu-lation in disregard of verbal direction q
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from the SRO Supervisor.
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,0;3dkh Intensive site management involvement in IE Inspection'
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- m issues made the key site managers and on-50-334/80-09, j!jyi@d site department heads unavailable for nor-79-24, 80-20,
$jg?pfli mal management of daily operations and 80-16 JQ@6is1 planning for future tasks. This appeared dis to have contributed to several items of d~
.j Md noncompliance. (Control of modifications
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and related activities, Inspection 80-09; e
Radiation Monitor operation, maintenance, and corrective action, Inspection 79-24; h " P N $i Inadequate submittals to NRC, Inspection.
t e,9 80-20; and, Failure to implement corrective actions for noncompliances, Inspection 80-16).
Station department heads were frequently un-available for routine departmental operations j
and upgrading of previously identified prob-lems because of participation in protracted l
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Onsite Safety Committee meetings or staff meetings (discussed in Contention B).
Much of the existing technical and en-.
IEB 79-14 i'
gineering support was evailable only IEB 79-01B through contractors and consultants.
IEB 79-02 The interface problems with these ex-ternal organizations appeared to affect the quality and timeliness of actions and to require extensive management attention which diluted the management attention available for other tasks.
Inadequate licensee submittals were identi-IE Report 50-31 fied in Enforcement Conference 79-21 and 79-21 x
4 L
resulted in further absorption of DLC and 4e NRC management time and attention in a 3
reactive fashion.
Key managers appeared to need additional direct engineering jlf p,. g and technical support to prevent unneces-8try sary escalation of tasks to major manage-ifI.
ment issues, e.g., IEB 79-14 IEB 79-018.
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d Schedular and economic pressures appeared IE Report 50-334/
g.y ls,.
gh: r.a to contribute to this problem by imposing 80-16, 80-18 y
deadlines which did not permit available resources to address both routine and reac-gQ;gg tive tasks adequately.
For example, li-IE Reports 50-334'
@ gee;jN censee followup to NRC noncompliances was 80-26, 80-16 at iq@;y,d found to be inadequate during Inspection 80-18 i
f(f },4 80-16, licensee followup and management 9(.a of physical security matters as discussed t Mj in Inspection 80-18 and Enforcement Confer-
@gp,M. j i
s ence 80-26, and followup to problems and M
M deficiencies identified during incidents 5,
,via Licensee Event Reports.
k('h.3 '
2.
NRC Action References
_u.
Enforcement Conference on September 25, 1979 (Re-IE Report 50-334f" port No. 50-334/79-21). Special enforcement con-79-21 ference regarding licensee implementation of the
@IFh design control program, the effectiveness of g{;gg
- g.g licensee management controls, and the facility's recent enforcement history.
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Civil Penalty issued December 5, 1979, opera-NRC Orders 11/27/
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q tion with both HHSI ECCS Subsystems inoperable 12/5/79-on November 27, 1979.
Order Modifying License issued December 5, 1979 i-
. requiring licensee action in response to power Q ',, f-operition of facility with both HHSI ECCS sub-systems inoperable on November 27, 1979. Order IE Reports 50-330 required independent verification of redundant 79-21, 80-04,
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safety systems when a train is removed from 80-21, 80-26 L*.
service and~ detailed procedure review to insure r"'.
only one safety system is removed from service during maintenance or surveillance.
f Public Enforcement Meeting on January 22, 1980.
IE Report 50-334/
Special public enforcement meeting convened by 80-04 the Director, 0IE, to discuss the licensee's actions pursuant to an Order Modifying License, issued on December 5, 1979, as a result of faci-
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lity power operation with both HHSI ECCS subsys-tems inoperable.
I
Order Modifying License issued May 23, 1980 re-NRC Orders 5/23/80 (4
quiring the licensee to submit information which and 11/1/80 fully and completely responded to staff informa-tion requests for IE Bulletin 79-018, Environ-mental Qualification of Class IE Electrical Equipment, by November 1, 1980. (generic to all licensees)
A special Enforcement Meeting was held on July 18, IE Reports 50-334/
1980, to discuss the reasons for continued extension 80-21 and 80-26 of security compensatory measures in lieu of aggres-sively pursuing installation of security related
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equipment.
Additional areas discussed were licensee implementation of administrative controls, licensee action taken in response to recent incidents in-
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volving outage recovery activities and plant staff y%
work hours, u-u M
Order Modifying License issued August 29,1980 NRC Order 8/29/80 FWU requiring licensee to establish and maintain.a ydid; repository for data developed per IEB 79-018.
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(generic order to all licensees) hf;[
IAL No. 80 7/21/80 - Physical protection Licensee requested W rj program, requiring the licensee to upgrade the Management Meeting M
security program to meet the requirements of 4/3/81 10 CFR 73.55.
M I;k) 5%
IAL No. 80 11/3/80 - Status for plant re-Licensee letters Mii]
start. Seismic analysis for "as-built" safety-of 4/10/80 and
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yN related piping systems.
6/30/81 (TS amend-ment request)
IAL No. 80 10/31/80 - Status of TMI Lessons 10/31/80 NRC Learned Category "A" Items.
Region I letter (IAL 80-46) 3.'
License ~e Corre'ctive Action References In recognition of these factors and in response Licensee letters to the deficiencies identified by SALP, the li-4/10/81 and censee has initiated a major reorganization.
6/30/81 The new organization establishes a new, separate Nuclear Division and appears to provide more management attention, resources, and capabi-lities than are presently available. (see " Gen-eral")
The licensee's activities relative to reorgani-zation and staffing have not been fully evalu-6 ated by Region I but generally appear to be responsive to the deficiencies identified. The licensee's recognition of need for and initia-
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tion of need for and initiation of broad based, f-extraordinary action is a major step in achieving J
improved regulatory performance.
-l Contention D "Many items of noncompliance concerned personnel errors, indicated instances of insufficient training, and revealed instances of poor supervision of personnel."
[
These areas are addressed in Contention "C" and "F".
.c.
Contention E
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"The licensee experienced difficulties in meeting some technical commit-
.a ments to NRR and lacked an adequate technical support staff."
r.f These areas are discussed in Contention "C".
D'fl Contention F
- M "The Beaver Valley 1 facility displayed evidence of weakness in the area.
of plant operations."
-4
'Q 1.
Basis References nlffj Three items of noncompliance were identified IE Report 50-334/
s if
$,.h during several inspections.
Major issues in 79-25, 79-30, 81-01 W
the plant operations area were:
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Administrative control breakdown'and op-erator errors resulted in both HHSI suction flow paths inoperable (Order, Civil Penalty, and Public Enforcement Conference).
Additional issues include: operation without
. s operable boric acid flow path (administra-tive control breakdown and operator error),
inadequate jumper control, failure to con-trol temporary and permanent procedure changes, inadequate surveillance tests, use of uncontrolled information for procedure development, marginally adequate require-ments for operating procedure adherence, and inadquate turnover control for modi-fied systems.
.During the refueling outage, three RHR flow losses occurred because of airbinding while operating with the RCS loops drained to the hot leg midpoint. Frequent venting and more careful flow changes were only parti-ally successful remedies. Design change re '
mains in the conceptual stage.
Failure to solve old problems and.com-r
(.
prehensively address new ones, and to optimize professionalism and error free operation, appeared due to inadequacies in: 1) direct management attention to control room and facility operation; 2) understanding of quality assurance re-quirements and implementation by opera-tions personnel; and, 3) technical /en-gineering support for operational problem correction. Management of operations ap-peared to be largely reactive.
These problems may have been side effects of failure to muster the managerial and techni-cal resources to solve problems before they seriously. affect plant operations.
