ML20202A969
| ML20202A969 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20202A952 | List: |
| References | |
| 50-334-97-09, 50-334-97-9, 50-412-97-09, 50-412-97-9, NUDOCS 9802110035 | |
| Download: ML20202A969 (26) | |
See also: IR 05000334/1997009
Text
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50 334/97 09;50-412/97 09
Docket Nos. 50 334,50 412
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Licensee: Duquesne Light Company (DLC) l
Post Office Box 4 1
Shippingport, PA 15077
Facility: Beaver Valley Power Station, Units 1 and 2
Inspection Period: November 16,1997 through December 27,1997
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Inspectors: D. Korn, Senior Resident inspector
F. Lyon, Resident inspector
G. Dentel, Resident inspector
J. Furia, Senior Radiation Specialist, DRS
W. Maler, Reactor Engineer, DRS
Approved by: N. Perry, Acting Chief
Reactor Projects Branch 7
9002110035 9eo204
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PDR ADOCK 05000334
G PDR
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EXECUTIVE SUMMARY
Beaver Ve'!ey Power Station, Units 1 & 2
NRC Inspectn Rep 'rt 50 334/97 09 & 50 412/97-09
This integrated inspection int, loc td ast acts of licensee operations, engineering,
maintenance, and plant support. ": report covers a 6 week period of resident inspection;
in addition, it includes the results of announced inspections by regional inspectors in the
areas of emergency preparedness, radiological controls, and engineering.
Ooerations
- Du'ing the continuing refueling outage for Unit 1 and the Unit 2 shutdown on
December 16,1997, the inspectors observed good control of shutdown safety
parameters and awareness of safety equipment availability. The Operations staff
identified and stopped two improperly scheduled work activities that would have
potentially impacted safety. (Section 01.2)
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- Strong operator attention to detallled to the discovery of deficiencies in the Unit 2
Control Room Emergency Ventilation System. (Section E4.1)
Maintenance
- Inspectors assessed that the licensee responded appropriately to a valve linkage
failure on a turbine plant component cooling water control valve and noted good ,
coordination between operatora, system engineering, and maintenance staff. The
prompt response eliminated a potential challenge to safe plant operation. Some
inconsistencies were noted in the guidance provided to operators and maintenance
staff regarding emergency work, in addition, failure to repair the degraded linkage
during earlier opportunities indicated a weakness in the work control process that
unnecessarily challenged operators when the linkage subsequently failed.
(Section M1.3)
Enaineerina
- Engineers demonstrated an excellent questioning attitude in identifying a non-
conforming safety related small bore piping deficiency. Over 200 supports and
anchors did not meet Code requirements due to inadequate original construction
design specification. Extent of condition reviews, findings, causal assessment, and
corrective actions were comprehensive. Communication of this potentially generic
issue to the industry demonstrated a sound safety perspective (Section E1.1).
- The operator's strong attention to detail and the engineers' rigorous questioning
attitude led to the distuvery of deficiencies in the Unit 2 control room emergency
ventilation system. The licensee's full assessment of the design and licensing basis
and corrective actions was not yet completed. (Section E4.1)
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Plant Suonort
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The program for maintaining occupational exposures as low as reasonably
achievable (ALARA) was generally effective improvements in work planning and
the integration of ALARA controls into work packages was evident, especially
during the Unit 1 refueling outage (1R12). Radiological housekeeping at both units
has also continued to show improvement, especially in the Unit 1 containment.
Audits and surveillances conducted in support of the refueling outage were of
appropriate scope and technical depth. (Section R)
- The licensee's emergency facilities were generally well-maintained. The failure to (
regularly test the off line commercial phone lines at the Alternate EOF is a violation
of Section IV.E.9.a-d of Appendix E to 10 CFR 50 since those lines would be relied
upon if the Alternate EOF was activated. (Section P2)
- The licensee's process for performing 10 CFR 50.54(q) evaluations for the latest
emergency plan revision was weak. Several questionable changes were made to
the latest revision of the plan and some procedures. However, the inspectors
concluded that the current procedure for performing these evaluations is an
improvement over the previous procedure. The inspectors considered the licensee's
prompt commitment to re evaluate some of the questionable changes to be proper.
(Section P3)
The training program for the emergency response organization met all regulatory
requirements and was implemented well. (Section PS)
The Emergency Preparsdness (EP) organization has not been weakened by the
changes that have occurred since the last EP program inspection. Tne ik isee's
conversion to a team-oriented response was an improvement over the previous
! response and its implementation was properly conducted. The authorization of an
additional staff position in the EP program to strengthen the EP organization's ability
to maintain the onsite and offsite EP programs was a positive indication. (Section
PS)
- The inspectors concluded that the licensee's Quality Services audit of the
emergency preparedness program met all regulatory requirements of 10 CFR
50.54(t) and that the audit and its attendant report were much improved over the
calendar year 1996 audit and report. (Section P7)
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, TABLE OF CONTENTS
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EX E C U TI V E S U M M A R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I
T ABLE O F CO NT ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . lil
1. Operations .................................................... 1
01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01.1 General Comments (71707) ........................... 1
01.2 Shutdown Saf ety (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
ll . M aint e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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M1.1 Routine Maintenance Observations (62707) . . . . . . . . . . . . . . . . 2
M1.2 Battery No.12 Maintenance Surveillance (62707,61726) . . . . . . 2
M1.3 Emergent Repair of Control Valve Linkage (62707) . . . . . . . . . . . 2 ,
M1.4 Routine Surveillance Obs6.vations (61726) . . . . . . . . . . . . . . . . . 4
M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
M8.1 Emergency and Appendix R Lighting (62707) ............... 4
Ill. Eng ine e ri ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
El Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
E1.1 Unit 1 Small Bore Piping Operability Assessment . . . . . . . . . . . . . 4
E4 Engineering Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . 7
E4.1 Control Room Emergency Pressurization Ventilation System
Design Deficiencie s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
IV. Pla n t S u pport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . 8
R4 Staff Knowledge and Performance in RP&C .................... 10
R4.1 Unit 2 Post Accident Sampling System (PASS) Drill (71750) . . . . 10
R7 Quality Assurance in Radiological Protection and Chemistry Activities . . 10
R8 Miscellaneous RP&C lssues ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
R8.1 (Closed) Inspector Follow up ltem (IFI) 50 334 and 412/97-04-
04 ............................................ 11
P2 Status of EP Facilities, Equipment, and Resources . . . . . . . . . . . . . . . . 11
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P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
P5 Staf f Training and Qualification In EP , . . . . . . . . . . . . . . . . . . . . . . . . 15
P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . 16
P7 Quality Assurance in EP Activities (82701) . . . . . . . . . . . . . . . . . . . . . 17
V. M anag eme nt Mee ting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
X1' Exit Me eting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
X2 Pre Decisional Enforcement Conference Summary . . . . . . . . . . . . . . . . . . . . . 17
X3 Management Meeting Summary . . . . . . . . . . . . . . . .................. 17
PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
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INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
ATT A C H M E N T I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
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, Reoort Details
Summarv of Plant Siging
Unit 1 began this inspection period :n Mode 5 (cold shutdown) for the 12th refueling
outage. Mode 4 (hot shutdown) was entered on December 20, and Mode 3 (hot standby)
was entered on December 23.
