ML20205Q831

Ack Receipt of 990329 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-334/98-11 & 50-412/98-11 Issued on 990225.Actions Will Be Examined During Future Insp of Licensed Program

ML20205Q831
Person / Time
Site:	Beaver Valley
Issue date:	04/14/1999
From:	Schmidt W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J DUQUESNE LIGHT CO.
References
50-334-98-11, 50-412-98-11, NUDOCS 9904220088
Download: ML20205Q831 (2)

See also: IR 05000334/1998011

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April 14,1999

Mr. J. E. Cross

l President

Generation Group

Duquesne Light Company

Post Office Box 4

Shippingport, Pennsylvania 15077

SUBJECT: INTEGRATED INSPECTION 50-334/98-11,50-412/98-11

l Dear Mr. Cross:

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This letter refers to your March 29, 999 correspondence, in response to our

, February 25,1999, letter.

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Thank you for informing us of the corrective and preventive actions documented in your letter.

These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Original Signed By:

Wayne L. Schmidt, Acting Chief

Projects Branch 7

Division of Reactor Projects

Docket Nos.: 50-334; 50-412

cc w/o cv of Licensee Response Letter:

Sushil C. Jain, Senior Vice President, Nuclear Services Group

K. Ostrowski, Vice President, Nuclear Operations Group and Plant Manager

R. Brandt, Vice President, Operations Support Group

B. Tuite, General Manager, Nuclear Operations Unit

W. Kline, Manager, Nuclear Engineering Department

M. Pearson, Manager, Quality Services Unit

M. Ackerman, Manager, Safety & Licensing Department

J. Macdonald, Manager, System and Performance Engineering

cc w/cv of Licensee Response Letter;

J. A. Hultz, Manager, Projects and Support, FirstEnergy

M. Clancy, Mayor, Shippingport, PA

l Commonwealth of Pennsylvania

State of Ohio Q(

State of West Virginia

9904220008 990414

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Distr;bution w/cv of Licensee Response Letter:

. Region l Docket Room (with concurrences)

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Nuclear Safety information Center (NSIC)

PUBLIC

NRC Resident inspector

H. Miller, RA/J. Wiggins, DRA

P. Eselgroth, DRP

N. Perry, DRP

C. O'Daniell, DRP

M. Tschiltz, OEDO

S. Bajwa, PD1-2, NRR

D. Collins, PM, NRR

R. Correia, NRR

DOCDESK

Inspection Program Branch, NRR (IPAS)

DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\bvreply.frm

To receive a cop r of this document. Indicate in the box: "C" = Copy without attachment / enclosure *E" = Cop, with attachment / enclosure "N" = No copy

OFFICE Rl/DRP. l& Rl/DRP C / l

NAME NPerry Tj WSchmidt LA>a

DATE 'i /s 1/99 MA 4 /99 ~

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OFFICIAL RECORD COPY

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gg Beaver Valley Power Station

Shippingport, PA 15077 0004

SUSHIL C. JAIN (412) 393-5512

Senior Vice President Fax (724) 643-8069

Nuclear Services

Nuclear Power Dmsion

March 29, 1999

L-99-053

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U. S. Nuclear Regulatory Commission  !

Attention: Document Control Desk

Washington, DC 20555-0001

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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 l

NRC Inspection Report 50-334/98-11,50-412/98-11

Reply to a Notice of Violation

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

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subject inspection report.

Please contact Mr. Mark S. Ackerman at (412) 393-5203 if there are questions

concerning this response.

Sincerely,

p.a. :

Sushil C. Jain

c: Mr. D. S. Collins, Project Manager

Mr. D. M. Kern, Sr. Resident Inspector

Mr. W. D. Lanning, Director, Division of Reactop Safety, Region I

Mr. H. J. Miller, NRC Region I Administrator /

DEllVERING

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DUQUESNE LIGHT COMPANY

Nuclear Power Division

Beaver Valley Power Station, Unit No. I and No. 2

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Repiv 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) j

Description of the Violation

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 l

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 serri-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

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.

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s Beaver Valley Power Station, Unit No. I and No. 2

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NRC Inspection Report 50-334/98-11,50-412/98-11

Reply to a Notice of Violation

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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 XVI" 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 determined

that 3 work orders may have installed wind sensors that had not been calibrated '

within the last 6 months as required by the technical 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 i

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calibration time requirement. The TSI responder believed that the issue was

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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 j

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

December 18,1998, that identified the sensor calibration issue and stated that a j

TSI had been previously submitted. The CR did not clearly document that the TSI i

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 j

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affected but it was not his responsibility to make the final determination.

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Throughout the communications there wr.s an underlying belief that the currently I

installed wind speed sensors were operable 1,ecause a recent design change ,

package (DCP 2166) had replaced the wind speed sensors and because calibration l

documentation associated with the work was checked by the Instrumentation and I

Controls (I&C) supervisor and confirmed to be current. The NSS did not probe

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the issue further or request to personally review calibration dates for verification.

