ML20236X856
| ML20236X856 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/05/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| Shared Package | |
| ML20236X857 | List: |
| References | |
| 50-334-98-03, 50-334-98-3, 50-412-98-03, 50-412-98-3, EA-98-359, NUDOCS 9808100323 | |
| Download: ML20236X856 (4) | |
See also: IR 05000334/1998003
Text
_ _ _ _
_ _ _ _ _ _ - _ _
- - _ _ _ _ _ _
=
e
August 5,1998
EA 98-359
Mr. J. E. Cross
President
Generation Group
Duquesne Light Company (DLC)
Post Office Box 4
'
Shippingport, Pennsylvania 15077
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-334/98-03,50-412/98-03
NOTICES OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Cross:
,
The NRC conducted an inspection of the Beaver Valley Power Station (BVPS) facilities from
April 26 to June 27,1998. The enclosed report presents the results of that inspection.
During the 9-week period covered by this inspection report, you maintained both units in a
safe shutdown condition while your organization worked to identify and resolve degraded
equipment and design conditions. Our inspectors observed that your engineering,
operations, and maintenance personnel typically implemented appropriate actions to
resolve identified mode hold constraints. Unit 2 pressurizer power operated relief valve
(PORV) corrective maintenance and testing were safely performed. Identification of
nonseismically qualified capacitors in the high energy line break isolation circuit, during
routine preventive maintenance, demonstrated a good questioning attitude. In addition,
prioritization processes for maintenance and engineering backlogs generally demonstrated
appropriate risk insights.
You have developed and implemented an effective program for the calibration and repair of
radiological survey instrumentation, air sampling devices and electronic dosimeters, and for
maintaining an inventory of radiological sources at the facility. The program for periodic
leak testing of radiological sources was conducted in accordance with plant Technical
Specifications (TS). Controls for PORV work in the Unit 1 containment were determined to
be effectively established and implemented. The program for training and qualification of
radiation protection technicians was effectively established.
Notwithstanding these areas of good performance, based on the results of this inspaction,
the NRC has determined that two violations of NRC requirements occurred. These
violations are cited in the enclosed Notices of Violation (Notices) and the circumstances
surrounding them are described in detail in the subject inspection report. The violations are
i
of concern as follows. In the first instance, an increasing trend of human performance
errors involving inadequate procedure implementation occurred which challenged operators'
capability to maintain adequate plant configuration control. in the second instance, past
practices of venting the high head safety injection pumps prior to surveillance testing
g
$
I
9808100323 900805
ADOCK 05000324
.[.
G
m
_ __ - _ ___
- - _ - - _ - _ - _ _ - _ - _ _ - _ _ - _ - _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _
- _ _ _ - _ - _ _ _ - - - . _ _ _ - _ _ _ - - _ _ _ -
.
.
Mr. J. E. Cross
2
l
preconditioned the system because adverse conditions were revealed through the venting
l
process and not assessed and, as a result, invalidated the tests.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part,
to determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements. A response to the second violation is not required because our
inspectors verified your corrective actions during this inspection.
Our inspectors also reviewed several longstanding deficiencies associated with the testing
-
i
of safety related logic circuits and your actions to identify and correct these items. Each
deficiency represented a violation of the respective TS surveillance testing requirement.
l
l
The NRC is exercising discretion in accordance with Section Vil.B.3 of the Enforcement
Policy and is not issuing a Notice of Violation for these Severity Level IV violations
involving inadequate surveillance testing. Discretion is warranted because: (1) the
inadequacies were self-identified as a result of your initiative in response to NRC Generic Letter 96-01, (2) you implemented timely and effective corrective actions, (3) the testing
deficiencies were not likely to be identified by routine efforts, and (4) the actions that
caused the testing deficiencies are dated and not reflective of current performance. The
exercise of discretion acknowledges your good effort to identify and correct subtle
violations, that would not be identified by routine efforts, before the degraded safety
systems are called upon.
l
In addition, an apparent violation was identified and is being considered for potential
l
enforcement action. This issue involved instances between 1990 and present, in which
your staff identified that the TS were not adequate to assure station compliance with the
design basis as described in the Updated Final Safety Analysis Report. Despite identifying
l
these adverse to quality conditions, in some instances, you failed to establish appropriate
administrative controls and failed to request revisions to your TS to properly resolve these
i
l
conditions. Accordingly, no Notice of Violation is presently being issued for these
!
inspection findings. In addition, please be advised that the number and characterization of
apparent violations described in the enclosed inspection report may change as a result of
further NRC review. Additional NRC inspection, as well as assessment of your ongoing
investigations and corrective actions is necessary to determine the safety and regulatory
l
significance of these issues. You will be advised by separate correspondence of the
results of our deliberations on this matter. No response regarding the apparent violation is
required at this time.
I
r
. . . . . . .
.
.
. ..
.
. . .
. .
.. . . .
.. .
. . .
. . . . . . . . . . .
. . . . . _ - -
__
__
__ ____- ______ - ___ _ _ _ _ _
.
.
Mr. J. E. Cross
3
!
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
l
and its enclosures will be placed in the NRC Public Document Room (PDR).
'
Sincerely,
j
Original Signed By:
4
I
Charles W. Hehl, Director
Division of Reactor Projects
l
Docket Nos. : 50-334,50-412
l
i
Enclosures:
2. Notice of Violation with No Response Required
I
3. Inspection Report 50-334/98-03,50-412/98-03
cc w/encis:
S. Jain, Senior Vice President, Nuclear Services Group
l
D. Brandt, Vice President, Nuclear Operations Group and Plant Manager
!
R. LeGrand, Vice President, Operations Support Group
W. Kline, Manager, Nuclear Engineering Department
B. Tuite, General Manager, Nuclear Operations Unit
M. Pergar, Acting Manager, Quality Services Unit
S. Hobbs, Director, Safety & Licensing Department
J. Macdonald, Manager, Systeni and Performance Engineering
M. Clancy, Mayor, Shippingport, PA
Commonwealth of Pennsylvania
State of Ohio
State of West Virginia
l
l
,
1
L.______________
- _ _ _ _
.-
- _ - _
-
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
e
.
Mr. J. E. Cross
4
1
l
Distribution w/encts:
Region i Docket Room (with concurrences)
PUBLIC
Nuclear Safety information Center (NSIC)
)
NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
M. Evans, DRP
N. Perry
'
D. Haverkamp, DRP
C. O'Daniell, DRP
D. Holody, EO, RI
l
Distribution w/encls (VIA E-MAIL):
B. McCabe, OEDO
R. Zimmerman, ADPR, NRR
J. Goldberg, OGC (AEN, LFD)
J. Lieberman, OE (OEMAIL)
,
D. Holody, EO, RI
R. Capra, PD1-2, NRR
V. Nerses, PDI-2, NRR
R. Correia, NRR
F. Talbot, NRR
DOCDESK
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\\ BRANCH 7\\BV\\lR98-03.BV
,
To receive e copy of this document, indicate in the boa: "C" = Copy without ottachment/ enclosure
'E" = Copy with attachment / enclosure
"N" = No copy
,
(
" OFFICE
Rl/DRP
Rl/DRP
l
Rl/DRP q
lc (Rl/ORAyff
NAME
DKern/al
gg,
MEvans
EE
CHeht. 1/A
fTWalker'
n
DATE
07/3098
07/3U98 9/ggg
OgF,g981
'
'/ 0%/i/98
OFFICIAL RECORD COPY
_ - - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _