ML20140G334
| ML20140G334 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/06/1997 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| 50-334-96-10, 50-412-96-10, NUDOCS 9706160150 | |
| Download: ML20140G334 (2) | |
See also: IR 05000334/1996010
Text
.
.
June 6, 1997
Mr. J. E. Cross
President
Generation Group
Duquesne Light Company
.
Post Office Box 4
Shippingport, Pennsylsania 15077
'
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-334/9610,50-412/96-10 AND
. Dear Mr. Cross:
This letter refers to your April 23,1997 correspondence, in response to our
February 21,1997 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
l
Sincerely,
Original Signed By:
Peter W. Eselgroth, Chief
Projects Branch 7
i
'
Division of Reactor Projects
Docket No.
50-334,50-412
cc: w/o cv of Licensee's Resoonse Letter
l
Sushil C. Jain, Vice President, Nuclear Services
'
R. LeGrand, Division Vice President, Nuclear Operations Group & Plant Manager
l
R. Hansen, Acting Manager, Nuclear Engineering Department
B. Tuite, General Manager, Nuclear Operations Unit
l
K. L. Ostrowski, Manager, Quality Services Unit
l
J. Arias, Director, Safety & Licensing Department
I
cc: w/cv of Licensee's Resoonse Letter
M. Clancy, Mayor
Commonwealth of Pennsylvania
l
State of Ohio
'(
i
(
'
9706160150 970606
>
{llllllllllgglgi
j
gDR
ADOCK 0500
4
c
.......
-
.
. . . - . . . - . . . -
I
..
.
Mr. J. E. Cross
2
Distribution w/cv of Licensee Response Letter
Region i Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
,
j
D. Screnci, PAO
P. Eselgroth, DRP
.
'
D. Haverkamp, DRP
J. Nick, DRP
l
C. O'Daniell, DRP
i
J. Stolz, PDI-2, NRR '
!
W. Dean, OEDO
'
l
R. Correia, NRR
j
j
F. Talbot, NRR
'
DOCDESK
j
inspection Program Branch, NRR (IPAS)
!
l
l
i
l
DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\BV96-10.rpy
'
Ta receive a copy of this document, indicate bi the box: "C" = Copy without attachment /enclosura
"E" = Copy with attachment / enclosure
"N" = No copy
OFFICE
Rl(D,RPp
l
Rl/DRS
l
/
l
l
NAME
PW
i
DATE
4 g /97
/ /97
OFFICIAL RECORD COPY
'
i
a
4
!
1
l
l
.
_
-
.__
- _
-
_ . _ _
-- -
. , -
.
M
Beaver Valley Power Station
.
(
Shippingport, PA 15077 0004
SUSHIL C. JAIN
(412) 393-5512
Division Vice President
Fax (412) 643 8069
Nuclear Services
Nuclear Power Division
April 23, 1997
U. S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. I and No. 2
BV-1 Docket No. 50-334, License No. DPR-66
BV-2 Docket No. 50-412, License No. NPF-73
Reply to Notice of Violation
In response to NRC correspondence dated March 24,1997, and in accordance with
10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the
letter.
The cited events were discussed in NRC Inspection Report Nos. 50-334/96-10,
,
50-412/96-10 and also during a Predecisional Enforcement Conference held on March 7,
1997.
If there are any questions concerning this response, please contact Mr. J. Arias,
Director, Safety & Licensing at (412) 393-5203.
Sincerely,
Sushil C. Jain
Mr,. D. M. Kern, Sr. Resident Inspector
c:
yt. H. J. Miller, NRC Region I Administrator
Mr. D. S. Brinkman, Sr. Project Manager
!
l
'
DEllVERING
i
QU AltTY
ENERGY
-Q W
UOD&
~)@
. . -
.
_ -
- - - .
- _ . _ . .
-
-
_
_.
--
.-
.
.
.
.
.
'
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF BEAVER
)
L
Subject:
Beaver Valley Power Station, Unit No. I and No. 2
BV-1 Docket No. 50-334, License No. DPR-66
BV-2 Docket No. 50-412, License No. NPF-73
Reply to Notice of Violation EA 97-076
<
1
,
!
Before me, the undersigned notary ^ public, in and for the County and
Commonwealth aforesaid, this day personally appeared Sushil C. Jain, to me known,
who being duly sworn according to law, deposes and says that he is Division Vice
l
President, Nuclear Services of the Nuclear Power Division, Duquesne Light Company,
,
i
he is duly authorized to execute and file the foregoing submittal on behalf of said
l
Company, and the statements set forth in the submittal are true and correct to the best of
his knowledge, information and belief.
&no_'&
'
l
Sushil C. Jain
~
1
Subscribed and sworn to before me
a
-
.
..
on thisfi day of (4guj, / T/ '/
I
L
d/ ?1/ 5 /!til'n<' A?
l
N'otary Public
!
Neuw seg
Bee
~ w an%
u . ~. := - _
-
_
_
_
_ . . _ -. _ .-_. _ _. _ _ _ _ _ __ _ _ _ _ . __ _ _ _ _ _ _
.
