ML20154M243

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-334/88-02

ML20154M243
Person / Time
Site:	Beaver Valley
Issue date:	05/25/1988
From:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	DUQUESNE LIGHT CO.
References
NUDOCS 8806010223
Download: ML20154M243 (1)

See also: IR 05000334/1988002

Text

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MAY 251988

Docket No. 50-334=

Duquesne Light Company

Post Office Box 4

Shippingport, Pennsylvania- 15077

Gentlemen:

Subject: Inspection No. 50-334/88-02

This refers to your letter dated May 13, 1988, in response to our letter dated

April 14, 1988.

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,

ROBERT M. GALLO

Robert M. Gallo, Chief

Operations Branch

Division of Reactor Safety

cc:

Public Document Roon (PDR)

Nuclear Safety Information Center (NSIC)

bcc:

Region I Docket Room (w/ concurrences)

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0FFICIAL RECORD COPT REPLY LTR 50-334 - 0001.0.0

05/19/88

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Telephon. (412) 393.e000

Nucleer Group

$nSopinaport. PA 15077 0004 '

U. S. Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, DC 20555

Reference: Beaver Valley Power Station, Unit No. 1

Docket No. 50-334, License No. DPR-66

Inspection Report 88-02

Gentlemen:

In response to NRC correspondence dated April 14, 1988 and in

accordance with 10 CFR 2, Appendix C, the attached reply addresses

the Notice of Deviation which was included with the referenced

report.

If there are any questions concerning this response, please

contact my office.

Very truly yours,

ObM

J. D. Sieber

Vice President

Nuclear Group

Attachment

cc: Mr. J. Beall, Sr. Resident Inspector

Mr. W. T. Russell, NRC Region I Administrator

Mr. Robert M. Gallo, Chief, NRC Region I Operations Branch

Director, Safety Evaluation & Control (VEPCO)

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DUQUESNE LIGHT COMPANY

Nuclear Group

Beaver Valley Power Station, Unit No. 1

Reply to Notice of Deviation

Inspection 88-02

Letter dated April 14, 1988

DE'/I ATION ( 68-02-01)

Description of Deviation

NRC Generic Letter 82-33 (GL 82-33) identified basic requirements for

upgrading their emergency response capabilities. Duquesne Light

Company responded to one of the basic requirements of GL 82-33,

upgrading of their Emergency Operating Procedures, in letters dated

June 28, 1984 and April 8, 1987. In these letters Duquesne Light

Company committed to using an NRC approved Procedures generation

Package (PGP) for upgrading their EOPs. The NRC approved PGP

contains decalled instructions for the preparation of the Emergency

Operating Procedures and Background Information.

Contrary to the above, as of February 5, 1988, many of the Emergency

Operating Procedures and the Background Information did not adhere to

the guidelines in the PGP. Some examples of this deviation are as

follows:

1. Contrary to PGP Appendix A Section V.E.4.e, Step 7 of EOP ECA-0.0

uses the logic term IF NOT without specifying a first condition

by the use of an IF statement.

2. Contrary to PGP Appendix A Section V.H.2, Step 23 of EOP E-0

requires two transitions in the same step and uses "complete" to

transition to other steps rather than the recommended term "GO

TO".

3. Contrary to PGP Appendix A Section V.F.1 and 6, EOP E-O page 23

contains a "CAUTION" which lacks identification for the hazard

and includes an action statement.

4. Contrary to PGP Appendix A Section V.B.1, Step 5.C of EOP E-3.1

uses two complex sentences which deal with more than one task in

an action statement rather than using concise steps which deal

with only one task.

5. Contrary to PGP Appendix B Section IV.A.4.e, the Step Description

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Tables in the Background Information do not include the

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benchboard identification of the instruments to be used.

Further examples are detailed in Inspection Report 50-334/88-02.

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R; ply to Notica of Deviction

Incpection 88-02

. Letter dated April 14, 1988

Page 2

Corrective Action Taken

Based on the deficiencies identifie6 u ing the inspection, a review

of the Beaver Valley Unit 1 PGP and E01 was conducted to determine

the actions necessary to resolve and eziminate these deficiencies.

Following this evaluation, the items were organized into six

deficiency categories and an action plan was developed for each.

