IR 05000334/1998010

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Insp Repts 50-334/98-10 & 50-412/98-10 on 981115-1226.No Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support.Matl Condition of Fire Protection Equipment Installed in Plant Was Excellent
ML20199F204
Person / Time
Site: Beaver Valley
Issue date: 01/13/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20199F199 List:
References
50-334-98-10, 50-412-98-10, NUDOCS 9901210248
Download: ML20199F204 (33)


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' i U. S. NUCLEAR REGULATORY COMMISSION i

REGION I

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License No DPR-66, NPF-73  !

Report No /98-10,50-412/98-10 Docket No ,50-412 Licensee: Duquesne Light Company Post Office Box 4 '

Shippingport, PA 15077

I Facility: Beaver Valley Power Station, Units 1 and 2 l l

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i inspection Period: November 15,1998 through December 26,1998 Inspectors: D. Kern, Senior Resident inspector G. Dentel, Resident inspector G. Wertz, Resident inspector L. Peluso, Radiation Physicist L. Eckert, Radiation Specialist R. Fuhrmeister, Senior Fire Protection Specialist Approved by: P. Eselgroth, Chief Reactor Projects Branch 7

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l EXECUTIVE SUMMARY l

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l Beaver Valley Power Station, Units 1 & 2 NRC Inspection Report 50-334/98-10 & 50-412/98-10 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6-week period of resident inspection; in addition, it includes the results of announced inspections by regional radiation protection, environmental monitoring, and fire protection specialist j Operations

On November 19, a containment entry team successfully stopped a secondary side leak of the "B" steam generator blowdown sample line. The troubleshooting plan !

was well developed and executed. The prejob and containment entry briefings were very detailed and included lessons learned from previous containment entrie (Section 01.2)

Operators performed the primary component cooling water pump surveillance test accurately and in conformance with procedures. Due to high pump vibrations, the l procedure could not be completed satisfactorily. Operations exited the procedure and restored the system correctly. (Section 02.2)

  • Operators were alert and demonstrated questioning attitudes during routine plant activities. Careful scrutiny of planned work activities prior to authorization precluded conditions not permitted by technical specifications and potential reactor plant transients. Discrepancies were promptly acted on and entered into the station's corrective action program. (Section 04.1)

Maintenance

  • Six routine rnaintenance activities were performed safely and in accordance with proper procedures. Peer checking, supervisor and contractor oversight, and communications with control room operators were good. Improvements were noted in minimization of Limiting Condition of Operation durations. (Section M1.1)
  • Four surveillance tests were performed safely and in accordance with proper procedures. Good communication was observed. (Section M1.2)
  • On two occasions, poor work planning, including inadequate identification of clearance boundaries, posed challenges to the operations staff. The planning deficiencies could have resulted in reactor plant transients and conditions not permitted by technical specifications. (Section 04.1)

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  • In response to a previous NRC violation, the licensee took comprehensive actions to ensure the appropriate level of detail was specified in maintenance work requests ii

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l Enclosure 1 l and that controls were established for supplemental work instructions. Corrective actions were appropriately irnplemented and effective. Guidance for minor changes to maintenance work requests was being handled appropriately through the

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corrective action program. (Section M8.2)

Plant Support

  • ' Overall, the licensee effectively maintained and implemented a radiological environmental monitoring program in accordance with regulatory requirement (Section R1.1)

The licensee effectively maintained and implemented a meteorological monitoring program in accordance with regulatory requirements. (Section R1.2)

  • Audits were of sufficient depth to assess the implementation of the radiological environmental monitoring program and meteorological monitoring program. (Section R7.1)
  • The environmentallaboratory continued to implement effective Quality Assurance and Quality Control programs for the radiological environmental monitoring program samples, and continued to provide effective validation of analytical results. The programs were capable of ensuring independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample media. (Section R7.2)
  • Housekeeping, control of combustible materials, and the material condition of the fire protection equipment installed in the plants was excellent. (Section F2.1)
  • The Quality Services Unit (OSU) has done an excellent job identifying areas for improvement in the fire protection program through their program audits. The QSU i is ahead of the industry in that they started reviewing post-fire safe shutdown ,

procedures and methodologies in 1995. (Section F7.1) i

  • Corrective actions for some fire protection program audit identified deficiencies (particularly safe shutdown analysis actions not being properly implemented in the post-fire shutdown procedures) had not been completed for a significant time period. The Nuclear Engineering Department review of post-fire shutdown procedures against the fire protection design basis had not been started at the end of the inspection, nor had the plan for conducting the review been finalized and approved. (Section F7.1)