.
.
.
.'
DUQUESNE LIGHT COMPANY
j
Nuclear Power Division
i
Beaver Valley Power Station, Unit Nos. I and 2
Reply to Notice of Violation
Letter dated March 24.1997
VIOLATION (Severity Level HI; Supplement I)
EA 97-076
I
l
A.
Technical Specification (TS) 6.8.1.a requires that written procedures be properly
l
established and implemented covering activities recommended in Appendix A to
i
NRC Regulatory Guide 1.33, Revision 2, " Quality Assurance Program
i
Requirements (Operation)." Section 3 of Appendix A to Regulatory Guide 1.33
specifies that procedures be established for operation of safety related systems.
Procedure 1/2 OM-48.2.C, " Adherence and Familiarization to Operating
l
Procedures," Rev.17; NPDAM 1.2.1, " Establishment of written directives and
!
procedures," Rev. 3; and Chemistry Manual Chapter 3, " Sampling and Testing,"
(
Rev. 7, specify criteria for implementing procedures as written.
Contrary to the above, on numerous occasions, licensee staff did not implement
procedures as written, as evidenced by the following examples.
1.
When : repeatedly depressurizing the Unit 2 residual heat removal (RHS)
system from January 23 to January 30, 1997, operators and chemistry
,
technicians did not properly implement station procedures 20M-10.4.C,
'
" Residual Heat Removal System Shutdown," Rev. 20, and CM 2-3.40
Part D, "RHS Grab Sample Purging to Sample Sink," Rev. 6. Specifically,
a.
Operators did not perfonn RHS depressurization as specified in
procedure 20M-10.4.C in that although operators had reviewed 20M-
10.4.C, they continued to depressurize RHS based on their memory of
the procedure instead of performing and signing off the procedure step-
by-step, as required by Procedure 1/2 OM-48.2.C; and,
b.
Chemistry technicians did not properly perform steps in procedure CM
2.3-40 in that steps to reposition 2SSR-SOV129A1/A2 were performed
out of the required sequence in Sequence D of the procedure, and Valve
,
l
SS-175, a primary system sample valve, was not returned to the correct
position.
l
WP
- -
-
.
. _ _ _ . _ _
_ _ _ . -
._ _ . _ _ _ . _ - _ _ _ . _ _ .
. - - -
.
,
.
Reply to Notice of Violation
Page 2
These errors contributed to . mispositioning Valve SS-175, which
unexpectedly altered the existing RHS depressurization lineup.
2.
On January 14,1997, Unit 1 operators failed to properly implement station
procedures OM 1.15.4.H, " Securing a component cooling water (CCR)
pump or placing the spare CCR pump in service," Rev.1, and 10M-
15.3.B.1, " Valve List-1CCR," Rev. 7, when securing the 'C' CCR pump.
Specifically, the operators did not shut the 'C' CCR pump discharge valve,
ICCR-9, as specified by the Procedure OM 1.15.4.H, Step IV.C.4.b.2, and
also failed to annotate system configuration drawings and procedures to
reflect this change, as required by Procedure 1/2 OM-48.2.C, Step VI.B.15.
B.
Beaver Valley Power Station Technical Specification 4.11.2.6.1 requires oxygen
concentration to be monitored during waste gas decay tank (WGDT) filling
operations to ensure that an explosive gas mixture is not present.
Contrary to the above, operators failed to monitor oxygen concentration when
running the degasifier to the waste gas decay tank (WGDT) on November 30,
1996, since operators had inadvertently deenergized both Unit 1 oxygen analyzers
l
on November 25,1996, a repeat problem caused by corrective actions previously
!
implemented to address a known human factors issue (look-alike control
switches) not precluding recurring misoperation of the oxygen analyzer control
!
switches.
!
C.
10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that
l
measures be established to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, defective material and equipment,
and nonconformances are promptly identified and corrected.
In the case of
significant conditions adverse to quality, the measures shall assure that the cause
i
of the condition is determined and corrective actions taken to preclude repetition.
l
Contrary to the above, following the identification of mispositioned service water
l
valves 2SWS-82 on July 14,1995, and 2SWS-MOV-105D on October 3,1995,
l
and other mispositioned components during this time period, which represented a
'
condition adverse to quality involving inadequate management of plant
configuration control, the licensee did not take appropriate measures to correct
this condition adverse to quality and prevent recurrence, as evidenced by the fact
t
that numerous component mispositionings occurred which were identified by the
i
licensee during the period September 1996 to February 1997.
Poor work
practices, personnel errors, and failure to properly implement station procedures
continued to result in component mispositionings.
Several of the affected
I
components were on safety related systems, including the emergency diesel
.
.
.
.
.
_
..
..
.
.
.
.
.
.
Reply to Notice of Violation
,
Pye3
-
generator, component cooling reactor, service water, and auxiliary feedwater
systems.
Reasons for the Violation
A.
Procedures were not followed as written due to lax enforcement of standards,
policies and administrative controls.
