View source for L-99-053, Responds to NRC Re Violations Noted in Insp Repts 50-334/98-11 & 50-412/98-11.Corrective Actions:Cr 990345 Was Written on 990216 to Document Overall Condition in CAP & to Provide Rollup Document Ref Related Corrective Actions

{{Adams
| number = ML20205F130
| issue date = 03/29/1999
| title = Responds to NRC Re Violations Noted in Insp Repts 50-334/98-11 & 50-412/98-11.Corrective Actions:Cr 990345 Was Written on 990216 to Document Overall Condition in CAP & to Provide Rollup Document Ref Related Corrective Actions
| author name = Jain S
| author affiliation = DUQUESNE LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000334, 05000412
| license number = 
| contact person = 
| document report number = 50-334-98-11, 50-412-98-11, L-99-053, L-99-53, NUDOCS 9904060123
| title reference date = 02-25-1999
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 11
}}

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ver Valley Power Station SNppingport PA 15077 0004 s          .
Senior Vice President                                                                  Fax   4) 64 -8 9 h          we Division March 29, 1999 L-99-053 U. S. Nuclear Regulatory Commission
                  / A ttention: Document Control Desk Washington, DC 20555-0001

==Subject:==
Beaver Valley Power Station, Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 NRC Inspection Report 50-334/98-11,50-412/98-11 Reply to a Notice of Violation l
In response to NRC correspondence dated February 25,1999, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
Please contact Mr. Mark S. Ackerman at (412) 393-5203 if there are questions concerning this response.
Sincerely, b'''                    ,
Sushil C. Jain         i c: - Mr. D. S. Collins, Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. W. D. Lanning, Director, Division of Reactor Safety, Region I
[' j Mr. H. J. Miller, NRC Region I Administrator 9904060123 990329                                                                          DEllVERING PDR      ADOCK 05000334 g                         PDR _                                                            g ggg79 ENERGV 0G0047

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l DUQUESNE LIGHT COMPANY Nuclear Power Division l                         Beaver Valley Power Station, Unit No.1 and No. 2 Reply to a Notice of Violation NRC Inspection Report 50-334/98-11, 50-412/98-11 Letter Dated February 25,1999 VIOLATION (Severity Level IV Supplement 1) l Description of the Violation                                                        l l
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from November 3,1998, until January 13,1999, the licensee failed to promptly identify and correct a condition adverse to quality in that investigation ofimproperly calibrated meteorological instrumentation channels was incomplete, corrective actions were untimely, and absent NRC involvement, the licensee would not have recognized and reported several related violations of technical specifications (TSs.) Specifically, on three occasions between April 22 and November 6,1998, wind speed and direction sensors were not calibrated as required by TS 4.3.3.4 (which required the sensors to be calibrated semi-annually.) On seven occasions during this same period, gaseous      ;
effluent releases were performed in violation of TS 3.3.3.4.a (which required that radiological gaseous releases be suspended.) In addition, the prolonged instrument inoperability was not reported to the NRC as required by TS 3.3.3.4.b (which required a special report to be submitted to the NRC.) Past and current equipment inoperability was not properly evaluated until questioned by the inspectors on      l January 13,1999. As a result, the licensee failed to identify and report the violations of TS 3.3.3.4.a and TS 3.3.3.4.b in a timely manner. Corrective actions for this issue failed to preclude recurrence, and on January 14,1999, wind direction sensor number 414 exceeded its required calibration frequency.
This is a Severity Level IV Violation Supplement 1.
f L
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Be!.ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 2 Discussion of the Violation The February 25,1999 Notice of Violation accurately characterizes the events related to the violation of 10 CFR 50 Appendix B Criterion 'GI " Corrective Action."
The Beaver Valley Power Station Quality Services Unit (QSU) performed an audit (BV-C-98-13) on the meteorological monitoring program from September through November 1998. Among several other observations, the QSU auditor determbed that 3 work orders may have installed wind sensors that had not been calibrated within the last 6 months as required by the techuical specifications.
The QSU auditor initiated a Technical Specification Interpretation (TSI) request on November 3,1998, to determine whether or not the technical specifications allowed for "on the shelf" storage without penalty against the semi-annual calibration time requirement. The TSI responder believed that the isue was purely historical and did not affect current operability. He also believed that QSU or the Safety and Licensing Department (SLD) would follow-up on reportability from a historical standpoint. Because the need for an answer did not appear urgent (no due date had been specified by QSU and none was required by procedure NPDAP 7.1 " Technical Specification Control Program"), the TSI responder elected to work on other TSIs that he considered a higher priority.                    !
The QSU auditor prepared and issued condition report (CR) 982223 on                    i December 18,1998, that identified the sensor calibration issue end stated that a        l TSI had been previously submitted The CR did not clearly document that the TSI request and issue were now 6 weeks old.
The CR was hand carried to the unit Nuclear Shift Supervisor (NSS) at both units.
Each NSS asked if the situation affected operability of the current installation and the auditor replied, in essence, that he believed that current operability was not affected but it was not his responsibility to make the final determinatio...
Throughout the communications there was an uriderlying belief that the currently installed wind speed sensors were operable because a recent design change package (DCP 2166) had replaced the wind speed sensors and because calibration          j documentstion associated with the work was checked by the Instrumentation and         ]
Controls (I&C) supervisor and confirmed to be current. The NSS did not probe           !
,        the issue further or request to personally review calibration dams for verification.
l l