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Enclosure 1

  • An electrical engineer identified a deficiency in the fire protection safe shutdown analysis which affected a boration flowpath. Corrective actions were appropriat (Section F8.1)

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TABLE OF CONTENTS Page EXECUTIVE SUMMARY .... .. ..................... . ....... .. ii .

TABLE OF CONTENTS . . . . ........... ......... .... ... ....... . v 1. Operations ............... ................. ........... .. 1 O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . ... ...... 1 01.1 General Comments (71707) .................... . . .. 1 01.2 Containment Leak identification and Isolation (Unit 1) . ..... 1 02 Operational Status of Facilities and Equipment ...... ............ 2 02.1 Engineered Safety Feature System Walkdowns (71707) . . . . . . . . 2 02.2 Unit 2 Primary Component Cooling Water Pump "A" Test . . . . . . . 2 ,

04 Operator Knowledge and Performance . ......... ............. 3 04.1 Operator Awareness During Routine Activities .... ...... 3 08 Miscellaneous Operations issues (90712) . . . . . . . ............. 4 08.1 (Closed) Licensee Event Report (LER) 50-334/98-28 ..... .. . 4 ll. M ainte na n ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ... ........ 5 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . .... . 5 M 1.1 Routine Maintenance Observations ..... .. ............ 5 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 6 M8 Miscellaneous Maintenance issues . . . . . . . . . . . ................ 6 M8.1 (Closed) Violation 50-334(412)/97-05-05 . . . . . . . . . . . . . . . . . . 6 M8.2 (Closed) Violation 50-412/97-11 -08 . . . . . . . . . . .......... 7 lli . Eng ineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................... 9 E8 Miscellaneous Engineering issues (37551,92903) . ........... 9 E (Closed) Violation EA 50-412/97-517(01013)...... ........ 9 E8.2 (Closed) Violation 50-3 3 4/9 8-8 0-0 2 . . . . . . . . . . . . . . . . . . . . . 10 ,

l IV. Pl a n t S u p po rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 10 :

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R1 Radiological Protection and Chemistry (PhC) Controls .... ....... 10 R1.1 Implementation of the Radiological Environmental Monitoring Program l ( R E M P) . . . . . . . . . . . . . . . . . ...... . ........... 10 i R1.2 Meteorological Monitoring Program (MMP) ... ..... ...... 11 R7 Quality Assurance in Radiological Protection and Chemistry Activities . . 12 R7.1 Quality Assurance Audit Program ..... ................ 12 R7.2 Quality Assurance of Analytical Measurements .... . ..... 12 R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . ...... ........... 13 R (Closed) Violation 50-334/97-08-05...... .. ..... . ... 13

R8.2 (Closed) Inspector Follow-up item (IFI) 50-334/97-08-06 ...... 13

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F2 Status of Fire Protection Facilities and Equipment ................ 13 F Facility Tours . . . . . . . . . . ............ ............. 13 F2.2 Fire Barrier Penetration Seals . . . . . . ... . . .. 14 F7 Quality Assurance in Fire Protection Activities ...... ........... 15 l F Fire Protection Program Audits ......... . ............ 15 v

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l F8 Miscellaneous Fire Protection issues ............... .... .... 17 F (Closed) LER 50-412 /9 8-0 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 V. M a n a g em e nt M e e tin g s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 X1 Exit Meeting Sum m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 X2 Duquesne Light Company Organization Changes . . . . . . . . . . . . . . . . . 18 X3 NRC Organization Change s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 X4 NRC Management Meetings ............................... 18 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 LI ST O F A C RO NYM S U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 vi