Operational,problemswerealsoreflectedbyf LER(s) several operational ~LER(s).
79-43, 79-45, 79-46, 79-49, 80-02, 80-04, 80-05, 80-07, 80-12, 60-22, 80-23, 80-24, 30-26, 80-31, 80-33, 80-46, 80-64 B.L 2.
NRC Action Increased inspection in this area. About 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> in a six month period, was provided by the resident inspectors.
3.
Licensee Corrective Action References Licensee management has taken positive action Licensee letters and become m, ore sensitive to operator profes-
- of 4/10/81 and sionalism and attitude and has implemented or 6/30/81 has under consideration programs and plans to improve communications, attitude and the op-erator career path.
Most significant licensee changes are being in-plemented by the new management organization and increased staffing efforts.,These changes'in-clude a formal management information system'to provide maNgement awareness and assurance that significant or potentially significant opera-tional problems are identified and corrected.
The revised organization will also establish an assessment function of plant'cperations, main-
^
t'enance, and instrument department actiyities.
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5;
s Contention G
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"The Beaver Valley 1 facility displayed ev.dence of weakness in the area of' security."
f,'
1.
Basis References
- +.v.S}j The licensee's Security Plan was effective Beaver Valley Power
- M}
24 February 23, 1979.
The licensee requested Station Unit No. 1 e $y Qlf 1.y relief from portions of 73.55 until December Physical Security 1979, in crder to obtain and complete instal-Plan, February 23,
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lation of security hardware. This extension 1979 R~. $",. el:
was granted, however, the licensee did not complete all of the system upgrade within the
. IE Report 50-334/
WM.
allotted time due to licensee schedulir.g, 80-18
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.. Y construction management, and equipment supply
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problems. A physical security inspection con-ducted June 16-20, 1980, disclosed that the
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that the licensee had not notified pr.C.
[Z:pl-December 1979 deadline had not been met and
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2.
NRC Actions, References y'.
7^4 Following the June 16-20 inspection, NRC Region IE Report U..
I held an enforcement meeting with licensee 50-334/80-26
?
management personnel.
As a result of the meeting, an IAL was issued to confirm commit-NRC Region I s
he j
ments made by the licensee regarding instal-Letter July 21, jg'M 5.3, lation of security equipment. The licensee 1980 (IAL 80-22) was given new deadlines of November 1, 1980, "N
for completion' of security equipment instal -
IE Report 50-334z
,"*]
1ation, and December 31, 1980, for completion 81-06 w'
of pre-operational testing of this equipment.
A followup inspection in March 1981 verified that all recurity systems were installed and
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operational.
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' 3.
Lice *nsee Cor'rective Action References
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.1 Immediately upon being apprised that NRC was June 20, 1980 F
unaware that,the December 1979 deadline could licensee letter not be met, the licensee sent notification to and Attachment the Commission.
The Attachment, a supplement to the fecurity Plan, stated that the delay resulted from the selection of a new security system vendor, a need to increase the original guardhouse space allocation, and innger mate-rials delivery times than criginally antici-pated.
The licensee requested that the Physi-cal Security Plan upgrade deadline be extended to December, 1980, with the then current com-pensatory measures to continue until that time.
1
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In a response letter to IE Inspection Report August ?l, 1980
[ J.-(L.
50-334/80-18, the licensee stated that all licensee letter s
future security-related correspondence would and attachment be submitted through the Superintendent of Licensing and Compliance to prevent recurrence of failure to notify the NRC in a timely man-i ner.
In addition, the licensee established I
a system of bi weekly reports to be submitted i
to the Vice President, Operations relative to the status of each of the commitments made at the July 18, 1980 enforcement meeting.
3 t9 In a status report to Region I, dated October October 30, 1980 q-30, 1980, the licensee informed the Commission licensee letter j
that nearly all of'the equipment was installed t
as required, with 100% of the systems expected 3
to be in operation by December 31, 1980. En-
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gineering modifications and late delivery of r/;
certain key electrical equipment were cited as
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esuses for delay in completion of the work.
