ML20154M243
| 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
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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
8806010223 880525
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Telephon. (412) 393.e000
Nucleer Group
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U.
S. Nuclear Regulatory Commission
Attn:
Document Control Desk
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
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
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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
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
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
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
benchboard identification of the instruments to be used.
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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
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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
to make it a common document for both Unit 1 and Unit 2, the Unit
1
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
Page 1 of 6
CATEGORIES OF DEFICIENCIES
COMPLETION
DATE
1.
Administrative Program
Problem Area- The Procedures Section receives Operations and
Training personnel EOP feedback via the
4
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
sheets to include sufficient justifications of
,
deviation and include an independent reviewer
sign-off.
12-31-88
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b. These deviation sheets will be typewritten
and administratively controlled by a PSP.
3-31-89
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Page 2 of 6
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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:
Some steps failed to properly use
a. Logic Terms
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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 &
The EOPs contained a number of
Branching
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transition terms which were
undefined in the Writer's Guide and
inconsistent with the guidance
provided,
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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",
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"Stable" (no range included), and
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"maintain" (without requirements).
c.
Equipment
Steps that use control board
nomenclature
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switches and indication did not use
exact placard nomenclature.
This
is in violation of the Writers
Guide,
f.
Abbreviations &
Some abbreviations and acronyms
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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
The verification program failed to
Nomenclature
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correctly translate control room
plant switch and indicator
nomenclature into the EOPs.
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1.
Mental Calculations- Several steps in E-0 required to
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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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-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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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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Page 6 of 6
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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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