Unit 2 began this inspection period at 100% power. On December 16, DLC determined
that the Control Room Emergency Air Cleanup and Pressurization System was outside its
design basis (see Ser' ion E4.1). Operators entered TS 3.0.3 and shut down the unit to
Mode 5 to evaluate the concern and implement corrective actions,
k_0_nerations
01 Conduct of Operations
01.1 General Comments (71707)'
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
- ongoing plant operations, in general, the conduct of operations was professional
l and safety-conscious.
01.2 Shutdown Safety (71707)
During the continuing refueling outage for Unit 1 and the Unit 2 shutdown on
l December 10,1997, the inspectors observed good control of shutdown safety
l parameters and awareness of safety equipment availability. Prior to the Unit 2
shutdown, the Operations staff identified and stopped severalimproperly scheduled
work activities that would potentially impact safety. For example, on November 17,
inspection and testing of the "A" recirculation spray pump and surveillance tests for
the "B" and "D" recirculation spray pumps were scheduled concurrently. This
would have led to both trains being out of service and subsequent entry into TS 3.0.3 On November 25, fill and vent of a recirculation spray flow transmitter was
requested by an Instrumentation and Control Technician while an emergency diesel
generator (EDG 2-2) was out of service for a scheduled surveillance test. This
would have caused entry into TS 3.0.5. The work was stopped by operators prior
to commencement, and the issues were reviewed through the corrective action
process. The inspectors noted that a strong questioning attitude by the operators
was a key in identifying the issues. These challenges to the operators were
considered weaknesses in the work control program.
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ll. MainteDirma
M1 Conduct of Maintenance
' Topical headings such a 01, M8, etc., are used in accordance with the NRC
standardized reactor inspection report outline, ind vidual reports are not expected to
address all outline topics.
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M 1.1 Routine Maintenance Observations (62707)
The inspectors observed selected maintenance activities on important systems and
components. Some of the activities observed and reviewed are listed below.
- 1MSP 39.02 E Battery No.12 Tes and inspection
The activities observed and reviewed were performed safety and in accordance with
proper procedures, except as noted below, inspectors noted tnat an appropriate
level of supervisory attention was given to the work depending on its priority and
ditficulty.
M1.2 Batterv No.12 Maintenanca Surveillance (62* 07,61726)
i 1MSP 39.02 Edomonstrates that 60-celllead acid battery No.12 of the 125VDC
l control system is fully charged and meets the TS acceptance criteria. During
performance of the MSP on December 7, electricians found 8 cells with marginal
specific gravity. The cells were still within the TS operability limits. Electricians
requested operators to place the battery on an equalizer charge in accordance with
the MSP. Operators found that the MSP required a 70 hour8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> charge, but operations
procedure 10M 39.4.0, Rev.1, " Battery Equalization Charges," required a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />
I charge. The system engineer verified that the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> requirement was correct.
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The issue also applied to battery No.1 1. The MSPs for the two batteries were
changed to reflect the correct requirement. The discrepancy was documented on a
mndition report for additional evaluation and appropriate corrective action.
During review of the specific gravity calculations in the MSP, inspectors noted that
the correction factors applied for electrolytu level for 27 of the 60 cells were
incorrect. The f actors had been read from the temperature column instead of the
electrolyte level column of the correction chart. Inspectors noted that the errors
were non conservative; however, they did not affect the operability of the cells.
The issue was discussed with electrical maintenance supervisors, and the
calculations were corrected. The cause of the error was inattention to detail by the
electrician performing the calculations. The issue was documented on Condition
Report 972272 for evaluation, inspectors assessed that licensee response to the
issue was appropriate. The MSP was satisfactorily completed af ter the equalizer
charge.
M1.3 Reoair of Control Valve linkaae (62707)
a. Insoection Scopo (62707)
Inspectors reviewed the licensee response to a f ailed actuator arm on Unit 2 turbine
plant component cooling water (CCS) valve 2CCS DCV 215, on the common
discharge of the CCS heat exchangers, inspectors also reviewed guidance provided
to operators and maintenance staff regarding emergency work.
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b. Observations and Findinag
On December 10, the actuator arm on turbine plant CCS valve 2CCS DCV 215
failed and the valve moved to the full open pn sn. The valve is a 24 inch
butterfly valve that modulates flow to maintalri t.ifferential pressure below 18 psid
across the CCS heat exchangers, it is located on the common discharge of the CCS
heat exchangers. CCS flow from the heat exchangers provides cooling to turbine
plant components and the station air compressors. The failure mode was a break in
the connecting linkage between the air operator and the valve. Operators noted
CCS temperature lower from about 78 degrees F to about 69 degrees F and
discovered the broken linkage.
Operators, system engineering, and maintenance staff responded promptly to the
issue. If the valve had drif ted closed, CCS flow would have been lost, resulting in a
main turbine trip. 'he nuclear shift supervisor declared an emergency condition on
the valve, which allowed repair work to proceed before molntenance work request
or temporary modification documentation was completed. The two swivel joints
and turn buckle of the connecting arm were replaced with an equivalent length of
angle iron, dri' led and pinned to the connection, which restored normal operation to
the valve. Inspectors noted good coordination between operators, system
enginesting, and maintenance staff.
! Inspectors reviewed the work and the temporary modification (TMOD 2 97 21) and
l Its associated technical evaluation and 10 CFR 50.59 evaluation. One weakness in
l the documentation was noted, inspectNs noted that the 10 CFR 50.59 evaluation
addressed the issue of the valve failing open, but not f ailing closed. Inspectors
discussed the issue with system engineers and concluded that an event where the
valve failed closed would be bounded by the analysis for a turbine trip, inspectors
also reviewed guidance given to operators and maintenance staff regarding
emergency work, inconsistencies wers noted in the definitions and requirements
for emergency work provided to operators and maintenance staff, Guidance,
definitions, and requirements for documentation of emergency work were provided
in Maintenance Programs Unit Administrative Manual Section 4.6, Rev.1,
" Emergency Work," Nuclear Power Division Administrative Procedur3 7.15, Rev.0,
" Initiation of a Work Request," and operating manuals 1/20M 48.2.C, Rev.18,
" Operating Procedures," and 1/20M-48.1.F, Rev.9, " Rules for Departure from Tech.
