ML20196H323

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Insp Repts 50-334/98-06 & 50-412/98-06 on 981004-1114.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Engineering,Maint & Plant Support
ML20196H323
Person / Time
Site: Beaver Valley
Issue date: 12/02/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196H312 List:
References
50-334-98-06, 50-334-98-6, 50-412-98-06, 50-412-98-6, NUDOCS 9812090045
Download: ML20196H323 (24)


See also: IR 05000334/1998006

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

License Nos. DPR-66, NPF-73

Report Nos. 50-334/98-06,50-412/98-06

Docket Nos. 50-334,50-412

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Licensee: Duquesne Light Company l

Post Office Box 4 '

Shippingport, PA 15077

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Facility: Beaver Valley Power Station, Units 1 and 2 )

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Inspection Period: October 4,1998 through November 14,1998

Inspectors: D. Kern, Senior Resident inspector

G. Dentel, Resident inspector

G. Wertz, Resident inspector

D. Brinkman, Project Manager, NRR

D. Haverkamp, Project Engineer, DRP

N. Perry, Project Engineer, DRP

J. Furia, Senior Radiation Protection Specialist

Approved by: P. Eselgroth, Chief

Reactor Projects Branch 7

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9812090045 981202

PDR ADOCK 05000334

G PDR

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EXECUTIVE SUMMARY

Beaver Valley Power Station, Units 1 & 2

NRC Inspection Report 50-334/98-06 & 50-412/98-06

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This integrated inspection included aspects of licensee operations, engineering,

maintenance, and plant support. The report covers a 6-week period of resident inspection;

in addition, it includes the results of an announced inspection by a senior radiological i

protection specialist.

Operations

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On November 1, Unit 2 operators performed a technical specification required l

shutdown due to an inoperable station battery. The shutdown was performed in a l

controlled manner and communications during reactivity changes were clear. The .

lessons learned critique following the forced outage was productive and identified  !

several recommendations to improve the organization's ability to respond to

degraded material conditions. (Section 01.2) -

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  • In response to a loss of annunciator panel "A-9" on October 15, the Unit 1 control  ;

room Assistant Nuclear Shift Supervisor developed and implemented a I

comprehensive plan to verify safety significant plant parameters. (Section 01.3)

  • Submittal of the license amendment request for a one time extension of the Unit 2 ,

fast bus transfer surveillance test was not timely in that it would have required an

expedited review by the NRC staff to meet the requested completion date. The l

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subject test was not a new requirement and the potential need for the amendment l

was previously known by the licensee. The untimely submittal represented a  !

continued weakness in planning and scheduling of TS surveillance tests, and i

amendment requests. (Section 08.1)  ;

  • The Management Review Team effectively assessed equipment condition and  ;

proposed repair actions for the multiple equipment problems experienced on Unit 1, I

October 15. System engineering and maintenance participation contributed to ,

effective problem solving. Previous action to correct the reactor coolant system I

flow spiking was slow and ineffective. (Section 08.2)

Maintenance

  • Maintenance repair work activities on the main steam pressure, loop 2, channel 2

pressure bi-stable and the "A-9" Annunciator Panel fuse replacement were

performed promptly and effectively in a technically sound manner. Minor

discrepancies were identified in the maintenance work request and in the fuse

failure root cause determination. (Section M1.1)

  • The "A" train of supplementalleak collection and release system remained

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inoperable for over 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in part due to poor communication between the

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operating crew and the system engineer, and demonstrated operator weaknesses in

evaluating degraded conditions. (Section M1.3)

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Enhanced individual cell voltage monitoring due to station battery degradation was

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! * The licensee identified and corrected severallong-standing design issues. The

l discoveries demonstrate a continued questioning attitude. (Section E8.5, E8.6, and

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E8.8)

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l Engineers conducted a detailed review of Unit 2 safety related logic testing as

a requested in NRC Generic Letter 96-01. Ten separate logic testing discrepancies

I were identified and resolved. Correction of these deficient conditions improved the

j reliability of severalimportant safety systems. Enforcement discretion in

j accordance with Section Vll.B.3 of the Enforcement Policy was exercised for these

I longstanding deficiencies. (Section E8.7)

Plant Sucoort

  • An effective program for the collection, processing, transport and disposition of

radioactive materials and radwaste has been established. All reviewed shipments

were determined to be in accordance with applicable regulations. Waste processing

conducted in accordance with the Process Control Program was found to meet the

standards for waste form and classification. (Section R1)

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  • Effective radiological controls were established and implemented during the clean

out of various sumps and tanks located in the radiologically controlled areas.

(Section R1)

  • The program for the training of HAZMAT employees handling radioactive materials

was effectively established and implemented. All personnel involved in these

activities were determined to be knowledgeable of the regulations. (Section RS)

  • An effective program for the review of the Process Control Prograrn and related

radwaste and transportation activities, including those activities performed by

vendors has been established, including an effective corrective actions tracking and

resolution process as demonstrated by the scope and quality of audits and

surveillances performed. (Section R7)

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i TABLE OF CONTENTS

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EX EC UTIV E S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

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l TA B LE O F C O NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii l

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i. Operations .................................................... 1

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i O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 )

O 1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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01.2 Unit 2 Forced Shutdown due to Inoperable Station Battery . . . . . . 1 ,

! 01.3 Response to Loss of Unit 1 Annunciator Panel "A-9" . . . . . . . . . . 3 '

i O2 Operational Status of Facilities and Equipment ................... 3

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O2.1 Engineered Safety Feature System Walkdowns . . . . . . . . . . . . . . 3

08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

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08.1 License Amendment Request (71707) . . . . . . . . . . . . . . . . . . . . 4 l

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08.2 Management Response to Multiple Unit 1 Equipment Problems . . . 4 l

08.3 (Closed) VIO 50-334/97-11-02: Failure of Operators to Log TS LCO

} Entries and Perform Proper Shift Turnover ................. 5

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i 11. M a int e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