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I Report Details Summarv of Plant Status Both units began this inspection period at 100 percent power and remained at full power through the perio l. Operations 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 and safety-conscious; specific events and noteworthy observations are detailed in the sections belo .2 Containment Leak identification and Isolation (Unit 1) Inspection Scooe (71707)

in response to an increase in the containment sump pumpout rate on November 10, operations personnel, in conjunction with the system engineer, developed and implemented a troubleshooting plan. The inspectors reviewed the troubleshooting plan and containment entry procedure and attended the prejob and containment entry briefings to evaluate resolution of the leakage issu Observations and Findinos On November 10, operators noted an increase in the containment sump pumpout rate. The rate increased from approximately 1.5 gallons per hour (gph) to 8 gp Sampling of the fluid indicated that it was secondary plant (non Reactor Coolant System) leakage based on low radioactivity, absence of boron, and pH leve Additionally, no inventory loss was experienced on the primary side. On November 17, after a few days delay to resolve containment airlock system problems, a containment entry was performed which identified leakage emanating from a bundle of sample lines in the "B" Steam Generator (SG) cubicl The system engineer and an Assistant Nuclear Shift Supervisor developed a troubleshooting plan to isolate the 3/8" "B" SG sample line. The inspectors reviewed the plan and determined that it was logical and well-controlled. The inspectors attended the prejob and containment entry briefing in the Radiological Operations Center (ROC). The briefing was performed in accordance with a new revision to Nuclear Power Division Administration Manual (NPDAP) 3.3, " Reactor Containment Entries", Rev. 8. The briefing was very detailed as the new procedural requirements and changes were reviewed. Personnel safety and radiation exposure minimization concepts were stressed in the briefing discussions. Lessons learned from previous containment entries included identification of low radiation dose f

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waiting zones and use of knee pads for personnel protection while maneuveringwith a bio-pak around the reactor coolant pump moto On November 19, a containment entry team successfully stopped the "B" SG blowdown sample line leak by isolation of the blowdown lin Conclusions On November 19, a containment entry team successfully stopped a secondary side leak of the "B" steam generator blowdown sample line. The troubleshooting plan was well developed and executed. The prejob and containment entry briefings were very detailed and included lessons learned from previous containment entrie l O2 Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature System Walkdowns (71707)

The inspectors walked down accessible portions of the following engineered safety l feature systems:

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  • Unit 1 Quench Spray
  • Unit 1 Recirculation Spray ,

Equipment operability, material condition, and housekeeping were acceptabl Several minor housekeeping items and material deficiencies were identified to the Nuclear Shift Supervisor and were correcte .2 Unit 2 Primary Component Coolina Water Pumo "A" Test j Inspection Scope (61726)

The inspectors observed the surveillance test 20ST-15.1," Primary Component Cooling Water Pump [2CCP'P21 A] Test," Rev. 21 which was performed to establish operability of the "A" primary component cooling water pump. The inspectors focused on procedural compliance and pump performance assessmen Observations and Findinas The pump (2CCP'21 A) had been overhauled and a new pump curve needed to be established for pump performance monitoring. The operators performed the test ,

accurately and in conformance with the procedure. The test was appropriately l stopped by the condition monitoring supervisor due to high pump outboard bearing vibrations. The operators exited the procedure and restored the system alignment l correctly. While observing the surveillance, the inspectors noted the order in which l operators established initial conditions for the test resulted in about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of i unnecessary pump unavailability, and increased Technical Specification (TS) Limiting '

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Condition of Operation duration. The inspectors discussed this with the Assistant l

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Nuclear Shif t Supervisor, who reviewed the issue with the operating crew to improve future performanc Conclusions Operators performed the primary component cooling water pump surveillance test accurately and in conformance with procedures. Due to high pump vibrations, the procedure could not be completed satisfactorily. Operations exited the procedure and restored the system correctly.