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4 Beaver Velley Power Station, Unit No. I and No. 2 NRC Inspection Report 50 334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 3 The Unit 1 NSS then contacted SLD to discuss ! mediate reportability. SLD in iurn contacted I&C supervision and received assurance that the currently installed sensors were operable. No immediate reporting (i.e., per 10 CFR 50.72) was required. The CR was assigned to a SLD engineer for a ret.srtability determination and LER/special report preparation as necessary.
On December 31,1998, the assigned SLD engineer reviewed CR 982223 and determined the meteorological tower instrumentation in use prior to November 1998 had not met the technical specification criteria for calibration frequency.
Because this constituted a failure to perform a technical specification surveillance in the past, this was reportable as a condition prohibited by the plant technical specifications in accordance with Technical Specification Bases 4.0.3 and 10 CFR 50.73(a)(2)(i)(B). I&C was then requested to provide an expedited CR response to support the development of the associated LER submittal.
1 The CR response was completed on January 8,1999. The respon',e addressed the fact that the purchase order for the vendor did not specify sensor calibration frequency requirements and that the maintenance surveillance procedures needed to be revised to ensure that the sensors were calibrated within 60 days prior to installation. The CR response did not fully address previous inoperability/
reportability, and due to a date review error by the investigator, the response failed to detent that the calibration for one of the newly installed sensors (#414) was about to expire. The LER preparer used the CR response as the main source of information and thus also did not independemly add ess previous inoperability/
repertability.                                                                         l On January 12,1999, Operations responded to the QSU auditor's TSI request by stating that an interpretation was not required due to the clarity of the calibration frequency requirement as stated in the technical specifications.
On January 13,1999, the I UR was presented to the Nuclear Safety Review Board (NSRB). The required qumum was present; however, an Operations representative and the CR investigator were not present, nor were they required to attend. The LER did not address potential violations of Technical Specification 3.3.3.4 action statements during the time frame when the wind speed sensors were inoperable due to expired calibrations. The NSRB suggested some minor changes         )
but did not detect that there was a potential second basis for making this issue reportable per 10 CFR 50.73 for a condition prohibited by plant technical

Belver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11 Reply to a Notice of Violation Page 4 specifications. Questions from the NRC senior resident inspector following the meeting pro.mpted the NSRB members to request additional investigation to determine if Technical Specification 3.3.3.4 Action Statement "a" (prohibits gas decay tank discharges) or Action Statement "b" (requires a special report) had been violated when there were less than the required number of operable meteorolm,ical    :
instruments.
The follow-up review by the SLD engineer identified seven instances during           l which gas decay tank discharges were perfonned without the required number of        j technical specification meteorological wind speed sensors being operable. At the time of tl'e discharges (prior to November 1998), the plant would not have been aware that the requirements were not met because the sensor calibration frequency issue had 'ot been ide itified.
The mow-up review also detected that sensor inoperability met requirements for submitting a special report to the NRC; however, no reports were submitted (again due to the condition not being detected.)
r                                                                                               ;
LER 1-98-029 was subsequently revised, reviewed by the NSRB, and submitted to        I the NRC on January 18,1999.                                                          l l
On March 19,1999, a new condition report was written to document our discovery       I that installed wind sensors were not calibrated over their entire wind speed service range but instead relied on an extrapolation assumption for part of the range. The   !
sensors are currently inoperable due to this new issue.                              '
Reason for the Violation The violation occurred because of a failure to fully implement the corrective action program. The identified weaknesses include:                                          i 1
a) promptness ofidentification and threshold for initiating a CR b) clarity of the issue as documented within initiated CRs c) condition report investigation completeness, including current and past operability and reportability implications d) initial corrective actions