!i M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1

l M 1.1 Routine Maintenance Observations ...................... 5 l

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M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 6

M1.3 Unplanned LCO Time During Unit 2 Maintenance . . . . . . . . . . . . . 6

M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

M8.1 (Closed) Licensee Event Report (LER) 50-334/97-38-01 . . . . . . . . 7

j M8.2 (Closed) LER 5 0-3 34 /9 8- 16 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1 M8.3 (Closed) LER 5 0-41 2/9 8-06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

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i Il l . En g i n e e ri ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l

j E8 Miscellaneous Engineering Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

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E8.1 (Closed) LER 5 0-3 34/9 7-3 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

j E8.2 (Closed) LER 50-334/97-35-00,01 ..................... 8 l

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E8.3 (Closed) LER 5 0-3 3 4/9 7-3 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 l

E8.4 (Closed) LER 5 0-412/9 7-0 8-01 . . . . . . . . . . . . . . . . . . . . . . . . . 8 i

j EB.5 (Closed) LER 5 0-412/9 7- 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

E8.6 (Closed) LER 5 0-412/9 8- 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

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{ E8.7 (Closed) Unit 2 LERs Associated With NRC Generic Letter 96-01  !

j R e vi e w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

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E8.8 (Closed) LER 5 0-412/9 8- 1 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 -

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j I V. Pl a nt S u p p ort . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 12

R5 Staff Training and Qualification in RP&C . . . . . . . . . . . . . . . . . . . . . . . 14 j

R7 Quality Assurance in Radiological Protection and Chemistry Activities . . 15

V. M a na g e m e nt Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

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X1 ' Exit Meeting Sum m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

X2 - Management Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ 16

INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

LIST OF ACRONYMS USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

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Report Details  !

Summarv of Plant Status

Unit 1 remained at full power throughout this inspection period.

Unit 2 began this inspection period at 100 percent power. On November 1, the plant was i

taken to hot standby due to a station battery cell voltage value falling below the Technical l

Specification requirement. The inoperable battery cell was replaced along with three i

additional cells (see Section 01.2). The plant was restarted on November 4, returned to l

the grid on November 5, and remained at full power through the end of the inspection 1

period. I

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I. Operations I

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01 Conduct of Operations l

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01.1 General Comments (71707) ,

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The inspectors conducted frequent reviews of ongoing plant operations. The I

conduct of operations was professional and safety-conscious; specific events and

noteworthy observations are detailed in the sections below.  ;

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, O 1.2 Unit 2 Forced Shutdown due to Inocerable Station Batterv  :

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a. Insoection Scopo (37551. 71707. 93702)

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On November 1, enhanced monitoring of station battery 2-1 performance identified

an inoperable battery condition which ultimately led to a unit shutdown. The.

inspectors responded to the site, interviewed personnel, reviewed maintenance test

records, and observed operator actions, to evaluate response to the degraded

station battery condition.

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b. Observations and Findinas

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Individual cell voltages (ICVs) for the 125 volts direct current (VDC) station

batteries are normally checked once per quarter. In March 1998, electricians began

checking station battery 2-1 ICVs on a weekly basis due to several low voltage

readings which had led to cell replacements. From March through October all ICVs

indicated normal, with one exception. On one occasion, cell 60 voltage was 2.14

VDC. While cell 60 voltage remained above the alert range, it was lower than

expec:ed. The 125 VDC station battery system was appropriately being monitored

as a maintenance rule category (a)(1) system and replacement of the entire 2-1

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station battery was scheduled for the upcoming refueling outage. The inspectors

determined the enhanced ICV monitoring was appropriate due to battery age and

the eight cell replacements during the preceding year.

On November 1, at 11:13 a.m., electricians and operators confirmed that cell 3 l

voltage was 2.055 volts, which was below the 2.07 volt minimum permitted by l

Technical Specification (TS) 3.8.2.3. Operators promptly entered the applicable

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limiting condition of operation (LCO) action statement and notified appropriate

station personnel for assistance in resolving the inoperable battery condition.

Technical specifications provide two hours to restore battery operability (individual

cell voltage greater than 2.07 VDC), otherwise the unit must be placed in hot

standby within the following six hours, and cold shutdown within the next 30

hours.

The inspectors observed control room activities. The pre-evolution briefing for the

shutdown was clear and operators reviewed applicable procedures. Station battery

2-1 was placed on charge, while engineering and maintenance personnel evaluated

options to jumper out cell 3. Based on updated cell three voltage readings and

j. reports that battery repairs would take longer than the time permitted by the TS

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LCO, the nuclear shift supervisor initiated a unit shutdown in a timely manner. The

shutdown was performed in a controlled manner and communications during

reactivity changes were clear. The unit achieved hot standby at 6:47 p.m.

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Prior to this event, the inspectors had discussed contingency actions for battery

degradation with station personnel including a temporary modification (TM) to

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jumper a degraded cell within the TS LCO time if cell voltage degraded below TS

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limits. A TM and 10 CFR 50.59 safety evaluation had been prepared for jumpering

cell 60. However, this TM was written specifically for cell 60 and could not be

used to jumper cell 3 due to jumper configuration differences associated with cell

location. Maintenance and engineering personnel were unable to locate appropriate

materials and prepare a TM to jumper cell 3 in sufficient time to preclude the unit

shutdown.

At 7:42 p.m., cell 3 voltage recovered to 2.09 VDC and operators exited TS 3.8.2.3. On November 3, cells 3,4,59, and 60 were replaced and on November 4,

the unit was synchronized to the grid. The inspectors attended a lessons learned

critique following the forced outage and observed good discussion concerning

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contingency planning, Management Review Team (MRT) implementation, and forced

outage work controls.

