ML20153F738
| ML20153F738 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/22/1998 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| 50-334-98-03, 50-334-98-3, 50-412-98-03, 50-412-98-3, NUDOCS 9809290225 | |
| Download: ML20153F738 (2) | |
See also: IR 05000334/1998003
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September 22,1998
Mr. J. E. Cross
President
Generation Group
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Duquesne Light Company
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Post Office Box 4
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Shippingport, Pennsylvania 15077
SUBJECT:
INTEGRATED INSPECTION 50-334/98-03,50-412/98-03
Dear Mr. Cross:
This letter refers to your September 4,1998 correspondence, in response to our
August 5,1998, 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.
Sincerely,
Original Signed By:
Peter W. Eselgroth, Chief
Projects Branch 7
Division of Reactor Projects
Docket Nos.: 50-334;50-412
cc w/o cv of Licensee Response Letter:
Sushil C. Jain, Senior Vice President, Nucisar Services Group
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R. Brandt, Vice President, Nuclear Operations Group and Plant Manager
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R. LeGrand, Vice President, Operations Support Group
B. Tuite, General Manager, Nuclear Operations Unit
W. Kline, Manager, Nuclear Engineering Department
M. Pergar, Acting Manager, Quality Services Unit
J. Arias, Director, Safety & Licensing Department
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J. Macdonald, Manager, System and Performance Engineering .
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cc w/cv of Licensee Resoonse Letter:
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M. Clancy, Mayor, Shippingport, PA
Commonwealth of Pennsylvania
. State of Ohio
State of West Virginia
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9809290225 98d922
ADOCK 05000334
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Mr. J. E. Cross
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- Distribution w/cv of Licensee Response Letter:
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Region l Docket Room (with concurrences)
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Nuclear Safety information Center (NSIC)
PUBLIC
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NRC Resident inspector
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H. Miller, RA/W. Axelson, DRA
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P. Eselgroth, DRP
N. Perry, DRP
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D. Haverkamp, DRP
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C. O'Daniell, DRP.
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B. McCabe, OEDO
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R. Capra, PD1-2, NRR
. D.- Brinkman, PDI-2, NRR
V. Nerses, PDI-2, NRR
R. Correia, NRR
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F. Talbot, NRR
DOCDESK
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\bv9803.rpy
' Ta meelve a sepy of this document. indicate in the box:
"C" = Copy without attachment / enclosure
"E* = Copy with attachment / enclosure
"N" = No copy
OFFICE
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OFFICIAL RECORD COPY
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Beaver Valley Power Station
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Shippingport, PA 15077 0004
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SUSH" C. JAIN
(412) 393-5512
Sento Vr.e President
Fax (724) 643-8069
Nuclear Services
Nuclear Power Division
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September 4,1998
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U. S. ' Nuclear Regulatory Conunission
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Attention: Document Control Desk
Washington, DC 20555-0001
Subject:
Besver Valley Power Station, Unit No. I and No. 2
BV-1 Decket No. 50-334, License No. DPR-66
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BV-2 Docket No. 50-412, License No. NPF-73
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Integrated Inspection Report 50-334/98-03 and 50-412/98-03
Reply to Notice of Violation
In response to NRC correspondence dated August 5,1998, and in accordance with
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10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the
subject inspection report.
If there are any questions concerning this response, please contact Mr. S. H. Hobbs
at (412) 393-5203.
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Sincerely,
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Sushil C. Jain
Attachment
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Mr. D. S. Brinkman, Sr. Project Manager
Mr. D. M. Kern, Sr. Resident Inspector
Mr. H. J. Miller, NRC Region I Administrator
Mr. C. W. Hehl, Director, Division of Reactor Projects, Region 1
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DELIVERING
0VALITY
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ENERGY
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DUQUESNE LIGHT COMPANY
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Nuclear Power Division
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Beaver Valley Power Station, Unit No. I and No. 2
Reolv to Notice of Violation
Integrated Inspection Report 50-334/95-03 and 50-412/98-03
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Letter Dated August 15,1998
VIOLATION (Severity LeveI IV, Supplement I)
Descrintion of Violation (50-334(412)/98-03-01)
Technical Specification 6.8.1.s requires that, ' written procedures shall be' established,
implemented and maintained covering ... the applicable procedures recommended in
Appendix "A" of Regulatory Guide 1.33, " Quality Assurance Program Requirements,"
Rev. 2, February 1978."
Appendix "A" of Regulatory Guide 1.33 recommends
procedures for surveillance testing, operation, and control of maintenance work
(including clearances) for safety related equipment.
Contrary to the above, during the period April 28 through June 8,1998, the licensee
failed to implement procedures as evidenced by the following examples:
1. Procedure 2OST-30.13A, " Train A Service Water System Full Flow Test," Rev. 8,
requires that the service water system be returned to the desired configuration as
directed by the nuclear shift supervisor / assistant nuclear shift supervisor.