Specs." There was not clear separation between work performed as allowed by
10 CFR 50.54(x), and emergency work as defined in the maintenance procedure, or
work classified as Priority 1 Emergency or Priority 2 Urgent in the work request
procedure. Inspectors considered the lack of consistent guidance to be a weakness
in procedures. The issue was discussed with operations management. Orerations
and maintenance management agreed with this observation and initiated action to
revise procedures to establish consistent guidance for amergency work.
MWR 068364 was written to document the emergency repair work and installation
of the temporary modifiction, inspectors noted the MWR was coded as Priority
3 Expedite, even though it was declared emergency work. Inspectors noted that
the degraded linkage had been identified by operators and documented on
MWR 060437 in January 1997; however, the repair was postponed and not done,
though the opportunity existed during the two Unit 2 forced outages in 1997. This
was considered to be a weakness in the work control process that resulted in an
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unnecessary challenge to the operators when the linkage f alle '. Licensee
assessment of the linkage f ai!ure under the Maintenance Rule was not yet complete,
but preliminary evaluation was that it would be considered a maintenance
preventable functional f ailure,
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c. Opnclusions
inspectors assessed that the licensee responded appropriately to the valve linkoge
f ailure and noted good coordination between operators, system engineering, and
maintenance staff. The prompt response eliminated a potential challenge to safe
plant operation. Some inconsistencies were noted in the guidance provided to
operators and maintenance staff regarding emergency work, in addition, inspectors
assessed that f ailure to repair the degraded Skage during earlier opportunities
indicated a weakness in the work control process that unnecessarily challenged
operators when the linkage subsequently failed.
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M1.4 Equtine Surveillance Observations (01726)
The inspectors observed portions of selected surveillance tests. Surveillance tests
l reviewed and observed by the inspectors are listed below.
- 1 BVT 1.1.7, Rev.2 Rod Position Indication System Calibration Verification
- 1 BVT 1.1.1, Rev 0 Control Rod Drop Time Measurement
The surveillance testing was performed safely and in accordance with proper
procedures. The inspectors noted that an appropriate level of supervisory attention
was given to the testing, depending on its sensitivity.
! M8 Miscellaneous Maintenance issues
M8.1 Emeroency and Annendix R Llahtina (62707)
Inspectors reviewed the UFSAR, Operating Manuals and Preventive Maintenance
Procedures (PMPs) for both units regarding Appendix R Lighting and Emergency
Lighting maintenance and testing. Licensee personnel contacted were
knowledgeable. The PMPs fulfilled surveillance requirements in licensee
administrt,tive procedure NPDAP 3.5 and assured that the requirements of Section
Ill.J of Appendix R to 10 CFR Part 50 were met. The inspectors identified minor
discrepancies which the licensee entered into the corrective action program to be
resolved.
Ill. Enaineerina
E1 Conduct of Engineering
E1.1 Unit 1 Small Bore Pioina Ooerability Assessment
a. inspection Scoce (37551. 92903)
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In June 1997, while perfomdng reviews for a motor operated valve replacement,
engineers noted that. a sliding st'pport for a 2-inch diameter seactor coolant system
valve drain line (PS-2) was disengaged from its guide. The inspectors reviewed
design documentation, interviewed personnel, and observed licensee inspection and
repair activities to evaluate the licensee's resolution of this problem including extent
of condition reviews,
b. Q .grvations and F edinas
NRC Inspection and Enforcement Bulletin (IEB) 7914," Seismic Analyses for As-
Built Safety Related Piping System," Rev.1, required .'icensees to confirm safety
related piping .121/2 inches in diameter, as installed, satisfied seismic design
requirements. No specific action was required regarding smaller bore piping. In late
1996, the licensee identified inadequately supported small bore piping inside
containment (see LER 50-334/96-010). Three deficiencies were corrected and a
sample inspection identified no further deficiencies. Engineering Standard ES-N-
017, " Pipe Stress Reconciliation," was instituted to ensure no additional piping
support defeciencies were created through plant design changes. ES-N-017
specified that computer based stress calculations be performed to reconcile as-
installed piping configurations against design requirements prior to implementing
piping design changes. In June 1997, engineers identified that support PS-2 was
disengaged from its guide while reviewing a photograph in preparation for replacing
a motor operated valve inside containment. Additionalinspections were initiated to
determine the extent of condition.
Engineers initially reviewed all .12-inch diameter and smaller, safety related Q1
category piping attached to the reactor coolant system (RCS). Twelve slidirm type
supports were identified as being susceptible to significant RCS loop mov .t
which would challenge support integrity. Two supports (PS-2 and PS-3) w 1. s found
disengaged. Six were inspected and found satisf actory. Four of these had the
same design as PS-2 and PS-3. The two disengaged supports and those with
similar design were replaced using design rhange package (DCP) 2263. The
remaining four sliding supports were determined to be acceptable through routine
inservice inspection program activi'.ies.
Extent of condition review scupe quickly expanded through the condition report
process (CR 970999). Bar type anchors were reviewed based on reassessment of
LER 50-334/80-056. Twenty-three bar type anchors were modified based on these
inspections. Engineers determined that many of the piping, anchor, and support
deficiencies were due to original construction design not meeting applicable
American National Standards institute (ANSI) B 31.1-1967 or American Institute of
Steel Construction (AlSC) Seventh Edition codes. UFSAR B.2.1.9 indicates that the
small bore safety related piping was originally evaluated under a " simplified" method
that did not employ formal calculations. Engineers concluded that this condition
was not applicable to Unit 2 because Unit 2 required small bore piping evaluation
using rigorous computer based analytical methods. fhe licensee submitted a
vo'untary report (LER 50-334/97-035)to report the Unit deficiencies as a
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potentially generic issue. The station architect engineer performed a 10 CFR 21
evaluation of the bar type anchor deficiencies, arx. concluded that the condition did
not appear to result in a substantial generic safety hazard. The licensee performed
additional inspections in the Fall of 1997, and generated CR 971875 and CR
972079 regarding additional small bore piping support design deficiencies. _
Engineers determined that numerous sliding supports and bar type anchors were
inadequately designed for their intended application in the plant. Sliding supports
were damaged by piping movement associated with normal thermal plant transients.
The conditions existed since original plant design and construction. Three additional
conditions which resulted in not meeting design requirements were identified: (1)
installed valves in small bore piping systems may be heavier than accounted for in
original plant design; (2) pipe supports in small bore piping systems were
inadequately designed to support rated load capacity; and (3) interaction of non-
safety related small bore piping with safety related piping (Q-Breaks) were not
adequately considered in original plant design. Thirty-eight additional supports were
modified during refueling outage number 12 using DCP 2298 to restore them to
Code requirements.