Be:ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11,50-412/98-11
             , Reply .to a Notice of Violation Page 5 l
The effects of these weaknesses were amplified by a less than desirable plant staff sensitivity to implications of technical specification requirements. The supporting details of these weaknesses as causes for the violation are given in the following discussion.
A.       Condition Identification Delay The approximate 6 week delay in identifying the meteorological tower calibration problem in a condition report was caused by failure of plant staff to recognize the significance of the meteorological tower calibration question and initiate a          ,
condition report. Although many of the individuals involved (QSU acting manager, I&C supervisor, I&C director, Maintenance manager) had attended technical specification training, the issue of the wind sensor calibration was not immediately recognized as a problem, in part, due to comfort with past practices.
The involved individuals from these groups failed to use their knowledge to relate the sensor calibration practice to a compliance issue.
In addition, the identification delay was partially caused by procedures that were not adequate for the situation. Specifically, clear direction was not provided in NPDAP 5.2 " Initiation of Condition Reports" on the proper thresheld for initiating a CR. In this case, the proper concern resolution path should have been tne condition report process, not the technical specification interpretation process.      I A contributing factor was the absence of clear direction in NPDAP 7.1 " Technical Specification Control Program" for establishing appropriately prioritized due dates    i based on issue significance. The procedure did not require the Technical               ,
Specification Interpretation (TSI) request initiator to immediately write a condition  I report if the request involved a suspected operability issue. Finally, NPDAP 7.1       !
did not require direct communication between the TSI request originator and an on-duty NSS when questioning the operability of existing systems, structures, or components. Supervisor involvement and communication were not aggressive enough to compensate for the procedural weaknesses (e.g., site management reviewing the quality services condition report did not immediately question the six week time period between issue discovery and condition report initiation.)
Also contributing to the identification delay was a mistaken belief by the plant staff that ti e as a historical issue with:t the potential to impact current s
operabilit, inis belief was, in part, becue 9CP 2166 had recently replaced the meteorological tower wind rpeed sensors. Finny, there was a lack of i
       +

g Beav:r Vciley Power Station, Unit No. I and No. 2                                         )
NRC Inspection Report 50-334/98-11,50-412/98-11                                           1
            , Reply.to a Notice of Violation Page 6 accountability because of enclear system ownership and inadequate priority on the meteorolog'.ical tower because ofits perceived low safety significance.                  ;
B.      Condition Recurrence QSU identified the issue in a condition report on Decenber 18,1999. Once identified, the corrective action program failed to prevent recurrence, in part, because the Nuclear Shift Supervisor (NSS) was comfor.able with information              ]
regarding DCP 2166. The NSS did not believe the condition report documented a current operability issue and, therefore, relied on the reports of others and did not request that the specific calibration dates or supporting documentation be provided to him. It is not uncommon for the NSS to rely on reports from others; however, a stronger questioning attitude on the part of the on-duty NSS on this issue could have identified the pending expiration of a sensor (#414) calibration.
Inadequate attention to detail and self-checking functions performed by Maintenance caused a subsequent incomplete condition report investigation. The condition report investigator missed information in the current calibration i            documentation that should have caused him to detect that an installed sensor
(#414) calibration was nearing expiration.
C.      Historical Operability and Reportability Reviews l
The historical operability (and corresponding reportability) reviews were inadequate because these responsibilities were not clearly delineated in station procedures.
l Corrective Actions Taken and Results Achieved                                             i i
CR 990345 was written on February 16,1999, to document the overall condition
                                                                                                       ~
in the corrective action ptogram and to provide a rollup document referencing related corrective actions.
The original issue of the meteorological tower wind speed instrumentation calibration periodicity has been resolved. However, the meteorological tower wind speed instnimentation is currently inoperable due to additional issues discovered by the plant staff.
m                                                                                ~w

E Beaver Valley Power Station, Unit No. I and No. 2 NRC Inspection Re. srt 50-334/98-11,50-412/93-11
         , Reply,to a Notice of %1ation Page 7 Preventive actions to avoid further violations and to address the broader scope of the corrective action program issues are provided in the following section.
Corrective Actions to Avoid Further Violations A. Completed Actions
: 1. A review session has been conducted with the QSU staff to clarify management expectations concerning the prompt initiation of condition reports during ongoing quality services audits.
: 2. A " lessons learned" meeting was held within SLD to discuss the need to identify all criteria under which an event is reportable and to ensure historical (" backward look") reportability reviews are performed when necessary.
: 3. Condition report categorization and assignment duties are now performed by the Condition Assignment Board (CAB.) This format supports more thorough discussion of condition reports.
: 4. Maintenance procedures (IMSP-45.17-I and IMSP-45.17A-I) have been revised to require separate verification that the meteorological tower sensor calibration dates meet requirements.
B. Planned Actions
: 1. A memorandum will be issued to the plant staff to clarify management expectations regarding the need for a low threshold for initiating condition reports and for thorough investigations. The letter will emphasize the importance of the corrective action program and sensitivity to implications of technical specification               i requirements.
: 2. A multi-discipline team review, under direction of the Sr. Vice          ;
President, Nuclear Services, is in progress to examine the broader aspect of site sensitivity to technical specifications and effective use of the corrective action program. The focus of the review is the plant's:
a)      sensitivity to implications of technical specification requirements, b)      threshcld for writing condition reports, and,