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procedure was not properly implemented, in that on May 29, after conducting the
service water test, operators failed to properly restore service water to the "A" high
head safety injection pump.
The "A" high head safety injection pump was
improperly considered operable and was thus improperly credited as part of an
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operable boration flow path from June 2 to June 8. On June 8, a licensed operator
identified that service water was aligned to the "C" high head safety injection pump
and not the "A" pump.
2. Procedure 1/2 OM-48.1.D, " Operations Shift Rules of Practice," Rev. 25, requires
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' that if an instrument provides an apparent improper indication, the operator should
believe the instrument arui respond conservatively to prevent damage to station
equipment unless the inssrument indication is demonstrated to be false by checking
against at least two redundant instruments.
The procedure was not properly
implemented, in that on May 22, operators did not respond conservatively when the
branch flow line flow data for the high head full flow test indicated pump mnout
conditions. Testing continued without proper assessment of the indication of runout
flow and the potential adverse effects on the high head safety injection pump.
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Reply to Notice of Violation
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Inspection Report 50-334/98-03 and 50-412/98-03
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3. Procedure NPDAP 3.4, " Clearance / ragout Procedure," Rev. 9, requires a senior
reactor operator to verify that the tagout is properly prepared. The procedure was not
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properly implemented, in that on June 3, the clearance for exhaust fan 222-B was not
properly prepared and was posted. The clearance deenergized fan 222-B; however,
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the clearance also disabled the two emergency diesel generator room ventilation fans,
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which was not recognized.
Subsequently, the licensee identiGed EDG 2-2
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inoperability when operators attempted to start an emergency ventilation fan and it
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failed to start. EDG 2-2 was inoperable for approximately four hours.
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4. Procedure 2MSP-1.14B-I, " Train B Reactor Trip and Bypass Breaker Time Response
Test," Rev.1, step K.l.b requires the removal of the jumper that disabled the Unit 2
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general warning trip. The procedure was not properly implemented, in that on
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May 10, operators discovered that the jumper was still installed in the solid state
protection system. The technicians failed to remove the jumper on April 28 as
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required in the procedure, despite requirements for double verification.
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Reasons For The Violation
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For the examples cited in the violation, Examples 1 and 2 are attributable to a
combination of human performance deficiencies and procedure weaknesses.
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Example 3, the clearance was prepared based on load list information contained in the
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operating manual; however, this information was incomplete in that it did not provide
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details concerning the unique aspects of the circuit design. Example 4 was caused by a
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human performance error I.~ ae Instnament & Control (I&C) Technicians involved, who
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mistakenly believed that the procedure step to remove the jumper was optional.
Corrective Actions Taken and Corrective Actions Planned to Prevent Further Violations
The corrective actions taken for each example listed in the violation are as follows:
Examole 1
1. Condition Report 981236, concerning the service water full flow surveillance test,
was written on June 8,1998, to document the problem for evaluation and resolution
under the corrective action program.
2. Human performance issues related to Operations were reviewed by August 27,1998,
between the Operations Manager and the operating crews at the periodic
management-shift crew meetings that are held during the requalification training
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Reply to Notice of Violation
Inspection Report 50-334/98-03 and 50-412/98-03
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week.
These sessions were used by the Operations Manager to review the
Operations Standards and management expectations regarding human performance,
with emphasis on the need to reduce human performance errors.
3. The service water full flow surveillance test procedures (20ST-30.13A & B) were
revised on September 1,1998. Changes included instructions to ensure that service
water flow to the in-service high head safety injection (HHSI) pump is restored prior
to the swapping of service water trains and/or from exiting the test procedure.
Example 2
1. The issues brought to the attention of Operations management by the NRC inspectors
concerning the HHSI full flow surveillance test were immediately discussed with the
operating crews involved in the test. The crews were reminded of management
expectations and standards that emphasize the need to compare all process
indications when conflicting data is obtained and to stop and resolve problems
en-nuntered during plant operations and/or testing before proceeding.
2. Procedure weaknesses noted during the performance of the test were identified and
documented in an Operations Standard Surveillance performed on May 23,1998.
The Operations Standard Surveillance is a surveillance critiquing method periodically
used by the on-shift SROs to ensure surveillance procedures and their performance
meet management expectations for Operations standards, as well as providing for an
on-going quality check of procedural content and accuracy.
3. Condition Report 981251 was written on June 5,1998, to document the problem for
evaluation and resolution under the coaective action program.
4. The HHSI pump full flow operations surveillance test procedure (2OST-11.14B) was
revised on September 1,1998, to correct the deficiencies that were identified during
the May 23, 1998, performance. This surveillance test will be completed prior to
Beaver Valley Unit 2 (BV-2) entry into Mode 4 from its current extended outage.
Examole 3
1. Condition Report 981194, concerning the inadequate load list information on the
emergency diesel generator exhaust fans breakers, was written on June 3,1998, to
document the problem for evaluation and resolution under the corrective action
program.