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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 3

The Unit 1 NSS then contacted SLD to discuss immediate reportability. SLD in

turn 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 reportability

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 perfonn 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.

The CR response was completed on January 8,1999. The response 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 I

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 detect 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 independently address previous inoperability/

reportability.

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. l

On January 13,1999, the LER was presented to the Nuclear Safety Review Board

(NSRD). The required quorum 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

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NRC Inspection Report 50-334/98-11,50-412/98-11

Reply to a Notice of Violation

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specifications. Questions from the NRC senior resident inspector following the

meeting prompted the NSRB members to request additional investigation to

determine if Technical Specification 3.3.3.4 Action Statement "a" (prohibits gas I

decay tank discharges) or Action Statement "b" (requires a special report) had been

violated when there were less than the required number of operable meteorological

instruments.

The follow-up review by the SLD engineer identified seven instances during

which gas decay tank discharges were performed without the required number of

technical specification meteorological wind speed sensors being operable. At the

time of the 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 not been identified.

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The follow-up review also detected that sensor inoperability met requirements for l

submitting a special report to the NRC; however, no reports were submitted (again

due to the condition not being detected.)

LER l-98-029 was subsequently revised, reviewed by the NSRB, and submitted to

the NRC on January 18,1999.

On March 19,1999, a new condition report was written to document our discovery

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:

a) promptness ofidentification and threshold for initiating a CR

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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

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NRC Inspection Report 50-334/98-11,50-412/98-11

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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

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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 j

manager, I&C supervisor, I&C director, Maintenance manager) had attended I

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 threshold for initiating

a CR. In this case, the proper concern resolution path should have been the

condition report process, not the technical specification interpretation process.

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A contributing factor was the absence of clear direction in NPDAP 7.1 " Technical

Specification Control Program" for establishing appropriately prioritized due dates l

based on issue significance. The procedure did not require the Technical

Specification Interpretation (TSI) request initiator to immediately write a condition

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 this was a historical issue without the potential to impact current

operability. This belief was, in part,. because DCP 2166 had recently replaced the

meteorological tower wind speed sensors. Finally, there was a lack of

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Beaver Valley Power Station, Unit No. I and No. 2

NRC Inspection Repon 50-334/98-11,50-412/98-11

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accountability because of unclear system ownership and inadequate priority on the

meteorological tower because ofits perceived low safety significance.

B. Condition Recurrence

QSU identified the issue in a condition report on December 18,1999. Once

identified, the corrective action program failed to prevent recurrence, in part,

because the Nuclear Shift Supervisor (NSS) was comfortable with information

regarding DCP 2166. The NSS did not believe the condition repon 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 repons 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 repon investigation. The

condition report investigator missed information in the current calibration

documentation that should have caused him to detect that an installed sensor

(#414) calibration was nearing expiration.

C. Historical Operability and Reportability Reviews

The historical operability (and conesponding reportability) reviews were

inadequate because these responsibilities were not clearly delineated in station

procedures.

Corrective Actions Taken and Results Achieved

CR 990345 was written on February 16,1999, to document the overall condition

in the corrective action program 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 instrumentation is currently inoperable due to additional issues

discovered by the plant staff.

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Beaver Valley Power Station, Unit No. I and No. 2

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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 l

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

requirements.

2. A multi-discipline team review, under direction of the Sr. Vice

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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) threshold for writing condition reports, and,

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Beaver Valley Power Station, Unit No. I and No. 2

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c) thoroughness and completeness of condition report

evaluations and corrective actions.

This will be done, in part, by: j

a) analyzing Corrective Action Review Board (CARB) rejection

data  :

b) 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 I

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

f) conducting interviews with site personnel, assessing their

understanding of when to write condition reports and

sensitivity to technical specification compliance

g) conducting interviews 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 j

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i) providing causes, corrective actions, and recommendations to

management for final closure of this issue  ;

3. NPDAP 5.2 " Initiation of Condition Reports" will be revised to more

clearly communicate management expectations for when it is

appropriate to initiate a condition report rather than using other I

mechanisms (e.g., a TSI request) to address an issue.

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4. NPDAP 7.1 " Technical, Specification Control Program" will be

revised to require Operations to track technical specification

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interpretation requests and establish requirements for prioritization

and response times. As an added precaution, the revision will

require a condition 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 repres':ntative and the associated condition l

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 Perfonnance 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.

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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. )

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13. Auditors from quality services will be provided technical I

specification training.

14. A review will be performed to identify additional groups to receive

technical specification training.

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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.

Date When Full Compliance Will Be Achieved

The original issue of the meteorological tower wind speed instmmentation

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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