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c. Conclusions

Enhanced individual cell voltage monitoring due to station battery degradation was
good and led to prompt identification of an inoperable battery condition. On

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November 1, Unit 2 operators performed a TS shutdown due to an inoperable

i station battery. The shutdown was performed in a controlled manner and

j communications during reactivity changes were clear. The lessons lem.ned critique

following the forced outage was productive and identified several recommendations

to improve the organization's ability to respond to degraded material conditions.

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01.3 Response to Loss of Unit 1 Annunciator Panel "A-9"

j a. Inspection Scoce (71707)

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The inspectors reviewed the response by the control room staff to the loss of

control room annunciator panel "A-9".

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a b. Observations and Findinas

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] At 1:26 a.m. on October 15, while performing a routine test of the control room

annunciators, the "A-9" control room annunciator panel failed to respond properly.

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The annunciators that comprise the left half of the panel would not acknowledge

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(light) and the annunciators that comprise the right side of the panel were frozen in

j a lighted condition. This annunciator panel provides indication for normal and

emergency power supplies to the plant as well as other indications. The Assistant i

! Nuclear Shift Supervisor reviewed the Alarm Response Procedures for the 125 ,

l annunciators which comprise the "A-9" panel and developed and implemented a

j comprehensive plan to verify safety significant plant parameters. A temporary log

l was implemented. Hourly tours of the switchyard and diesel generators were

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performed to verify normal and emergency power sources were available. The

j annunciator panel failure was due to a faulted power supply fuse which was

[ replaced a few hours later. The compensatory actions were thoroughly planned and

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effectively implemented. The inspectors determined that the operating crew

l appropriately responded to the annunciator panel failure.

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j c. Conclusions

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j in response to a loss of annunciator panel "A-9" on October 15, the control room

j Assistant Nuclear Shift Supervisor developed and implemented a comprehensive

i plan to verify safety significant plant parameters.

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02 Operational Status of Facilities and Equipment i

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O2.1 Enaineered Safetv Feature System Walkdowns (71707)

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The inspectors walked down accessible portions of selected systems to assess

l equipment operability, material condition, and housekeeping. Minor discrepancies

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were brought to operator's and system engineer's attention and were corrected. No

! substantive concerns were identified. The following systems were walked down:

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  • Unit 1 River Water

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08 Miscellaneous Operations issues

08.1 License Amendment Reauest (71707)

By letter dated October 16,1998, the licensee submitted License Amendment

Request No.134 for Unit 2. The proposed amendment requested a one time only

extension of the surveillance interval of TSs 4.8.1.1.1.b and 4.8.1.2 (fast bus

transfer surveillance test) from their due date of January 30,1999, to the first entry

into Mode 4 following the seventh refueling outage, but not later than May 1,1999.

This license amendment request was submitted on October 16,1998,and

requested amendment issuance by December 31,1998. The license amendment

request was subsequently withdrawn by a letter dated November 10,1998,

following successful completion of the surveillance test on November 5,1998.

Submittal of this request with its requested completion date of December 31,1998,

was not timely in that it would have required an expedited review by the NRC staff

to meet the requested completion date. The fast bus transfer test was a

longstanding, periodic requirement. The untimely submittal represented a continued

weakness in planning and scheduling TS surveillance testing. The surveillance test

was successfully completed during the restart from a short duration forced outage

on November 5,1998.

08.2 Manaaement Resoonse to Multiole Unit 1 Eauipment Problems

a. Insoection Scope (71707)

The inspectors observed management response to the multiple equipment problems

that occurred on Unit 1, October 15 focusing on the effectiveness of problem

resolution.

b. Observations and Findinas

On October 15, at 1:26 a.m. a failure of Unit 1 control room annunciator panel "A-

9" occurred (see Section 01.3). At 3 a.m., the main steam pressure loop 2,

channel 2, bi-stable began cycling after Instrumentation and Control technicians

placed it in the tripped condition to perform a surveillance test. At 3:36 a.m.,

reactor coolant system (RCS) low flow alarms were received on channels 1 and 3 of

loop 1 A.

Due to these multiple events, the control room staff requested assistance from the

MRT. The MRT consists of a management member from Operations, Nuclear

Engineering, System and Performance Engineering, Nuclear Safety and Licensing,

and Maintenance departments. The MRT reviewed each event in detail. System

engineering and maintenance input was used effectively in assessing equipment

condition and proposed repair actions. LCOs were reviewed and discussed. The

MRT formulated the repair plan strategy. The annunciator panel "A-9" and main

steam pressure loop 2, channel 2 bi-stable were repaired expeditiously (see Section

M1.1). System engineers developed and implemented a TM package to adjust the

setpoint for the RCS flow transmitters and eliminate the low flow alarms. However,

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previous action to resolve this problem was slow and ineffective as the spiking had  ;

been occurring intermittently since August 20, and had recently increased in i

frequency. Further degradation could have resulted in a reactor trip.

c. Qmelusions

The Management Review Team effectively assessed equipment condition and

proposed repair actions for the multiple equipment problems experienced on October l

15. System engineering and maintenance input contributed to effective problem l

solving. However, previous action to correct the reactor coolant system flow

spiking was slow and ineffective.

08.3 (Closed) VIO 50-334/97-11-02: Failure of Operators to Log TS LCO Entries and

Perform Proper Shift Turnover (92901)

The inspectors identified in NRC Integrated inspection Report 97-11 that operators

failed to log TS LCO entries and exits and failed to perform a proper shift turnover.

Based on a sample review of corrective actions, including operator training, the

inspectors determined that the actions were completed and addressed the violation.

During routine reviews of the control room logs, the inspectors noted improvements

in the description of the specific TS entries. The inspectors did not identify any

instance where TS entries were not logged. Shift turnovers were cornpleted in

accordance with procedures.

11. Maintenance

M1 Conduct of Maintenance

M 1.1 Routine Maintenance Observations (62707)

The inspectors observed portions of the following maintenance work requests

(MWRs):

  • MWR 075030: Main Steam Pressure Loop 2, Channel 2, Bi-Stable

Actuation Repair.

b. Observations and Findinas

The main steam pressure, loop 2, channel 2 repair work was performed in a

techr6ically sound manner. The supervisor and technicians were well briefed and

were cognizant of their intended actions. The repair was completed satisfactorily;

however, the inspectors observed minor discrepancies during troubleshooting.