2. The system power supply and control switch list, and MCC load list for the affected
breaker (s) were revised by September 3,1998, to note that the opening of the EDG
room exhaust fan breaker will render both EDG room supply fans unable to start due
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Reply to Notice of Violation
Inspection Report 50-334/98-03 ar.2 '0-412/98-03
Page 4
to the electrical configuration of the EDG room high temperature switch circuitry and
the interlock relationship between the two supply fans. The changes to the load lists
will help to ensure that future clearances for the EDG exhaust fans cannot occur
without due consideration of EDG operability.
3. A keyword search of the Condition Report (CR) data base (from 1997 on) was
performed to determine other CRs associated with the keywords " load list." This
search resulted in 12 CRs, which were reviewed and none were attributed to be
caused by a deficiency in the station's various breaker load lists. In fact, in several
instances the detail contained in the load lists contributed to corwervative decisions
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being made that either prompted further research prior to proceeding, or, in one
instance, greatly aided system restoration and contingency actions during the loss of a
power panel. The uniqueness of this particular circuit's configuration is believed to
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be a major contributor to this event, and therefore, similar problems of this type are
not anticipated to occur.
4. Condition Report 981194 will be reviewed by the Operations Manager by
October 31,1998, with the operating crews at the periodic management-shift crew
meetings that are held during the requalification training week, Review of the
condition report will be used to stress management expectations concerning the use
of proper self-checking techniques, clearance review and approval requirements, and
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the role of a questioning attitude.
Example 4
1. Condition Report 981172, conceming the general warning trip jumper, was written
on May 29,1998, to document the problem for evaluation and resolution under the
corrective action program.
2. The technicians involved with the performance of the procedure were counseled by
August 11,1998, on their failure to properly follow station procedures.
3. Procedures 2MSP-1.14A-I and 2MSP-1.14B-I were revised by August 20,1998, to
completely remove optional instruction steps.
4. This event and the STAR (Stop, Think, Act and Review) concept will be reviewed
with the Instrument and Control Technicians as part of their continuing training
program by October 31,1998. In addition, site relay crew personnel will also review
this event and the STAR concept as part of their continuing training program by
December 31,1998. This training will emphasize the use of proper self-checking
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techniques.
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Reply to Notice of Violation
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Inspection Report 50-334/98-03 and 50-412/98-03
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The examples listed above will also be included in scheduled training for the operating
crews as part of the License and Non-License Requalification Training by December 31,
1998. This training will be used to heighten sensitivity to human performance errors on
shift and review Operations Standards related to: conservative decision making when
challenged with instrument indication anomalies, pre-job briefing requirements,
communicating to the crew activities affecting safety-related equipment, use of proper
self-checking / peer-checking techniques, and initiating corrective actions for deficiencies
identified during surveillance testing.
In addition to the above, the following initiatives are being taken to improve human
performance:
1. BVPS recently introduced the STAR (Stop, Think, Act, and Review) concept at the
station as a preemptive measure to minimize human performance errors. Currently
being phased in station-wide, the STAR program is an improvement over the
previous BEST (Before Each Step Think) program as it includes a review step to the
self-checking sequence. STAR principles are emphasized to the operators during
simulator and on-the-job training (OJT) exercises to further underscore the
importance of proper self-checking and peer-checking techniques.
2. Prior to the startup of Beaver Valley Unit 1 (BV-1) from its extended outage, each
department conducted standdowns to emphasize the use of the STAR concept during
BV-1 startup activides. In addition, Operations managers and other senior managers
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provided 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day oversight of BV-1 startup activities to reinforce management
expectations and standards to site personnel.
Twenty-four hour management
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oversight will also be in place during BV-2 startup activities from the current outage.
Departmental standdowns are also planned prior to this BV-2 startup to re-emphasize
the STAR concept.
3. Management will formalize a human performance program at Beaver Valley Units 1
and 2. A plan and schedule for implementation of this program will be developed by
November 15,1998.
Date When Full Comoliance Will Be Achieved
1. Surveillance test 20ST-11.14B will be completed prior to BV-2 entry into Mode 4
from its current outage.
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2. Condition Report 981194 will be reviewed with the operating crews by October 31,
1998.
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Reply to Notice of Vislation
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Inspection Report 50-334/98-03 and 50-412/98-03
Page 6
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3. The examples cited in the violation will be discussed in Licensed and Non-Licensed
Requalification Training by December 31,1998.
4. Condition Report 981172 and the STAR concept will be reviewed in the continuing
training program for I&C Technicians by October 31,1998, and in the continuing
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training program for site relay crew personnel by December 31,1998.
5. Prior to BV-2 startup from the current outage, departmental standdowns will be
conducted to re-emphasize use of the STAR concept.
6. Senior and operations management will provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day oversight of BV-2
startup activities from the current outage.
7. A plan and schedule for implementation of a formal human performance program
will be developed by November 15,1998.
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