B.
Recurring misopastion of the oxygen analyzer control syritches occurred because
the switches were susceptible to human factors related errors, and inadequate
operator self-checking and attention to detail.
C.
Whi*e ;orrective actions were taken for the 199. <..ispositioning events, these
actions were not effective in minimizing these type of events. An effectiveness
review was not conducted in a timely manner following the completion of the
corrective actions for these events.
Corrective Actioqilaken
1.
Mispositioned components were evaluated and restored to their correct positions.
2.
Problem or Condition Reports were initiated as appropriate, to document the
events and determine corrective actions.
i
3.
The appropriate personnel were counseled on perfonnance problems and
management expectations.
4.
The valve list (10M-15.3.B.1) was revised by February 21,1997, to change the
normal system arrangement (NSA) of valve ICCR-9 to open.
5.
The procedure (10M-15.4.H) for operating the IC CCR Pump was revised by
February 21, 1997, to reflect the new NSA of the pump's discharge valve
i
'
i
6.
Unit 1 and 2 operator logs were revised by January 24,1997, to strengthen the
l
monitoring of oxygen analyzers O2AS-GW-110-1 and 2.
7.
Procedure 10M-19.4 G was revised by January 21, 1997, to verify proper
operation of oxygen analyzers 02AS-GW-110-1 and 2 prior to transferring gas
l
from the surge tanks to the w. te gas de=y tanks.
l
1
,
,
,
\\
Reply to Notice of Violation
,
Page 4
.
8.
A protective aluminum cover war 5 stalled over the power switch for oxygen
analyzers 02AS-GW-110-1 and 2 to provide a barrier to prevent misoperation due
to confusing the power switch for the pressure override switch.
9.
The Vice President, Nuclear Operations issued a letter on February 13,1997, to
all plant personnel to clearly c~nmunicate management's expectations regarding
the control of valves, use of procedures, and completing a procedure in its
,
entirety. In addition, restrictions were imposed to limit the approved means by
which valves can be manipulated. Emphasis was placed on the impodance of
precluding and correcting these types of problems as they are precursors to more
significant events.
Actions Taken to Prevent Recurrence
1.
On March 6,1997, the Independent Safety Evaluation Group (ISEG) completed
an evaluation of mispositioning events reported in Problem or Condition Reports
since July 1,1995. The ISEG review identified vveral recommendations for
reducir,3 mispositioning events which are being tracted on the Commitment
Action Tracking System.
,
2.
A change notice has been submitted to revise the Unit 1 UFSAR during the next
annual update to reflect the change in NSA position for ICCR-9.
'
3.
Valve, switch and breaker positian verifications were performed on safety
systems identified by Operating Imnual Table 48.2.C-1 in those areas normally
accessible during power operation to baseline the current status of these
t
components against their normal system arrangement. These verifications were
completed by April 14, 1997. This baseline was completed to facilitate a self-
assessment of the effectiveness of corrective actions for these occurrences.
4.
A review of procedures which manipulate components is ongoing to ensure that
the final system condition is consistent with the NSA, or otherwise that the off
normal condition is administratively controlled.
5.
Additional self-checking training using a self-checking simulator was provided to
in-plant operations personnel by April 10,1997.
6.
Small (2 inch and under) safety related ball valves that have the potential to be
moved through inadvertent centact with personnel are being immobilized in
position. In addition an evaluation will be completed in regards to securing safety
emw
-
_.
_
_ _ . -
.
_
_ . . _ . . . . _ . . _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ .
.
.
.
,
.
i
!
Reply to Notice of Violation
q
Page 5
.
related ball valves 2 inches and larger. This effort will be completed by May 31,
1997,
1
7.
A construction standard was issued by March 14,1997, which details the conduct
of pre-job walkdowns and the precautions to be taken while working near plant
equipment during normal operation to minimize the potential for inadvertent
contact.
8.
Administrative controls for valve manipulation were enhanced and incorporated
into Operating Manual 1/2OM-48.3.D, " Administrative Control of Valves and
)
,
Equipment" by March 19,1997.
9.
The procedural controls and ownership of operator workarounds are being
reviewed to insure that they are adequate and well defined. This review will be
- completed by May 31,1997.
10.
A program will be developed for retiring plant equipment. This program will be
incorporated into appropriate procedures by August 15,1997.
I 1.
. Operations will perform a self-assessment on the effectiveness of these corrective
actions by September 30, 1997, by monitoring the number and type of
mispositioning events that have occurred since April 15,1997.
Date When Full Compliance Will Be Achieved
The next annual update of the Unit 1 UFSAR is scheduled to be submitted by July 31,
1997.
The effort to immobilize ball valves in position will be completed by May 31,1997.
The review of procedural controls and ownership of operator workarounds will be
completed by May 31,1997.
The program for retiring plant equipment will be incorporated into appropriate
procedures by August 15,1997.
The self-assessment on the effectiveness of corrective actions for mispositioning events
will be completed by Septemoer 30,1997.
l
'
,.
i
-
__
_
.