Attached is the action plan with a completion schedule for the

deficiency categories. Due to a recent change to the Beaver Valley

PGP to make it a common document for both Unit 1 and Unit 2, the Unit

1 EOPs were previously scheduled for revision. The completion

schedule provided in the action plan is consistent with our previous

planned actions.

Action Taken to Prevent Recurrence

Completion of the tasks in the action plan should prevent recurrence

of these issues.

Date of Full Compliance

As provided in the action plan schedule, all tasks should be

complated by March 31, 1989.

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18e; var Vellsy Powar Station, Unit.No. 1

Dockst No.' 50-334,- Licanco No. DPR-66

Inspection Report 88-02

Attechment

BVPS UNIT 1 EOP ACTION PLAN

Page 1 of 6

CATEGORIES OF DEFICIENCIES COMPLETION

DATE

1. Administrative Program

Problem Area- The Procedures Section receives Operations and

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Training personnel EOP feedback via the

Operating Manual Deficiency Report (OMDR)

process. However there is no written

administrative program for the disposition of

OMDRs.

Action Plan- The Procedures Section will revise the

Procedures Section Procedures (PSPs) to explain

how approved OMDRs are resolved and' processed. 12-31-88

2. EOP-ERG Deviation Sheets

Problem Area- Numerous deviation sheets that were reviewed

contained inconsistencies and often lacked

sufficient detail to explain technical reasons

, for deviations. Deviation sheets lacked

administrative control. Several deviation

sheets were missing.

Action Plan- a. The Procedures Section will revise deviation

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sheets to include sufficient justifications of

deviation and include an independent reviewer

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sign-off. 12-31-88

I b. These deviation sheets will be typewritten

and administratively controlled by a PSP. 3-31-89

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BVPS UNIT 1 EOP ACTION PLAN

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Page 2 of 6

3. EOP Background Documents

Problem Area- Majority of step background documents lack

specific control board instrumentation mark

numbers. Many background documents did not

contain technical references.

Action Plan- The Procedures Section will revise the

background documents to ensure they all

reference qualified specific instrumentation

mark numbers where needed for each step.

References have been added to numerous

background documents revised since Rev 0. Not

all documents will have a reference until the

associated EOP steps are reviced. 12-31-88

4. EOP ECA-0.0

Problem Area- Portions of several steps between Steps 10

through 30 contain actions that cannot be

performed due to loss of power condition.

Although each of these steps is usable, these

steps need to be reevaluated and revised to

only include all of the required actions that

can be performed.

Action Plan- a. A Procedures Engineer and a Reactor Operator

walked down ECA-0.0 on 3-16-88 to identify

those actions not capable of being performed

during loss of power. These discrepancies are

all documented on OMDR 1-88-0416. 3-16-88

b. This OMDR will be incorporated into the Unit

1 EOPs. 12-31-88

5. Human Factors Concerns:

PROBLEM AREAS:

a. Logic Terms -

Some steps failed to properly use

logic terms "E , THEN" ; " E NOT,

THEN"; "AND" ; and "OR_". In

addition the auditors disagreed

with the Writers Guide requirement

to emphasize "or" and "and" where

joining actions, alternatives or

conditions,

b. Referencing &

Branching -

The EOPs contained a number of

transition terms which were

undefined in the Writer's Guide and

inconsistent with the guidance

provided,

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BVPS UNIT 1 EOP ACTION PLAN

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c. Notes & Cautions - Some cautions and notes were found

to contain actions. Some cautions

lacked statements of the hazard at

hand and possible consequences.

d. Sentence Structure- Some steps contained more than one

action or task. Identified some

deviations from the Writers Guide

for the use of substep lettering or

numbering, and the use of substep

bullets. Some steps used vague

terms such as "as necessary",

l "Stable" (no range included), and

l "maintain" (without requirements).

c. Equipment

nomenclature -

Steps that use control board

switches and indication did not use

exact placard nomenclature. This

is in violation of the Writers

Guide,

f. Abbreviations &

Acronyms - Some abbreviations and acronyms

used in the EOPs are not approved

for use by the EOP Writers Guide.

g. Use of RNO column - Several steps in the EOPs had a

contingency action in the left

column. Some other steps needed to

include additional contingency

actions in the RNO column.

h. Benchboard

Nomenclature - The verification program failed to

correctly translate control room

plant switch and indicator

l nomenclature into the EOPs.

l 1. Mental Calculations- Several steps in E-0 required to

I have the operator perform simple

mental addition or subtraction.