Discussions with the responsible work crew supervisor and Instrumentation and

Control Director resulted in these discrepancies being addressed through the

corrective action program.

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The annunciator "A-9" power supply was restored in a timely manner with prompt i

effective troubleshooting. The power supply f aih re was attributed to a blown fuse.

The inspectors identified that there was no effort underway to identify the root

cause of the fuse failure. Discussions with the Fix-It-Now (FIN) supervisor and a  ;

search of the MWR database by the FIN Director revealed several control room  ;

annunciator power supply fuses failures per year. Additionally, guidance for fuse l'

failure root cause determination was not readily available and was not included in

the planning of the MWR. The FIN director recognized these deficiencies and i

initiated Condition Report 981987, i

c. Conclusions

Maintenance repair work activities on the main steam pressure loop 2, channel 2 1

pressure bi-stable and the "A 9" Annunciator Panel fuse replacement were

performed promptly and effectively in a technically sound manner. Minor i

discrepancies were identified in the rnaintenance work request and in the fuse  :

failure root cause determination.

M 1.2 Routine Surveillance Observations (617261 l

The inspectors observed the following operational surveillance tests (OSTs):

  • 10ST-7.5 " Centrifugal Charging Pump Test [1CH-P-1 B]," Rev.13 l
  • 10ST-43.17D " Control Room Area Radiation Monitor i

12RMC'RQ202)," Rev.16 i

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The surveillance testing was performed safely and in accordance with proper j

procedures. j

M1.3 Unolanned LCO Time Durina Unit 2 Maintenance (62707)

On November 7, maintenance technicians performed surveillance testing on the {

moisture sensor in the "A" train of the supplementalleak collection and release <

system (SLCRS). The testing was suspended later that day due to an inability to

complete the procedure. Late on November 8, the problem was determined to be a

procedure deficiency rather than a hardware problem. During the resolution time

from November 7 to November 9, the "A" train of SLCRS was considered

inoperable. The inspectors discussed the problem with the system engineer. The

system engineer stated that the moisture sensor was not needed for operability of

the system. He would have communicated that to the operating crew, but was not

contacted prior to November 9. The inst 9ctors discussed the system engineer's

comments with the technical assistant to the general manager of nuclear operations l

who stated that additional investigation was needed and training would be

evaluated. The inspectors determined that the safety consequences were minimal

since the operators could have manually returned the system to service if needed.

However, the additional LCO time highlighted an example of poor communication

between the operating crew and the system engineers, and operator weaknesses in

evaluating degraded conditions.

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j M8 Miscellaneous Maintenance issues (92700,90712)

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M8.1 (Closed) Licensee Event Report (LER) 50-334/97-38-01: Unsealed Penetration in

Main Steam Valve Cubicle Floor

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i The inspectors conducted an onsite review of this LER. The original LER was  !

i reviewed in NRC Integrated inspection Report 50-334(412)/98-02,Lnd resulted in ,

4 an NCV. This LER update documented the June 11,1998, discovery of an i

additional degraded floor penetration flood seal in the Unit 1 main steam valve

j cubicle. A new flood sealinspection procedure had been developed as corrective

] action to the original LER. The licensee identified this additional degraded flood seal

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during initial performance of the inspection procedure. As was the case in the

original LER, this degraded seal also caused the auxiliary feedwater system to be i

outside its design basis for a high energy line break outside containment. The LER

l update accurately documented the degraded floor penetration flood seal and

corrective actions. The inspectors determined that corrective actions were timely

l and comprehensive, and field verified selected corrective actions.  ;

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) M8.2 LClosed) LER 50-334/98-16: Missing Fire / Flood Sealin Main Steam Valve Room

j Shakespace

$ The inspectors conducted an onsite review of this LER. On March 29,1998, a Unit

i 1 operator identified a degraded main steam valve room floor to containment

, exterior wall (shakespace) seal, which placed the auxiliary feedwater system outside

I of its design basis. The event was documented in NRC inspection Report 50-

334(412)/98-02and resulted in a Non-Cited Violation (NCV) for inadequate design

control. The LER accurately documented the event and met the reporting criteria of

10 CFR 50.73. The inspectors conducted interviews, record reviews, and in-plant  ;

s inspections which verified selected corrective actions were properly completed or

! progressing according to the schedules stated in the LER. The corrective actions

were comprehensive. ,

i

M8.3 (Closed) LER 50-412/98-06: Reactor Protection System Actuation - Bypass Breaker -

Trip During 2 MSP-1.14A

This issue was documented in NRC Integrated Inspection Report 50-334(412)/98-

02 and resulted in a NCV. Therefore, the inspectors performed an in-office review

of the LER. No new issues were revealed.  !

Ill. Enoineerina l

E8 Miscellaneous Engineering lesues (92700,90712,92903)

i

E8.1 (Closed) LER 50-334/97-33: Potential for Nuclear Instrumentation System Supply l

Voltage to be Outside Design Requirements. i

l

The inspectors conducted an in-office review of the LER. This issue was  !

documented in NRC Integrated Inspection Report 50-334(412)/97-08. The report '

4, .

?

._. . _- - _ - - _ _ . _- _ _ _ .

. .

e

8

stated the inspectors noted that the issue was properly reported to the NRC in

accordance with 10 CFR 50.72 and 10 CFR 50.73. The inspectors concluded that

corrective actions, including design change implementation, were timely and

technically sound.

i

E8.2 (Closed) LER 50-334/97-35-00.01: Small Bore Piping Support Design Deficiencies.

! The inspectors conducted an in-office review of the voluntary LER and its

supplement. The issue was documented in NRC Integrated inspection Report 50-

1 334(412)/97-09and resulted in an NCV. The LER properly described the event.

The root cause evaluation and corrective actions were comprehensive. No new

, issues were identified in the LER.

E8.3 (Closed) LER 50-334/97-39: Gas Accumulation in Charging /High Head Safety

i Injection Pump Piping.

.

This issue was documented in NRC Integrated Inspection Report 50-334(412)/97-

j 07 and NRC Integrated Inspection Report 50-334(412)/97-08and resulted in

. Violation 50-412/EA 97-517 Item 01013. Since that violation remains open

pending review of the corrective actions, the inspectors performed an in-office

! review of the LER. No new issues were revealed.

E8.4 (Closed) LER 50-412/97-08-01
Failure to Meet Single Active Failure Criteria for

] Control Room Emergency Ventilation System Results in Entry into TS 3.0.3.

2

The inspectors conducted an in-office review of this LER revision. The issue was

originally documented in NRC Integrated Inspection Reports 50-334(412)/97-09and

97-11, and resulted in an NCV. The original LER was reviewed and closed in NRC

Integrated inspection Report 50-334(412)/97-11. The revision provided additional

analysis of control room habitability calculations, as well as updated / additional

corrective actions, and did not change the previous inspection assessments.

E8.5 (Closed) LER 50-412/97-10: Lack of Electricalisolation in the Unit 2 Emergency

'

Diesel Generator Room Ventilation System Temperature Control Circuits.

4 a. Inspection Scope

<

The inspectors performed an in-office review of the LER. The inspectors reviewed

i the root cause and corrective actions.

1

b. Observations and Findinas

.

On December 19,1997, the licensee identified that the Unit 2 emergeracy diesel

J

generator (EDG) room ventilation system temperature control circuitry did not have

electrical isolation between the Class 1E and non-Class 1E portions of the circuit.  ;

Therefore, a failure in the non-safety portion of the control circuit could potentially '

degrade the safety related portion of the circuit and prevent it from performing its  ;

safety function. This function was to maintain the ambient air temperature in the

'

1

_ - . ._ _

. . .

9

EDG rooms within design limits. The Unit 2 EDGs were declared inoperable and

aprropriate TSs were entered. The unit was in Mode 5.

T'se issue was originally reviewed in NRC Inspection Report 50-334(412)/98-80.

The NRC granted enforcement discretion, as an old design issue, for the failure to

have proper electrical isolation between Class 1E and non-Class 1E. The issue

described in this LER was considered part of the enforcement discretion. The

inspectors noted that this issue resulted in additional identification of electrical

separation problems in Westinghouse 7300 circuit cards.

Corrective actions for the specific issue described in the LER included a design

change package to install an isolation device in the ventilation temperature control

circuit for the EDG room. The root cause was inadequate design of the temperature

circuits. The extent of condition review was comprehensive.

c. Conclusions

The licensee identified and corrected an old design issue associated with EDG

ventilation temperature control circuit. The extent of condition evaluation was

comprehensive.

E8.6 (Closed) LER 50-412/98-10: Non-Safety Related Mechanical Seal Assembly

Installed in Quench Spray Pump 'A' 2OSS-P21 A.

a. J.nspection Scone

The inspectors performed an onsite review of the LER. The inspectors interviewed

the procurement personnel and examined a sample of corrective actions including

the extent of condition review.

b. Observations and Findinas

On April 21,1998, procurement engineers identified that the Quench Spray (OS)

Pump "A" gland plate in the mechanical seal assembly was not American Society of

Mechanical Engineers (ASME) Section Ill, Class 2, which is required for equipment

qualification. This issue was discovered during reviews of the stock description for

QS pump "B", which had experienced a water hammer event (see NRC Integrated

inspection Report 50-334(412)/98-04). Further investigation showed that the non-

safety related and non-ASME Section ill gland plate only affected the "A" QS pump.

The incorrect part was installed near the Unit 2 startup in 1987. Procurement

engineers determined the apparent cause of the event was inadequate knowledge

and training regar#ag pump mechanical seal assemblies for the individual who

originally classified and developed the replacement stock specification.

The corrective actions included training for procurement engineers on mechanical

seals, replacement of the QS "A" gland seal plate, and an extent of condition

review. The extent of condition review examined all other safety related pumps and

did not identify any other deficiencies and all corrective actions were appropriate.

. . . __- - - - .- -- -.~ - - . - . - - - - - - - - - - - - -

. . .

!

!

10

,

The safety significance of this event was low in that the seal had not failed and it i

affected only one train of QS.

The licensee determined the "A" QS pump was inoperable since 1987 in that the I

gland plate in the mechanical seal assembly did not meet equipment qualification  !

and safety related code classification requirements. This w 1 a violation of TS  !

3.6.2.1, which requires that two QS systems be operable. This non-repetitive, i

licensee-identified, and corrected violation is being treated as an NCV, consistent i

with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-412/98-06-01). ,

.

c. Conclusions

!

Procurement engineers identified and corrected a deficiency associated with non- '

safety related material in the "A" quench spray pump.

E8.7 (Closed) Unit 2 LERs Associated With NRC Generic Letter 96-01 Review

!

a. Inspection Scope  !