3 A special inspection conducted March 2-5, 1981 IE Report 50-334/
1.'
revealed that all security sytems were in-81-06 stalled, operational, and in use.
d Contention H k'
"The Bea'ver Valley Unit 1 facility displayed evidence of weakness in the q
area of fire protection."
i 1.
Basis References
. Inspections during the evaluation period re-LER(s) 80-01SP, l
sulted in two items of noncompliance (failure 80-30, 80-18, to perform housekeeping tours and failure to 80-34, 80-52, maintain fire doors).
80-59 A n~ umber of'LER'(s) during the evaluation period IE Inspection identified repeated failures of the permanently 50-334/80-03, installed fire pumps.
In addition, a portion 80-06 of the yard fire main spontaneously ruptured during system testing..The repetitive nature of these failures without successful corrective action raises concern about the preventive and corrective maintenance programs (see Contention I),
Routine maintenance is currently conducted on a reactive basis as failures or equipment outages occur.
In addition, the licensee imple-rrented design changes without prior submittal to NRR for approval.
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i 2.
NRC Action References A followup inspection was conducted in April IE Report 50-334/
I 1
_y
_....~--------r-.----
.------n
1981. A Notice of Violation was issued to the 81-11 (i
licensee for failure to conduct preventive maintenance on the diesel fire pump. Within the scope of the same inspection the design changes to the fire protection program were reviewed and those completed were found ac-captable.
These modifications remain to be completed (manually activated suppression system for containment penetration area, hose stations inside containment, automatic water supprtssion system for the RHR pumps) and will be completed during the next refueling outage, f'
3.
Licensee Corrective Action References i s
g The licensee has devoted considerable manage-LER 80-069/01T2 4
ment and technical attention to resolve fire i
protection system problems including the per-formance of two system failure and reliability studies as well as implementation of corrective actions.
Study results were submitted as re-vision 2 to LER 80-069 on January 30, 1981.
l Conter. tion I "The Beaver Valley 1 facility displayed evidence of weakness in the area of mainter)ance."
i 1.
Basis References Inspections during the evaluation period id-IE Report 50-334/
entified inadequate control of maintenance 80-01, 80-05, 80-15 activities including inadaquate procedure, use of unapproved vendor procedures, use of out-of-tolerance test equipment and inadequate control i
of procedure revisions.
The maintenance depart-ment.s,taff.was undermanned due to assignment of Maintenance Engineer's as Shift Technical Advisors.
i Four LERs were issued concerning vital bus in-LERs 79-38, 79-39, verter failures without permanent corrective 79-40, 80-42 maintenance being effected.
Several Fire Protection System LERs were issued rel,ative to maintenance. (see Contention H)
Several other LERs issued may be Maintenance or LERs 79-44, 79-47, Preventive Maintenance related.
80-10, 80-11, 80-14, 80-15, 80-16, 80-26, 80-38, 80-41, 80-47
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._-_,_...._--u
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2.
NRC Action References Resident and region based followup inspections IE Report 50-334/
identified two items of noncompliance, use of 80-27, 81-03 unapproved vendor procedures'and failure to calibrate safety-related equipment at the scheduled frequency.
Resident inspector follow-up has verified licensee activities and cor-rection of specific deficiencies and problems.
A reg' ion based inspection conducted in February 1981 found the licensea's program acceptable.
3.
Licensee Corrective Action The licensee has developed and partially in-stalled vital power inverter modifications to eliminate the cause of inverter failures.
Pre-ventive Maintenance programs have been revised and improved to allow identification and replace-ment of failure prone equipment to eliminate pre-dictable failures.
In recognition of maintenance department prob-lems one of the prompt actions initiated under the licensee's reorganization is the~ad-dition of supervisory personnel to the plant
'r}Q maintenance staff.