04 Operator Knowledge and Performance 04.1 Operator Awareness Durina Routine Activities Inspection Scope (71707)

The inspectors observed operators during routine activities and interviewed operators concerning daily plant observations to determine whether operators were alert and properly evaluating plant condition Observations and Findinas Control room operators were consistently aware of existing control room alarms, their cause, and corrective actions being taken. The deficiency tags posted in the auxiliary and turbine buildings indicated that tour operators were properly scrutinizing material conditions and had a low threshold for identifying deficiencie Unexpected indications or observations were properly questioned. The following examples demonstrate improved alertness and questioning attitudes by the operations staff. Upon identification, each issue was properly communicated to the Nuclear Shift Supervisor and a condition report was initiated for problem resolution and extent of condition reviews as appropriat *

On November 30, while restoring the Unit 2 component cooling water pump 2CCP-P21 A following maintenance, operators questioned whether the normal vent path configuration was adequate. Subsequent ultrasonic testing confirmed that a sizeable air void remained present following completion of the fill and vent procedure. The concern for potential water hammer conditions was properly resolved and a revised fill and vent procedure was developed for future us *

On December 4, the Unit 2 auxiliary building tour operator observed that suction piping spool pieces for each of the three charging pumps were missing bolting wedges between the flange and nut. Over time, the resulting stress had bent several of the bolts as much as 15 degrees. The issue was properly evaluated by engineers, bolts were replaced, and wedges installe Further inspections identified similar conditions on the auxiliary feedwater system, which were promptly correcte _ . _ ._ _ _ . _ . . _ _ _ ._ . . _ _ _ _ _ _ _ _ _ . - ______

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While preparing to post a clearance on a set of main condenser steam jet air l ejectors (SJAE) for nozzle replacement, Unit 2 operators identified that plant l procedures did not address restoring the SJAE from this plant configuration.

l Work planning was deficient. This activity had the potential to cause a I turbine trip if the SJAE were not properly restored. The job was halted until l appropriate procedural guidance was develope I

  • On December 22, the Unit 2 reactor operator observed that volume control l i tank (VCT) level was decreasing at a rate greater than expected, given the

! existing reactor coolant system leak rate. Operators confirmed that the l chemist had begun his primary coolant sample purge prior to notifying the control room. The operator was alert in identifying this small change in VCT ,

l leve * On December 23, while preparing to post a clearance on the control room i emergency bottled air pressurization system (CREBAPS), operators identified that a clearance isolation boundary valve (1VS-19) leaked by. Although a '

deficiency tag was hung, indicating the degraded condition, the work l package relied on this valve for isolation. If the planned work activity had i

, been performed using this clearance, a second set of CREBAPS air bottles I

would have depressurized resulting in an unplanned dual unit technical specification (TS) 3.0.3 entry. The job was halted and the work package was revise Conclusions Operators were alert and demonstrated questioning attitudes during routine plant activities. On two occasions, poor work planning, including inadequate identification of clearance boundaries, posed challenges to the operations staf Careful scrutiny of planned work activities prior to authorization precluded conditions not permitted by technical specifications and potential reactor plant transients. Discrepancies were promptly acted on and entered into the station's corrective action progra Miscellaneous Operations issues (90712)

08.1 (Closed) Licensee Event Report (LER) 50-334/98-28: Automatic Reactor Trip On 'A'  ;

Steam Generator Low Level Coincident With Steam Flow / Feed Flow Mismatch  !

Signal From Manually Tripped Transmitter Bistables of F-MS-475 This event was fully documented in NRC Inspection Report 50-334(412)/98-0 The LER accurately described the event causal f actors and corrective actions.

l Through inoffice review, the inspectors confirmed that the corrective actions were l appropriate and were complete.

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i 11. Maintenance '

M1 Conduct of Maintenance M 1.1 Routine Maintenance Observations 1 I

Inspection Scope (62707) l The inspectors observed selected maintenance activities on important systems and l components. The maintenance work requests (MWRs), maintenance surveillance !

procedures (MSPs) and maintenance planning scheduling (MPS) activities observed and reviewed are listed belo * 1 MSP-24.01 -1 "1FWS-L474, Loop 1 Narrow Range Steam Generator Water Level Channel i Test," Re * MWR 075495 Leak Repair of FW-302 (Unit 1)