The inspectors observed field walkdowns and several support and anchor
modifications, and discussed ongoing project status with the Director of Design
Basis Engineering. Based on the above observations, the licensee initiated a support
design review of all safety related small bore piping and associated Q-Breaks.
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Approximately 2400 support drawings and over 650 piping isometr!c drawings were
analyzed against Code design requirements. This extensive verification effort was
staffed with approximately 80 engineers, the majority of which were contractor
suppor'. The inspectors determined that appropriate oversigh: of the contracted
engineering support was provided. Engineers identified approximstely 200 small
bore piping support and anchor Code deficiencies. Affected systems included the
RCS, excess letdown system, letdown system, reactor coolant pump seal leak-of f,
RCS loop fill, RCS charging, and high head safety injection. Due to the large
numbc of deficiencies, each of associated system piping isometric drawings was
analyzed for operability using NRC Generic Letter 91-18 as guidance, The licensee
concluded that each of the analyzed piping systems remained operable,
notwithstanding the numerous Code deficiencies. This assessment was completed
in mid-December 1997. The inspectors observed that the methodology used for
operability assessment was sound.
Basis for Continued Operation (BCO) 1-97-007 was developed to document the
justification that it was safe for Unit 1 to start up and operate at power prior to
restoring each of the identified small bore piping supports and anchors deficiencies
to fully meet Code requirements. The BCO specified that all associated pip!ng
aystems remained operable. The BCO will remain in effect through the end of the
upcoming operating cycle, with restoration of supports and piping to full design
requirements schcJuled for tb.t next refueling outage. The inspectors reviewed the
BCO and attended the Nuclear 5afety Review Board (NSRB) meeting durir g which
the BCO was evaluated. The inspectors observed that the safety issue was clearly
presented by Nuclear Engineering Department personnel. Detailed background as
well as potentially generic aspects were discussed. The NSRB concurred with the
Onsite Safety Committee approval of the BCO. The inspectors determined that the
safety analysis performed for the BCO was technically sound.
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10 Cl R 50, Appendix A, Criterion 15, " Reactor Coolant System Design," seguires
the RCS to be designed with sufficient margin to assure that the design conditions
of the reactor coolant pressure boundary are not exceeded during any condition of
normal operation, including anticipated operational occurrences.10 CFR 50.55(a)
reqess in part that systems and components must be designed, and constructed to
quality standards commensurate with the importance of the safety function to be
perfctmod; ANSI B31.1-1967specified Code requirements for installed piping
support integral welds (Q-Breaks). AISC Seventh Edition specifies load
recuirements for piping supports. Failure to originally design and install piping
supports and anchors commensurate with the applicable Code standards was a
violation. 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 50 334/97 09 01),
c. Conclusions
The inspectors concluded that engineers demonstrated an excellent questioniog
attitude in identifying a non-conforming safety related small bore piping deficiency.
Over 200 supports and anchors did not meet Code requirements due to inadequate
original construction design specification. Extent of condition reviews, findings,
causal assessment, ano corrective actions were comprehensive. Communication of
this potentially generic issue to the industry demonstrated a sound safety
l perspective.
E4 Engineering Staff Knowledge and Performance
l E4.1 Control Room Emeroency Pressurization Ventilation System Desian Deficiencies
a. insoectinn Scooe (71707,37551,92901,92903)
Inspectors reviewed the licensee's follow-up to an anomaly observed during control
room emergency air cleanup and pressurization system testing. The inspectors
- reviewed the surveillance testing procedure,3BVT-1.44.1," Control Room
Emergency Bottled Air Pressure Test," Rev. 4, and the design and licensing bases
documents associated with the control room emergency ventilation system,
b. Observations and Findinas
On December 9, the system engineer and operators performed 3BVT-1.44.1,a TS
surveillance required every 18-months, to test the control room ventilation systems.
During the testing, the operator observed the Unit 2 "B" emergency supply fan
running indicator light cycle off and on approximately 11 seconds after the initial
auto-start of the fan. A sccond auto-start of the fan showed the same ancmaly.
The fan was declared inoperable.
Subsequent troubleshooting and engineering review identified the problem to be the
differential pressure switch actuating and stopping the "B" fan, which resulted from
the difference in opening times of the control room dainpers. P~:ing the
,. .
. . . .. .
. . . .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
y
8
.
engineering review of possible corrective actions, engineers identified that the
control room ventilation system did not meet single failure criterion for other failures
within the system. Both trains of the Unit 2 control room emergency ventilation
system were declared inoperable. At 1 p.m. on December 16,1997, the licensee'
commenced a shutdown of Unit 2 as required by TS 3.0.3.
. The inspectors noted that excellent attention to detail by the operator during the
performanes of the surveillance test led to the initial discovery of the anomaly, The
control room indication showing the cycling off and on of the fan lasted less than
1 second. The test had been performed seven times previously without observation I
of the anomaly.- Additionally, the engineers displayed a strong questioning attitude
in discovering the fmilure to meet single failure criterion.
The exact design and licensing basis for the system, as well as potential impact on
- control room habitability dose calculations for design basis accidents, were still
.being evaluated at_the closa of the inspection period. The single failures that would -
_
.
potentially place 'he Unit 2 control ventilation system outside its debian and
l licensing basis included failures of the "A" train inlet or outlet dampers due to some
!
'
electrical or mechanical failures and failure of the "A" fan mechanically. The
licensee's preliminary evaluation determined that the failure modes and effects.
analysis completed prior to the Unit 2 original startup was deficient in the evahation
!; of the control room emergency ventila41on system. Corrective actions to address
the design deficiencies were still being determined at the close of the inspection
period.- The licensee plans to keep Unit 2 shut down until the control rnom
ventilation corrective actions are completed.
The control roorn ventilation design issue will be an unresolved item, pending NRC
review of the licensee's full examination of design and licensing basis and licensee's
corrective actions to address the deficiencies. The corrective actions and the root .
cause evaluation were being performed under Condition Reports 972271
and 972304. '(URI 50 334 AND 412/97 09-02)
c. _ Conclusions
- The operator's strong attention to detail and the engineers' rigorous q"estioning
attitude led to the discovery of deficiencies in the Unit 2 control room emergency
ventilation system. The licensee's full assessment of the design and licensing basis
and corrective actions was not completed.
IV. Plant Suonort
R1- Radiological Protection and Chemistry (RP&C) Controls
_ a. Insoection Scone (83728)
The inspector reviewed the licensee's program for maintaining occupational
exposures as low as is reasonably achievable (ALARA). The inspection was
- accomplished by a review M plant documents and procedures, interviews with
. personnel and walkdowns of the related areas.
. . . . . . . . . .
.
.
9
b. Observations and Findinna
The licensee's program for maintaining occupational exposures ALARA is based on
three procedures, as listed below:
NPDAP 3.1, Rev 3, " Exposure Control" (effective date 7/14/97)
Health Physics Manual, Appendix 11, Rev 1, "ALARA Program" (effective
date 12/5/97)
RP 8.5, Rev 3, "ALARA Review Program" (effective date 12/5/97)
The inspector reviewed these documents and verified that they accurately reflect
current plant operations and methodologies for conducting the ALARA program.
All work performed at Beaver Valley currently requires the issuance of a
Maintenance Work Request (MWR) or a Design Change Package (DCP). Routine
work and maintenance activities are scheduled based on a 12 week planning cycle,
with the issuance of an MWR allowing work to be performed. Typically, MWRs are
received 6 7 weeks prior to the start of work, which is a notable improvement over
the one week or less typicitly seen prior to 1997. A work review screening
committee has also been established, which meets daily to discuss opcoming work.
The licensee currently does not have a dedicated work control center, although the
screening committee performs somewhat similar functions. DCPs are written by the
Engineering Department for plant modifications. Although the engineer assigned for
a particular DCP is responsible for ensuring appropriate exposure minimization
techniques and designs are incorporated into the design c,hange, close coordination
with the ALARA health physicists allows for a collaborative effort in this area.
Work in the RCA which involves any one individual receiving 200 millirem or more,
or a work party receiving 1000 millirem or more, automatically requires an ALARA
review. This is also identified in the MWR computer data base. ALARA reviews are
written by the RWP/ALARA Planning Group, and controls placed in the ALARA
review are then incorporated into the RWP.
Outage work is contrc%d through the Planning and Outage Management Group.
For the upcoming Unh ? refueling outage in 1998, a station goal has been
established to identify all work in the RCA and submit the Section 12s (RWP
requests) of the MWR to the RWP/ALARA Planning Group not less tnan 90 days
before the commencement of the outage. Any tasks identified after that time must
be submitted to the Planning and Outage Management Group for their review and
approval before it can be added to the outage scope. This is a significant
improvement in the lead time provided to the RWP/ALARA Planning Group for
preparing for the outage.
Recently, the licensee significantly revised its ALARA Committee format.
Previously, the ALARA Committee was chaired by the ALARA Coordinator, and
included representatives from each of the major departments, in general, the
committee members were not supervisors, and so the committee's control over
manpower resources and finance was limited to making recommendations only.
Under the revised NPDAP 3.1 referenced above, the Nuclear ALARA Review
_ _ - __ _ _ - - - -
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, 10
Committee (NARC) is now chaired by the Division Vice President, Nuclear
Operations and Plant Manager, and membership consists of the various major
department managers, with alternates not authorized. The NARC is required to
meet at a minimum of once per quarter, and held its first meeting just prior to the
commencement of 1R12.
Annual exposure goals are established by the ALARA coordinator, based in part on
three year average exposure goals and anticipated work scope. The station goals
are turther subdivided into departmental goals. Department heads and the plant
manager then review, modify (as necessary) and approve the goals through the
NARC. For 1997, the station goal was established at 256 person-rem. This goal
was subdivided further to include 231 person-rem for 1R12,16 person-rem for
operating periods at Unit 1 and 9 person rem for a full operating year at Unit 2. No
contingency was incorporated into the goal for forced outages during 1997. By
_
December 1997, the licensee had experienced two radiologically significant forced
outages at each unit, resulting in 56.587 person-rem of exposure. The Unit 1
outage goal was la or changed to 201 person-rem to ebsorb some of the exposures
seen during the forced outages, but no significant reduction to the outage scope
occurred. While the Unit 1 refueling outage (1R12) has extended some 40 days
over its goal, the exposures were approximately 223 person-rem, which is above
the 201 person-rem goal for a 40-day outage, but is below the originally established
outage goal of 231 person-rem. Unit 1 has never previously completed a refueling
outage for less than 260 person-rem. For 1997,it appeared that the licensee would
have a site total occupational exposure of app.oximately 300 person-rem, which
would be one of the lowest annual site exposure totals for any year including a
refueling outage. For 1998, a preliminary goal for each department and for the site
has been calculated by the ALARA Coordinator, but has not yet been reviewed and
approved by the NARC. The 1998 goal willinclude exposures from a Unit 2
refueling outage scheduled to commence on April 17, and last t.pproximately 36
days.
c. Conclusions
The licensee continuad to implement an effective program for maintaining
occupational exposures ALARA. Improvements in work planning have added to the
lead time provided to the RWP/ALARA Planning Group for planning radiologically
significant work. Although the sanual exposure goal for 1997 has been exceeded,
the additional occupa+.ional exposure appears traceable to the unplanned forced
shutdowns at the facility.
j R4 Staff Knowledge and Performar.ce in RP&C
R4.1 Unit 2 Post Accident Samolina System (PASS) Drill (71750)
On December 23,1997, inspectors observed the Unit 2 PASS Drill, prebrief, and
post drill critique. The participants were knowledgeable on the systen.s and
effectively obtained samples gas and liquid samples. The inspectors noted good
coordination between the chemistry and health physics technicians. The chemistry
technicians effectively handled several problems encountered during the diill. The
post drill critique was adequate to identify problems and possible improvements.
1
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, 11
The inspectnrs observed additionalissues not discussed in the post drill critique.
These issues were adequate'y addressed following NRC questioning.
R7 Qwlity Assurance in P.adiological Protection and Chemistry Activities
a. Insoection Scope (83728)
The inspector reviewed audits and surveillances of the radiation protection and
ALARA program performed both before and during the Unit 1 refueling outage
(1R12). The inspector also interviewed Quality Assurance personnel involved in
conducting these. audits, and reviewed their findings and the corrective actions
taken,
b. Observations and Findinas
The licensee conducted its annual audit of the Health Physics program during the
Unit 1 refueling outage. The audit (BV-C-97-12) was completed on
November 21,1997, but at the time of this inspection, the final audit report had not
yet been issued. The inspector reviewed the audit findings and conclusions, which
were presented to licensee management in November, with the lead auditor. Six
Condition Reports (CRs) were issued as a result of this audit. Although the required
response to these CRs has not been received yet, actions taken to address audit
identified deficiencies in the ALARA program, related to consistency of requirements
between procedures, was evident in the recently revised procedures listed in
Section R1, above. The audit team, which included a technical specialist, provided
an effective evaluation of the health physics program, both from a complience and
l
performance basis,
in addition to the audit, two surveillances of the health physics program were also
undertaken during the Unit 1 refueling outage. Additionally, earlier in 1997, four
surveillances in health physics, four surveillances in radwaste, and two suiveillance-)
of health physicr. involvement in emergency drills were also conducted. The lead
auditor indicated to the inspector that the results of these surveillances will be
incorporatc d into the annual audit.
c. Conclusions
~
The licensee conducted a program of audits and surveillances in the health physics
area cf sufficient scope and technical depth to provide early identification of
discrepancies, and a means to evaluate compliance with reguiatory requirements
and also provide a performance-based eveluation of the health physics program.