This is in violation of the EOP

Writers Guide.

j. Instrumentation -

Numerous EOP steps and step

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background documents failed to list

all required instrumentation used

to perform EOP steps.

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BVPS UNIT 1 ECP ACTION PLAN

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-ACTION PLAN TO HUMAN FACTORS CONCERNS:

The EOPs will be revised to address the following

concerns: 12-31-88

1) To properly utilize logic terms, notes, cautions and

action steps in accordance to the EOP Writers Guide.

Also the EOP Writers Guide will be revised to strengthen

the instructions on use of logic terms, conjunctions and

the system of step numbering and identification (e.g.

lettering of substeps versus use of bulleted substeps).

2) Transitions terms presently used in the EOPs (e.g.

perform, do, continue with) will be reviewed and changed

for consistency with the Writers Guide.

3) The use of vague terms and double negative terms in

the EOPs will be eliminated (where possible).

4) The steps throughout the EOPs will be revised to

include the new control board switches nomenclature

resulting from the Control Room Design Review changes.

The NRC inspectors were aware of the control board

design changes in progress during the audit. Since the

NRC audit, the EOP CIA, SI and CIB checklists were

revised to include new control board switches

nomenclature. Annunciator AS-9 has already been

incorporated into procedure E-0.

5) The EOPs and EOPs Writers Guide will be revised to

utilize only the abbreviations and acronyms approved by

chapter OM 1/2.48.

6) All steps in the EOPs will be evaluated and verified

to contain adequate contingency actions (where

necessary) in the RNO column.

7) The need to perform mental calculations in EOP steps

will be evaluated and eliminated where possible.

8) Review EOP steps and step background documents.

Ensure all required instrumentation is listed for each

step.

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BVPS UNIT 1 EOP ACTION PLAN

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6. Procedures Generation Package:

A. Problem Area- Several technical errors were discovered in

the ERG Reference Plant /BVPS Unit 1

Difference document of the PGP. The

technical errors included difference

between the plants CCW (CCR) systems, CIA

systems, and Containment Depressurization

systems.

Action Plan- The PGP will be revised to correct the

discrepancies identified during the audit,

and to evaluate and ensure the other

differences are technically correct. 12-31-88

B. Problem Area- The ERG-EOP Deviation Sheet (form) needs to

be revised to include an independent

reviewer's signature to ensure the

justifications of the deviations from the

ERGS are accurate, complete and legible.

Action Plan- The PGP will be revised to include a new

deviation form that addresses the above

concern. All deviation sheets will be

reviewed by an independent EOP procedure

engineer to ensure the objective above is 12-31-88

met.

C. Problem Area- The NRC inspectors reviewed the

documentation of five plant specific

setpoint documents and determined that the

engineering analysis to support those

setpoints was not referenced in all cases.

Action Plan- The BV-1 preliminary setpoints documents

will be formalised into a controlled

setpoints document that will, as a minimum,

reference all supporting engineering

analysis and list plant instrumentation

qualified for use of monitoring the 3-31-89

setpoints in the EOPs.

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l'VPS UNIT 1 EOP ACTION PLAN

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D. Problem Area- There has been no human factors or quality

assurance (QA) involvement in the

validation of the latest revision of the

EOPs.

Action Plan- Only a table top validation and a simulator

validation were required for the latest EOP

revision.

• PGP Appendix C (Table Top Validation) Section

II.A.l.b does not require human factors review.

• PGP Appendix D (Walk-Through Validation)

Section II.A.l.b states that a human factors

review should be performed during this phase of

validation.

• PGP Appendix E (Simulator Validation) Section

II.A.2. states that a human factors review is

optional during this phase af validation.

a. Eecause a walk-through validation was not

required, no human factors review was necessary

during this validation process of the latest

EOPs revision. Therefore the EOPs are in

compliance with the above listed sections of NO DATE

the PGP. REQUIRED

b. The PGP does not require QA involvement ,

during the EOP validation process. However QA

will perform audits of the EOP revision process

to verify conformance to PGP requiraments. 12-31-88

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