Beaver Valley Power St2 tion, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11,50-412/98-11                                         j I
       , Reply,to a Notice of Violation Page 8 c)      thoroughness and completeness of condition report evaluations and corrective actions.
This will be done, in part, by:                                            ,
a)      analyzing Corrective Action Review Board (CARb) ejection            ,
data b'l     performing a sampling ofinvestigations and corrective actions for accuracy and completeness, paying special attention to condition reports related to technical specification issues c)      reviewing technical specification interpretations and the Operations backlog for adequacy and significance d)     reviewing the Operations logs for technical specification action statement entries to determine if condition reports were written as necessary e)     performing a sampling of engineering memoranda related to technical specification issues, assessing sensitivity to technical specification compliance, and assessing whether condition reports were written when appropriate                    i f)      conducting interviews with site personnel, assessing their un lerstanding of when to write condition reports and sensitivity to technical specification compliance g)      conducting interview s with management to assess the extent of their involvement in the corrective action program h)      reviewing corrective actions associated with response to this Notice of Violation i)      providing causes, corrective actions, and recommendations to management for final closure of this issue                        1
: 3. NPDAP 5.2 " Initiation of Condition Reports" will be revised to more clearly communicate management expectations for when it is                 I appropriate to initiate a condition report rather than using other mechanisms (e.g., a TSI request) to address an issue.
: 4. NPDAP 7.1 " Technical Specification Control Program" will be revised to require Operations to track technical specification

n Ber.ver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11
           , Reply, to a Notice of Violation Page 9 interpretation requests and establish requirements for prioritization and response times. As an added precaution, the revision will require a cendition report to be written and direct communication with an on-duty NSS when the operability status of existing systems, structures, or components is in question.
: 5. NPDAP 8.13 " Nuclear Safety Review Board" will be revised to require an Operations representative and the associated condition report investigator to attend NSRB meetings when LERs and NOVs are reviewed.
: 6.     'NPDAP 5.6 " Processing of Condition Reports" will be revised to clarify responsibilities for historical operability and reportability reviews associated with condition reports.
: 7.      Department managers (QSU, Chemistry, Health Physics, Maintenance, Operations, System and Performance Engineering, and Nuclear Engineering) and the Condition Assignment Board (CAB) will present this event as a communications meeting case study. The focus of the meetings will be proper use of the corrective action program, technical specification compliance sensitivity, and the relationship of the meteorological tower to technical specifications and the emergency plan.                                                !
: 8. This event will be reviewed as a case study with licensed Operations personnel as part oflicensed requalification training, with focus on responsibilities and expectations regarding Operations' role in condition report reviews, technical specification sensitivity, and use of the corrective action program.
: 9. Clear meteorological tower system ownership will be assigned to the System and Performance Engineering Department.
: 10. An assessment of technical specification systems will be performed to check for clear assignment of system ownership.
: 11. The NSRB Chairman will conduct a meeting with NSRB members and alternates to discuss LER and NOV review expectations.

w~.-
Beaver Valley Power Station, Unit No. I and No. 2 NRC Inspection Report 50-334/98-11, 50-412/98-11
         , Reply to a Notice of Violation Page 10
: 12. QSU procedures will be revised, and training provided, to reflect management's expectations regarding the prompt initiation of condition reports during ongoing quality services audits.
: 13.   ' Auditors fmm quality services will be provided technical specification training.
: 14. A review will be performed to identify additional groups to receive technical specification training.
: 15. A review team will evaluate the broader scope ofinstrumentation in the calibration program for similar issues to those identified with the meteorological tower wind speed sensors.
p_ qts When Full Compliance Will Be Achieved The original issue of the meteorological tower wind speed instrumentation calibration periodicity has been resolved. However, the meteorological tower wind speed instrumentation is currently inoperable due to additional issues discovered by the plant staff.
Preventive actions to avoid further violations and to address the broader scope of the corrective action program issues are in progress. The site memorandum to clarify Management expectations regarding condition report initiation and investigation will be issued by April 2,1999. The communications meetings to present this event as a case study will be completed by April 30,1999. The remaining corrective actions are scheduled to be completed by July 30,1999.
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