R8 Miccellaneous RP&C issues
R8.1 (Closed) Ins 9ector Follow-up Item (IFI) 50-334 and 412/97-04-04: Process Control
Program (PCP) Update.
The licensee issued a full revision to the PCP (Issue 5.0, Revision 0, Process Control
Program), effective date November 5,1997. The inspector reviewed this
document, and toured the plant radwaste processing systems verifying that this j
document accurately reflects current plant conditions. This item is closed.
.
.
. .
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12
P2 Status of EP Facilities, Equipment, and Resources
a. Inspection Scone (82701)
The inspectors toured the control room area, the technical support center (TSC), the
emergency operations facility (EOF), the alternate emergency operations facility
(AEOF), the radiological operations center (ROC) and the joint public information
center (JPIC) to evaluate the readiness of these facilities. At each of these facilities
the inspectors performed a spot check of equipment and supply lockers to
determine their conformance with NRC regulations and the onsite emc 7ency plan.
They also reviewed communication and ventilation systems surveiilances for
equipment loce'.ed in several of these facilities. The licensee demonstrated the
features and capabilities of the recently implemented Beaver Valley Emergency
Response System (BVERS), which is used for activation of the emergency response
organization (ERO) and for conveying protective action recommendabon information
to the offsite agencies,
b. Observations and Findinas
The licensee changed the seating location arrangements of the major decision
makers and their statis in the TSC and EOF since the last inspection. This initiative
was part of a project designed to improve command and control and teamwork of
the F.RO. This project was undertaken with the assistance of a consulting firm.
The emergency response facility changes wero validated during the performance of
several mini-drills, and they were refined based on the results of those drills.
l
!
The licensee also adopted, since the last inspection, a new computer-driven
communication circuit for notifying the ERO and for communicating offsite
protective action information with offsite agencies. This system, BVERS, consists
of two subsyMems which are activated from any touch tone telephone and use
I
password security. These systems replaced two older, separate systems that
performed the same functions. The BVERS system enhances the licensee's
capabilities for accomplishing both timely ERO activation and reliable
communications with offsite agencies. The licenses is evaluating a future
expansion of B\rERS system capability by using it to perform initial notification to
offsite agencies of emergency events.
The readiness of the onsite facilities was as described in the emergency plan. There
was adequate equipment and supplios and revisions of the emergency plan and
procedures were current. EP supply lockers in the facilities were kept sealed and
contents were sufficient, but the inspectors noted a lack of control of the plastic
seals used to verify the integrity of the lockers. Extra, unused seals were present
either in or nearby the lockers in the Attemate EOF, the control room area and the
Unit 2 pump house. Although the locker at t5e Unit 2 pump house was padlocked
and the control room lockers were located in a vital area that is always occupied,
the presence of these extra uncontrolled seals negated the effectiveness of having
any seals kept on the lockers in the first place. Licensee management stated they
plan to address the issue.
1
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,
13
The reviewed ventilation surveillances indicated that the design criteria of the
emergency response facilities (TSC and EOF) were satisfied. Ti.e reviewed
communication test surveillances indicated that tho licensee was testing these
circuits in accordance with both the emergency plan and NRC requirements with
ono exception.
At the Alternate EOF, the licensee maintains the following comrnunication
capability:
-
two dedicated, inter facility phone circuits
-
one radio transmitter / receiver for communication with radiation monitoring
teams
-- 27 commercial phone lines for communication between licensee emergency
facilities and for communication with offsite agencies
Twenty of the 27 corrmercial phone lines are normally off-line and activated by a
switch that is repositioned as part of the facility activation procedure. The seven
lines that are always operational are used on a daily basis by a group working out of
-
spaces used for the Alternate EOF. The licensee does not test these seven lines
since the group using them does so on a daily basis, and any problems would be
reported promptly. The licensee's emergency plan credits this practice for ensuring
operability of these phone lines.
The twenty commerciallines enabled by switching are not normally used and
problems with these lines would not be promptly identified. The licensee has only
tested these lines sporadically since their installation as part of training
walkthroughs, and these tests have not been formally documented.
The inspectors discussed this testing oversight with licensee management
representatives both during the inspecticn, at an exit interview on December 12,
1997, and in a telephone conversation on December 16,1997. Licensee
management agreed during those discussions that periodic testing of the phone
lines in question was appropriate, and licersee management orally stated an
intention to accomplish this. The Director of EP initiated EP tracking item number
97-075 to include the twenty phone lines in question into the testing program.
Subsequent to the inspet- 'n, the lines were tested and several were found to be
inoperable. These were rep ired and returned tc service.
c. Conclusions
The inspectors concluded that the licensee's emergency facilities were generally
wcII-maintained. The licensee's modification of the TSC and EOF floor plans were
adequately planned, validated and documented. They are improvements over the
previous floor plans for these facilities. The BVERS system is also an improvement
over the two communication systems it replaced. The uncontrolled use of locking
seals on equipment and supply lockers was a weaknesses in EP facility oversight.
'
The failure to regularly test the off-line commercial phone lines at the Alternate EOF
is a violation of Section IV.E.9.a-d of Appendix E to 10 CFR 50; since these lines
could be relied upon to perform the functions described in that part of NRC
regulations if the Alternate EOF was activated. (VIO 50 334 and 412/97-09-03)
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, 14
P3 EP Procedures and Documentation
a .- Insoection Scoce (82701)
The inspectors reviewed recent revisions the licensee made to the emergency plan
and implemonting procedures. The list of reviewed revisions is included as
Attachment I to this report. The inspectors reviewed these revisions to verify their
conformance with 10 CFR 50.54(q) of NRC regulations. This regulation allows
licensees to make changes to their emergency plans that do not decrease the
effectivenese of the plans without obtaining prior NRC approval.
The inspectors also reviewed selected evaluations the licensee had performed for
recent changes to the emergency plan and implementing procedures. Finally, they
discussed the nature of some of these changes with licensee management
representatives.
Observations and Findinos
The licensee had completed a major revision of its emergency plan and
implementing procedures in June,1997. That revision included, among other
changes, the implementation of the BVERS communication system and the
realignment of certain emergency lesponse resources between the TSC and EOF.
Certain changes were also made to the implementing procedures to reflect the
recent plan changes and to eliminats redundant procedural steps.
The inspectors noted some discrepancies in their review of licensee revisions to the
emergency plan and implementing procedures. Among the discrepancies noted was
the deletion of a monthly communication testing r6quirement from the plan without
evaluating this deletion for a decrease of the plan's effectiveness. The requirement
for the monthly test was reinstated. Also, the description of a key function of the
Nuclear Communications group during an emergency was deleted inadvertently from
the plan without a 50.54(q) evaluation being performed.
The inspectors also noted changes the licensee made to the implementing
procedures that indicated possible decreases in the licensee's ability to implement
the emergency plan. First, the inspectors observed that revised notes in the
procedures for the activation, operation and deactivation of the TSC and EOF
(implementing procedures EPP/IP 1.4 and EPP/IP 1.6) changed the expected
activation times for those facilities from one hour after the initiating event
declaration to al29Ml one hour after the declaration. Second, certain steps in these
two procedures were re-located to checklists attached to the procedures. Thess
checklists, however, had notes at the beginning of them stating that their use was
optional; that they were not required to be completed. Third, the most recent
revision to the procedure for communications and dissemination of information
(EPP/IP 1.2) deleted a dedicated radiological controis circuit from the ROC in the
communication matrix located in an attachment to the procedure. This change is
the matrix was apparently a typographical error.
The inspectors discussed these changes with the licensee since they indicated a
decrease in the licensee's ability to effectively implement the emergency plan.
Through these discussions the inspectors learned that the changes did nqt represent
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e
, 15
a relaxation of the licensee's expectations for facility activation or procedural
compliance. Licensen management stated that they still expect responders to
activate the facilities within one hour of the initiating event declaration. They stated
that the wording was changed to accommodate the infrecuent cases where
activation occurred shortly after one hour's time had elapsed. The licensee also
stated its expectation was that the checklists attached to procedures EPP/IP 1.4
and EPP/IP 1.6 be at least referred to in the course of facility activation and
operation in order to verify the completion of important and large tasks.
As a result of discussing the above findings, the licensee initiated a convition report
(number 972275)to investigate corrective actions for some of the problems the
inspectors identihed. The licensee also initiated EP tracking items to revise the TSC
and EOF implementing procedures to reflect licensee expectations for activation of
these facilities (97-073) and to evaluate the desirability of labeling procedural
checklists as optional (97 072).
The licensee had also self identified problems with its 50.54(q) review process
before this inspection. The Director of EP commissioned a self assessment to
evaluate how the review process could be improved. This self assessment resultad
in the development and implementation of a new process in October,1097;
however, this change was not implemented in time to be used to evaluate the latest
revision to the emergency plan,
c. Conclusions
The inspectors concluded that the licensee's process for performing 50.54(q)
evaluations for the latest emergency plan revision was weak. This conclusion was
based on several questionable changes that were made to the latest revision of the
plan and some procedures. The inspectors also concluded that the current
procedure for performing these evaluations is an improvement over the previous
procedure. The inspectors considered the licensee's prompt commitment to re-
evaluate some of the questionable changes to be proper.
P5 Staff Training and Qualification in EP
a. Insoection Scone (82701)
The inspectors evaluated the effectiveness of the licensee's EP training program for
the ERO. They reviewed selected EP lesson plans and examinations, interviewed
the EP training staff, attended a reactive EP training session for on-shift
communicators and reviewed the litt of qualified ERO responders to verify that they
were qualified in accordance with station procedures.
The inspectors also conducted an event classification tabletop walkthrough with a
Unit 2 crew to evaluate the effectiveness of training given in that area. Finally, they
interviewed three senior members of the ERO to evaluate the effectivenest of their
position-specific training and their knowledge of iecent changes to the site EP
program.
_ _ _ _ _ _ _ _ _ _ _ _
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. 16
b. Observations. Findinas and Conclusions i
The licensee has effectively ensured the training of ERO raembers and tracked their
qualifications. The EP instructors apply systematic-approach-to training (SAT)
principles to their training of ERO members. Lesson plans were reasonably
organized. The limited examination review of two EP course examinations showed
sufficient variation between examination versions. An audit of qualifications for the
current ERO list showed no serious qualific6tlon discrepancie-
The observed training session for on-shift communicators was conducted well. The
instructor provided objectives and the reason for the training. He solicited feedback
and the attendees rebuily provided it and asked questions.
The ERO members that the inspectors interviewed further demonstrated thu
effectiveness of the EP training program. The shift crew, two Emergency Response
Managers and one Emergency Director all were familiar with their duties and
responsibilities to the extent that they were questioned. The ERO managers were
also familiar with recent changes the licensee made to the EP program.
The insptictors concluded that the training program for the ERO met all regulatory
requirements and was implemented well.
P6 EP Organization and Administration
a. Inspection Scnce (827011
The inspectors interviewed EP management and ERO merabers on the changes
made to the ERO organization since the last inspection. They also reviewed a
vidootaped training presentation describing the incorporation of the team concept in
onsite response and the new callout methods. They also discussed EP staff
changes with the Director of EP.
b. Observatior.s. Findinas and Conclusions
The licensee, within the last year, made a significant change to the method of.
staffing the emergency responm., facilities for emergencies. Prior to this change, the
. licensee would notify all members of the onsite ERO when an emergency occuried.
Currently, the ERO has been divided into three teams which rotate through an on-
duty status. A fourth team exists for any necessary augmentations to the on-duty
team. The licensee has developed a set of expectations it has conveyed to the ERO
members to ensure that adequats responders always exist to staff the facilities in
the event of an emergency. These were conveyed in several training presentations
and are reinforced by weekly and monthly team communication drills. The licensee
conducted severai team building drills to familiarize the team members with each
other. The inspectors concluded that the licensee's convers:on to a team-oriented
response was an improvement over the previous response and that its
implementation was properly conducted.
_. __
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17
The licensee transferred the EP group from the Licensing organization to the
Management Services organization since the last EP inspection. Since the new
Manager of Management Services was formerly the Licensing Manager (and a
former Director of EP), the inspectors concluded that no adverse changes in
management oversight of EP had occorr-d as a result of this change in the change
in EP reporting chain.
The EP Director informed the inspectors that he had obtained authorization to
increase his staffing level by one additional position. He filled this position by
promotion from within the EP organization such that a vacancy currenny exists. He
hopes to fill this vacancy in the near future.
The inspectors concluded that the EP organization has not been weakened by the
changes that have occurred since the last EP program inspection. They further
concluded the' the authorization of an additional position in the EP program may,
when the position is finally filled, strengthen the EP organization's ability to maintain
the onsite and offsite EP programs.
P7 Quality Assurance in EP Activities (82701)
The inspectors reviewed the licensee's Quality Services audit report (report number
BV-C-97-01) of the EP program for calendar year 1997 and interviewed the lead
auditor. They concluded that the audit met all regulatory requirements of 550.54(t)
of NRC regulations and that the audit, and its attendant report, were much
improved over the calendar year 1996 audit and report. They concluded that the
lead auditor had been trained in the regulatory requirements of EP and had used a
detailed audit plan by which to perform the 1997 audit. TL. inspectors further
concluded that the Quality Services Department is suh;c.ently independent from the
EP reporting chain to ensure independence of the audit, and although the lead
auditor is a member of the ERO, her position in the ERO is one which allows her to
be sufficiently independent of EP organization influence.