NRC Generic Letter (GL) 96-01, " Testing of Safety Related Logic Circuits," informed ;

licensees of various industry test deficiencies and requested specific actions be

taken. In some cases, portions of safety related logic circuits had never been tested

to verify operability. On October 13,1998, Duquesne Light Company (DLC) ,

reported their completion of NRC GL 96-01 requested actions for Unit 2. The  !

inspectors conducted interviews, reviewed design and testing documentation, and

reviewed LERs associated with licensee-identified test deficiencies to determine

whether the licensee has properly completed requested actions. +

b. Observations and Findinas

i

Engineers, maintenance personnel, and operations personnel performed detailed l

reviews of Unit 2 safety related logic circuit testing as requested by NRC GL 96-01, ,

Systems reviewed included (1) the reactor protection system, (2) EDG load >

shedding and sequencer, and (3) the engineered safety features actuation system.  ;

The inspectors reviewed the following LERs and supplements which documented l

licensee-identified test deficiencies associated with the NRC GL 96-01 review:

'

LERs 50-412/96-03-00and 01 Generic Letter 96-01 -Inadequate Testing

of Safety Related Logic

LER 50-41Ld7-07 Generic Letter 96-01 -Inadequate Routine

Surveillance Testing of the Power Range,

Neutron Flux High Positive Rate Reactor

Trip Function

. _ . _ . _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ . . _ _ . _ _ . _ _ . _ _

. .. .  ;

1

11

LERs 50-412/98-08-00,01,02, and 03 Generic Letter 96-01 - Technical

Specification Instrumentation Surveillance

Inadequacies

Engineers identified 10 separate testing deficiencies. In each case, follow-up

verification testing was successfully performed and procedures were modified as

necessary to specify periodic component testing as required in the future. The root

cause for the te it deficiencies was inadequate development of the original

surveillance test procedures. The corrective actions stated in each LER reasonably

resolved the reported logic testing deficiency. The LERs properly addressed the

reporting requirements of 10 CFR 50.73. Based on selected procedure reviews,

corrective action verifications, and design drawing validations, the inspectors

determined that the licensee satisfactorily completed the actions requested by NRC

GL 96-01 within the requested time period.

Collectively, the 10 instances where required portions of safety related logic

circuitry were not tested represented a deficient Test Control Program and was a

violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control." The NRC is

exercising discretion in accordance with Section Vll.B.3 of the Enforcement Policy

and refraining from issuing a citation for a potential Severity LevelIV violation.

Discretion is warranted because: (1) the inadequacies were self-identified as a result

of an initiative in response to NRC GL 96-01,(2) corrective actions were timely and

effective, (3) the testing deficiencies were not likely to be identified by routine

efforts, and (4) the actions that caused the testing deficiencies were dated and not

reflective of current performance.

c. Conclusions

Engineers conducted a detailed review of Unit 2 safety related logic testing as

requested in NRC Generic Letter 96-01. Ten separate logic testing discrepancies

were identified and resolved. Correction of these deficient conditions improved the

reliability of soveral important safety systems. Enforcement discretion in

accordance with Section Vll.B.3 of the Enforcement Policy was exercised for these

longstanding deficiencies.

l

E8.8 (Closed) LER 50-412/98-11: Cross-Connect Piping Installed Between Suction Lines

of Hydrogen Recombiners

a. Inspection Scoce

The inspectors performed an onsite review of the LER. The inspectors interviewed

licensing and design engineers and examined a sample of corrective actions. l

!

b. Observations and Findinas

On May 17,1998, operators identified that two cross connect lines without

isolation valves connected the suction piping of the Unit 2 hydrogen recombiners.

The operators questioned the system's ability to meet single f ailure criteria. Design I

,

l

. -- -- -

....---..-.---..---.- - - . .-..

- . . ..- _.-. - -...-.-.

!

, i

12 I

l

!

engineers determined the design change and safety analysis that added the cross I

connect in 1987 was inadequate. The 50.59 safety analysis did not evaluate ,

i passive failures as described in the Updated Final Safety Analysis Report (UFSAR), ,

l The design change analysis improperly assumed that the piping was not susceptible i

i to passive failures and met the crack exclusion criteria detailed in NRC branch  !

l technical position 3-1. In response to the identified issue, design engineers revised ,

I the UFSAR with a 10 CFR 50.59 safety evaluation to change the design basis to  ;

[ exclude passive failures. This position is in agreement with the NRC standard

2 review plan. Failure to maintain the design with the design basis requirements was

e a violation of 10 CFR 50 Appendix B, Criterion lil, " Design Control." This non-

) repetitive, licensee-identified, and corrected violation is being treated as a Non-Cited  ;

Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-

l 412/98-06-03).  !

c. ' Conclusions  !

!

Operators identified a design discrepancy in the hydrogen recombiner system. I'

Engineers properly evaluated and corrected the issue.

IV. Plant Support

R1 Radiological Protection and Chemistry (RP&C) Controls e

a. Insoection Scope (86750 & 83750)

A review of the program for the collection, processing and shipment of radioactive

waste and transportation of radioactive materials was conducted. Areas of  ;

inspection focus included verification of compliance with the following regulatory l

requirements:

10 CFR 20.1906 Procedures for receiving and opening packages  ;

t

10 CFR 20, Appendix G Requirements for transfers of low-level radioactive

waste intended for disposal at licensed land disposal

facilities and manifests

l

10 CFR 61.55 Waste classification

10 CFR 61.56 Waste characteristics

10 CFR 71.12 General license: NRC-approved package

10 CFR 71, Subpart H Quality Assurance

49 CFR 172, Subpart C Shipping Papers

49 CFR 172, Subpart D Marking

_ _ _ _ _ _ . _ . _ _ _ _ . _ _ . _ _ _ _ _ _ . . _ . . _ . _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _

. .. .

!

!

13 i

49 CFR 172, Subpart E Labeling

49 CFR 172, Subpart F Placarding  !

49 CFR 172, Subpart G Emergency Response information

49 CFR 173, Subpart I Class 7 (Radioactive) Materials  !

!

Also reviewed were activities associated with the sump and tank clean-up project

being conducted at both units by contractors under the direct supervision of the

Health Physics Department. Areas reviewed included maintaining occupational i

exposures as low as is reasonably achievable (ALARA), control of transient high l

radiation areas, and collection and processing of sludge removed from these

vessels. ,

The inspection was accomplished by direct observation of radwaste and l

!

transportation activities; review of selected procedures, shipping documents and  ;

records; and discussions with cognizant plant personnel,

i

b. Observations and Findinas

A random sampling of radioactive material and radwaste shipping records was r

reviewed for compliance with the requirements for waste classification and j

characteristics (if applicable), shipping papers, markings, labeling, placarding, and  !

emergency response information contained in 10 CFR and 49 CFR. No

discrepancies were identified.