Contention J l
"The Beaver Valley 1 facility displayed evidence ~of weakness in the area of surveillance."
1.
Basis References l
Inspections.dering the evaluation period iden-IE Report 50-334/
tified four surveillance noncompliances: pro-79-25, 79-27, 80-05,.
I cedures not current; use of out-of-tolerance 80-09 l
test equipment and non-documentation of test equipment calibration; failure to record sur-veillance testing; radiation monitor surveil-lance not done.
Several LERs issued during the reporting period LERs 79-43, 80-12, concern missed surveillances.
80-24, 80-64 2.
NRC Action References Followup inspections by the resident inspectors IE Reports 50-334/
(about 85 inspector-hours) identified five items 80-28, 80-27, 80-30 of noncompliance: failure to perform airlock sur-veillance when required; performance of NI-IR 1
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surveillance test under inappropriate conditions;
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improper performance of IR-HI surveillance test procedure; failure to maintain IR-NI surveillance test procedure records; and, failure to document IR-NI surveillance activities in station logs.
One region based inspection (about 25 inspector-hours) reviewed licensee preventive and corrective actions for other, prior inspection findings. LERs
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during the period reported surveillance related problems (missed surveillances, surveillance ac-ceptance criteria not met, and equipment fail-ures detected via surveillance).
4 3.
Licensee Corrective Action References y=J
- I.
The licensee has assigned review and evalua-alo tlon of the results of the surveillance test y ;-
program to the Technical Advisory Group (STAS).
Wh u.
-.l:Ri Surveillance test schedule performance has im-IE Report 50-334 pj f,J proved; routine reviews by the resident in-80-30 spectors have identified no scheduling problems E-~~
since October 1980.
Review of surveillance re-
- L +g sults by the Shift Technical Advisors and Opera-DN5j tions Department personnel appears to be con-
- gd sistently identifying problems and resulting in 15]
... g initiation of corrective action.
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On March 8-13, 1981, deficiencies were identi-IE Report 50-334/
gE cl fied in the-test methods and baseline data for 81-08 Y$
Residual Heat Removal Pump inservice testing:
inability to duplicate test conditions to ac-hieve test result repeatability; inability to meet TS acceptance criteria (inappropriate cri-teria); and erroneous test data assumptions.
Action was initiated by the Technical Advisory Group (STAS),on March 8-13, resulting in com-prehensive review and corrective actions. The capabilities evidenced during this period are indicative of improvements resulting from the assignment of surveillance program assessment functions to the STAS.
Contention K "The Beaver Valley 1 facility displayed evidence of weakness in the area of QA/QC."
1.
Basis References Inspections conducted during the evaluation IE Reports 50-334/
period reviewed selected outage activities 80-09, 80-16, 80-20
/
and both programmatic and implementation as-(
pects of modification activities identifisd
three items of noncompliance:
(failure to is-plement document control measures for system modifications; failure to implement and docu-ment corrective actions; and, failure to main-tain adequate records of safety reviews).
Program indicated a lack of understanding of QA requirements by onsite departments.
2.
NRC Action Referencas An enforcement conference was held in September IE Report 50-334/
1979 which addressed inadequacies in design 79-21 control and related QA/QC activities. Subse-quent followup inspections indicated substantial improvement in areas addressed at the enforce-IE Reports 50-334/
ment conference. Inspection of this area by 80-02, 80-08, 80-14, the resident inspectors have resulted in one 80-24, 81-07 NRC identified noncompliance, failure to im-plement and maintain procedures for calibration of safety-related instrumentation.
3.
Licensee Corrective Action References The licensee has completed a review of QA 8/6/80 Licensee training programs and has implemented ad-letter ditional training for all groups performing
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work at BVPS-1 and includes customized training i
id based on the needs of each group.
Training
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periods range from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to more than a week depending on the group.
The licensee has authorized and is acquiring additional QA and QC engineers and inspectors for assignment to respective department staffs.
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