V. Menaaement Meetinas
X1 Exit Meeting Summary
The preliminai/ results of the radiological controls and emergency preparedness inspections
wero presented to Mr. Jain, Mr. LeGrand, Mr. Brandt and other members of the licensee
staff on December 12. The inspectors presented the remainder of the inspection results to
members of licensee management at the conclusion of the inspection on January 12,
1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
X2 Pre-Decisional Enforcement Conference Summary
On December 10, a pre-decisional enforcement conference was held at the NRC Region i
office between Mr. J. Cross, President Generation Group, and members of his staff and
Mr. H. Miller, Regional Administrator, and members of the NRC staff to discuss the
,- _ __a
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_
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,
18
apparent violation documented in NRC Inspection Report 50 334 and 412/97-07 and a
related unresolved item in NRC Inspection Report 50 334 and 412/97 08. The results of
- the conference will be provided by separate correspondence. The slides presented at the
"
meeting are provided as an attachment to this report,
i
X3 Management Meeting Summary
On December 11, a management m7eting was held at the iJRC Region I office between Mr.
J. Cross, President Generation Group, and members of his staff and Mr. H. Miller, Regional
Administrator, end members of the NRC staff to discuss the current status of Beaver Valley
'
and DLC initiatives. The slides presented at the meeting are provided us an attachment to
this report.
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PARTIAL LIST OF PERSONS CONTACTED
D.LG
J. Cross, President, Generation Group
R. LeGrand, Vice President, Nuclear Operations / Plant Manager
S. Jain, Vice President, Nuclear Services
R. Brandt, Vhe President, Nuclear Operations
M. Pergar, Acting Manager, Quality Services Unit
D. Tulte, General Manaper, Nuclear Operations
R. Hansen, General Manager, Maintenance Programs Unit
R. Vento, Manager, Health Physics
D. Orndorf, Manager, Chemistry
F. Curi, Manager, Nuclear Construction
J. Matsko, Manager, Outage Management Department
T. Lutkehaus, Manager, Maintenance Planning & Administration
T. Cosgrove, Coordinator, Onsite Safety Committee
J. Macdonald, Manager, System & Performance Engineering
K. Beatty, General Manager, Nuclear Support Unit
J. Arias, Director, Safety & Licensing
W. Kline, Manager, Nuclear Engineering Department
l R. Brosi, Manager, Management Services
l 0. Arredondo, Manager, Nuclear Procurement
NB_Q
D. Kern, SRI
G. Dentel, RI
F. Lyor, RI
Ohio Emeraency Manaaement Aaency
E. Edwards, Radiological Analyst
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INSPECTION PROCEDURES USED
iP 37551: Onsite Engineering
IP 61726: Surveillance Observation
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71750: Plant Support
IP 82701: Operational Status of tha Emergency Preparedness Program
IP 83728: Maintaining Occupational Exposures Alara
IP 92700: Onsite Follow up of Written Reports of Nonroutine Events at Power Reactor
Facilities ;
IP 92901: Follow-up - Operations -
IP 92902: Follow up - Maintenance
IP 92903: Follow-up - Engineering
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
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ITEMS OPENED, CLOSED AND DISCUSSED
Opened
50 334 and 412/97-09-02 URI Control Room Emergency Pressurization Ventilation
System Design Deficiency (Section E4.1)
50 334 and 412/97-09-03 ' VIO . Status of EP Facilities, Equipment, and Resources
(Section P2)
Ooened/ Closed -
50 334/97-09-01 NCV Unit 1 Small Bore Piping Operability Assessment
(Section E1.1)
Closed
50 334 and 412/97 04-04 IFl Process Control Program (PCP) Update (Section R8.1)
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LIS7 OF ACRONYMS USED
1R12 Unit 1 Refueling Outage 12
AISC American Institute of Steel Construction
ALARA As Low As Reasonably Achievable
ANSI American National Standards Institute
BCO Basis for Continued Operation
- DVERS - Beaver Valley Emergency Response System
BVPS Beaver Valley Power Station
BVT Beaver Valley Tests
CCS Component Cooling Water
CFR Code of Federal Regulations
CR Condition Report
DCP Design Change Package
DLC Duquesne Light Company
EOF Emergency Operations Facility
EPP Emergency Preparedness Plan
ERO Emergency Response Organization
lEB Inspection and Enforceraent Bulletin
IFl Inspection Follow-up item
JPIC Joint Pubic Information Center
LER Licensee Event Report
MSP Maintenance Surveillance Procedure
MWR Maintenance Work Request
NARC Nuclear Alara Review Committee
NCV Non-cited Violation
NPDAP Nuclear Power Division Administrative Procedure
NSRB Nuclear Safety Review Board
OST Operational Surveillance Test
PASS Post Accident Sampling System
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PDR Public Document Room
PMP Preventive Maintenance Procedure
ROC Radiological Operations Center
RP&C Radiological Protection and Chemistry Controls
SAT Systematic Approach to Training
_TMOD Temporary Modification
URI Unresolved item
VIO Violation
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ATTACHMENT I
Emergency Response Plan and implementing Procedures Reviewed
DOCUMENT DOCUMENT TITLE REVISION
NO.
BVPS-EPP Beaver Valley Power Station Emergency Preparedness Plan 9
EPP/l 2 Unusual Event 12
EPP/l 3 Alert 12
EPP/l 4 Site Area Emergency 12
EPP/l S General Emergency 12
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EPP/IP 1.1 Notifications 16
EPP/IP 1.2 Communications and Dissemination of infoimation 10
EPP/IP 1.4 Technical Support Center Activation, Operation and 10
Deactivation
EPP/IP 1.6 Emergency Operations Facility Activation, Operation and 9
Deactivation
EPP/IP 2.6.8 Dose Assessment Based on Environmental Measurements and 6
Samples
EPP/IP 4.1 Offsite Protective Actions 8
EPP/IP 7.1 Emergency Equipment inventory and Maintenance Procedure 9
EPP/IP 9.1 Nuclear Communications Emergency Response Organization 9
(Controlling Procedure)
EPP/IP 9.3 . Activation, Operation and Deactivation of Nuclear 2
Communications Emergency Operations Facility
EPP/IP 9.4 Activation, Operation and Deactivation of the Joint Public 2
Information Center (JPIC)
EPP/IP 9.5 Activation, Operation and Deactivation of the Nuclear 2
Communications Corporate Offices -
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