An extensive database of scaling factor results is maintained for each of the

licensee-identified waste streams at each unit. Records dating back to 1983 were

incorporated into a statistical package which aided in screening out anomalous data

points, and in validating currently utilized scaling factors.

4

Waste minimization at the plant was effective, based on the significant reduction in

both waste generated and waste disposal volume. Tours of various portions of the

radiologically controlled area (RCA) confirmed that ,odiological nousekeeping was

adequate to minimize the generation of radwaste.

The processing of wet radioactive wastes into a wasta form acceptable for disposal

in accordance with 10 CFR 61 was accomplished as outlined in the Process Control I

Program (PCP) (Issue 5.0, Revision 1, dated 9/22/98). This document accurately i

reflected current plant processes, including modifications recently made to handle

sludges being removed from various sumps and tanks. All waste shipments were

accurately characterized and classified in accordance with 10 CFR 61.

Effective radiological controls were observed during the sump and tank desludging

project that was ongoing at the time of this inspection. At Unit 2,3500 pounds of

radioactive sludge was removed from the RCA sumps and selected tanks. As a

result of this effort, the high radiation areas around two tanks were eliminated.

_-. . - - - - - . . - . -

- -. -. . - - - . . . . - - ----- --- - -

. .. .

1

I

l

14

Temporary high radiation area controls were established on a daily basis in the RCA  !

to support this project. No discrepancies were identified in these areas.

,

c. Conclusions

An effective program for the collection, processing, transport and disposition of  :

radioactive materials and radwaste has been established. All reviewed shipments }

were determined to be in accordance with applicable regulations. Waste processing j

conducted in accordance with the PCP was found to meet the standards for waste ,

form and classification. Effective radiological controls were established and I

implemented during the clean out of various sumps and tanks located in the RCA. i

i

!

R5 Staff Training and Qualification in RP&C l

a. Inspection Scope (86750)

l

The program of initial and continuing training for workers who handle radioactive

materials received or being shipped, in accordance with 49 CFR 172, Subpart H,

and for workers who handle, generate, process or ship radioactive waste in

accordance with NRC IE Bulletin 79-19 was evaluated. Specific requirements

reviewed included:

-

proper identification of all HAZMAT employees covered under 49 CFR

172.702(a)

-

testing program for identified HAZMAT employees

-

content of HAZMAT training, including function-specific training

-

triennial requalification training

-

certification of training

This inspection was accomplished by a review of course outlines and lesson plans,

verification that all appropriate personnel are included in these training programs,

and discussions with cognizant personnel,

b. Observations and Findinas

The HAZMAT training program for Class 7 (Radioactive) materials includes three

distinct training programs, designed around the function-specific training required by

each group. Lesson plans and course handouts reviewed were adequate to aid in

presenting the required materials. Examinations were given following completion of

each course, and appropriate records of course grades and certifications were

maintained.

Personnel were determined to be knowledgeable of the appropriate rules and

regulations associated with the transport of Class 7 materials, and to effectively

  • .. .

15

apply this knowledge to transport activities. Additionally, this same training is

provided to quality assurance personnel who provide surveillances of transport

activities.

c. Conclusions

The program for the training of HAZMAT employees handling radioactive materials

has been effectively established and implemented. All personnel involved in these

activities were determined to be knowledgeable of the regulations.

R7 Quality Assurance in Radiological Protection and Chemistry Activities

a. Inspection Scone (86750)

The program for the evaluation of performance in radwaste and transportation

activities was reviewed to determine if the program met the requirements set forth

in the Quality Assurance Program Policy and the Operations Quality Assurance

Procedure (OP). The PCP is required to be audited in accordance with OP-3. 1

Application of the OP requirements for NRC-approved shipping casks is required

under the Unit 1 UFSAR and OP-Appendix B (for Unit 2).

The inspectors reviewed audits, surveillances and appraisals previously completed

or currently ongoing, and discussed the results of these reviews with cognizant

personnel.

b. Observations and Findinas

The most recent biennial audit of the PCP, Audit BV-C-97-05, Radioactive Waste

Management and Transportation Program Audit, dated July 2,1997, was performed

to meet the PCP auditing requirement contained in the Quality Assurance Program

Policy. This audit reviewed both radwaste collection / processing and the

transportation of radioactive materials. Nine condition reports and one

recommendation were included in this document, none involving any issue of

significant safety interest. Additionally, since the conclusion of this audit, three

surveillances directly related to the radwaste and/or transportation program, and

three surveillances of health physics practices, which included aspects of the

radwaste program have been conducted by qualified audit personnel. All audits and

surveillances were performed by trained licensee and contractor personnel

knowledgeable of the areas they were reviewing. All condition reports were tracked

to closure by quality assurance personnel. Although not procedurally required, the

Health Physics Department provided written responses to all recommendations. 1

Responses were thorough and timely, and of sufficient scope to praclude repetition.

In accordance with paragraph 7.1.1 of OP-3, Administrative Controls, records

related to audits (through the Nuclear Utilities Performance issues Council INUPIC])

or trip reports for vendor facilities filed by cognizant licensee personnel were

maintained to demonstrate the qualifications of vendors to perform radwaste

services or supply shipping containers and packages.

_ _ . . _ _ _ . . _ . _ _ _ _ _ . _ . - _ _ -

  • .. . l

i

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l

i

16 ,

I

c. Conclusions

I'

An effective program for the review of the PCP and related radwaste and

transportation activities, including those activities performed by vendors has been  ;

established, including an effective corrective actions tracking and resolution process i

as demonstrated by the scope and quality of audits and surveillances performed. l

V. Manaaement Meetinas

X1 Exit Meeting Summary

i

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on November 19,1998. The licensee acknowledged the 1

findings presented.

!

The licensee did not indicate that any of the information presented at the exit was l

proprietary.  !

X2 Management Changes l

Effective October 19,1998, Mr. Mark S. Ackerman became the Director, Nuclear Safety & ,

Licensing Department. On October 23,1998, Mr. Richard D. Brandt assumed the position l

of Division Vice President, Operations Support Group reporting to the President, Generation

Group and Chief Nuclear Officer. Effective October 23,1998, Mr. Kevin L. Ostrowski

assumed the position of Division Vice President, Nuclear Operations Group and Plant

Manager also reporting to the President, Generation Group and Chief Nuclear Officer.  :

!

- . . -. -

-. . . .-. - - . - . . . - - _ - . - - - . . . . _ - .-.- _ - - . . -

. .. .

l

!

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17 -

INSPECTION PROCEDURES USED '

i

IP 37551: Onsite Engineering ,

IP 62707: Maintenance Observation

'

IP 71707: Plant Operations  :

IP 83750: Occupational Radiation Exposure  ;

IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive '

Waste

IP 90712: In-Office Review of Written Reports of Nonroutine Events at Power Reactor i

Facilities -

IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor  !

Facilities

IP 92901: Follow-up - Operations ,

IP 92903: Follow-up - Engineering

IP 93702: Prompt Onsite Response to Evente 3t Operating Power Reactors t

ITEMS OPENED, CLOSED AND DISCUSSED

!

'

i

Opened and Closed

50 334/98-06-01 NCV Non-Safety Related Mechanical Seal Assembly Installed ,

in Quench Spray Pump 'A' 2OSS-P21 A- Reference LER -

'

50-412-98-10 (Section E8.6)

,

50-412/98-06-02 NCV GL 96-01 issues, Inadequate TS Testing (Section E8.7)  !

(Also EA 98-525)

50-412/98-06-03 NCV Inadequate Design Control of the Hydrogen l

Recombiners - Reference LER 50-412/98-11(Section

E8.8)

i

50-412/98-06-04 NCV inadequate Fire Protection Safe Shatdown Analysis for {

Boric Acid to Boric Acid Blender Valve 2CHS*FCV113A  !

- Reference LER 50-412/98-05 (Section F8.1)

'

Closed

50-334/97-11-02 VIO Failure of Operators to Log TS LCO Entries and Perform i

Proper Shift Turnover (Section 08.3)

'

!

'

50 334/97-38-01 LER Unsealed Penetration in Main Steam Valve Cubicle Floor

(Section M8.1)

50-334/98-16 LER Missing Fire / Flood Sealin Main Steam Valve Room j

Shakespace (Section M8.2) <

50-412/98-06 LER Reactor Protection System Actuation - Bypass Breaker l

Trip During 2 MSP-1.14A (Section M8.3)

i

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I

. .. .

--- . . - -- - . -. _

.

. ,. . 1

I

I

!

!

18

50-334/97-33 LER Potential for Nuclear Instrumentation System Supply i

Voltage to be Outside Design Requirements (Section

'

E8.1)

50-334/97-35 & LER Small Bore Piping Support Design Deficiencies (Section

50-334/97-35-01 E8.2)

!

50-334/97-39 LER Gas accumulation in Charging /High Head Safety ,

injection Pump (Section E8.3)

l

50-412/97-08-01 LER Failure to Meet Singte Active Failure Criteria for Control [

Room Emergency Ventilation System Results in Entry  !

into TS 3.0.3 (Section E8.4)  !

50-412/97-10 LER Lack of Electrical isolation in the Unit 2 Emergency [

Diesel Generator Room Ventilation System Temperature '

Control Circuits (Section E8.5) i

50-412/98-10 LER Non-Safety Related Mechanical Seal Assembly Installed  !

in Quench Spray Pump 'A' 2OSS-P21 A- Reference [

NCV 50-412/98-06-01 (Section E8.6) (

,

50-412/96-03-OOand LER Generic Letter 96-01 Inadequate Testing of Safety  ;

50-412/96-03-01 Related Logic - Reference NCV 50-412/98-06-02 i

(Section E8.7)

50-412/97-07 LER Generic Letter 96-01 -Inadequate Routine Surveillance i

Testing of the Power Range, Neutron Flux High Positive  ;

Rate Reactor Trip Function - Reference NCV 50-412/98- t

06-02 (Section E8.7)

l

50-412/98-08-00; LER Generic Letter 96-01 - Technical Specification i

'

50-412/98-08-01; instrumentation Surveillance inadequacies - Reference

50-412/98-08-02:and NCV 50-412/98-06-02(Section E8.7)

50-412/98-08-03  !

50-412/98-11 LER Cross-Connect Piping Installad Between Suction Lines  !

of Hydrogen Recombiners - Reference NCV 50-412/98-  !

06-03 (Section E8.8)

l

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.

I

i

. . __ ..._ _. _..___ _.___-__. _ _ ______ ___ _ __ _._._.__

- e ,e s \

l

l

j 19

1

LIST OF ACRONYMS USED

1

ALARA As Low as is Reasonably Achievable

ASME American Society of Mechanical Engineers

CFR Code of Federal Regulations

_

DLC Duquesne Light Company l

DRP Division of Reactor Projects l

'

EA Enforcement Action

EDG Emergency Diesel Generator

FIN Fix-it-Now

GL Generic Letter  ;

HAZMAT Hazardous Material l

ICV Individual Cell Voltage  !

LCO Limiting Condition of Operation

LER Licensee Event Report j

j MRT Management Review Team '

, MWR Maintenance Work Request j

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulation

NUPIC Nuclear Utilities Performance issues Council

OP Operations Quality Assurance Procedure

OST Operational Surveillance Test

PCP Process Control Program

OS Quench Spray

RCA Radiologically Controlled Area -

RCS Reactor Coolant System

RP&C Radiological Protection and Chemistry

SLCRS Supplemental Leak Collection and Release System

TM Temporary Modification

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

VDC Volts Direct Current