  • 2MSP-37.04-E "2P 480 Volt Emergency Bus Degraded Voltage Relays 27-RP200AB and 27-RP200BC 28 Day Functional Test," Rev.11 e 2MSP-6.39-1 " Reactor Coolant Temperature Loop 2RCS-T422 Delta T-Tavg," Rev. 9
  • MWR 075981 Check Calibration of T-hot & T-cold NRA Cards from the Terminal Blocks instead of the Test Jacks (Unit 2) Observations and Findinos The inspectors determined that the work performed under these activities was professional and thorough. On the steam generator water level channel test, the inspectors observed good peer checking by knowledgeable and skilled technician On the leak repair work, the job was performed with good safety emphasis and contractor control and oversight. The Project Coordinator made a good decision to stop the work and contact engineering when the required clearance between the leak repair clamp and the piping support was not achieved. The service water pump strainer preventive maintenance was completed ahead of schedule thereby minimizing the limiting condition of operation (LCO) duration. The degraded voltage relay test was conducted properly in accordance with procedures. The inspectors observed good supervisor oversight during maintenance work associated with the reactor coolant temperature loo Conclusions Routine maintenance activities were performed safely and in accordance with proper procedures. Peer checking, supervisor and contractor oversight, and communications with control room operators were good. Improvements were noted in minimization of LCO duration . . ~ - -- .= -=_ _ _ _ . _

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I Inspection Scope (61726)

The inspectors observed selected surveillance tests. Operating surveillance tests (OSTs) reviewed and observed by the inspectors are listed below.

l * 10ST-3 " Diesel Generator No.1 Monthly Test," Rev. 20

  • 20ST- " Centrifugal Charging Pump [2CHS * P21 C)," Rev.13 J
  • 20ST-1 " Quench Spray Pump [2OSS*P21B] Test," Rev.12 l l Observations and Findinas l The surveillance tests were performed safely and in accordance with proper procedures. Minor deficiencies were identified and entered in the maintenance work process. The Unit 1 diesel generator test was performed professionally and thoroughly. When a minor fuel oil leak developed on the fuel oil strainer, the Assistant Nuclear Shift Supervisor promptly inspected it and contacted maintenance. The inspectors observed good communication between the control room operator and the nuclear operator in the diesel cubicl Conclusions Surveillance tests were performed safely and in accordance with proper procedure Good communication was observe M8 Miscellaneous Maintenance issues M8.1 (Closed) Violation 50-334(412)/97-05-05: Inadequate Control of Troubleshooting Activities Leads to ESF Actuatio I Insoection Scope (92902)

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The inspectors reviewed the corrective actions to the violation which included a review of the new governing procedure for troubleshooting, NPDAP 8.34, " Control )

of Troubleshooting Activities," Rev.1, the maintenance department self  !

assessment, and the quality assurance assessment of troubleshooting. The inspectors examined over 70 MWRs to determine if troubleshooting was appropriately identified and controlled. Fourteen troubleshooting plans were evaluated for risk categorization, definition of boundaries, and level of review Various maintenance personnel were interviewe Observations and Findinas Maintenance personnel developed a troubleshooting procedure in response to the violation. The inspectors reviewed the procedure and observed that the procedure provided: 1) a method for categorization of risk; 2) appropriate supervisor / management approval requirements; 3) a good general method for

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l developing the troubleshooting plan; 4) emphasis on communication and especially l information being transferred to the operating crew; 5) pre-job briefing requirements; and 6) definition of troubleshooting boundarie The inspectors reviewed troubleshooting plans for fourteen MWRs. The troubleshooting plans were categorized for risk appropriately, boundaries were well defined, and the work stayed within the evaluated boundaries. The plans were properly reviewed by the appropriate level of management. Based on the procedure l revision and troubleshooting plan development, the inspectors determined the causes of the violation were comprehensively addresse l The maintenance self assessment and the quality assurance audit were detailed and '

self critical. Severalissues were identified and corrected. One common problem was that troubleshooting was not properly identified and implemented using the troubleshooting procedure in some maintenance activities. The inspectors !

independent review of 70 MWRs also identified that the troubleshooting procedure was not consistently applied to lower risk significant maintenance activitie Corrective actions to the self assessment and quality assurance audit finding did not address the deficiency. The inspectors determined troubleshooting was not well defined in the maintenance procedure The determination of whether an item is troubleshooting is based on the work planner's assessment. In discussions with planners, the inspectors were informed that no guidance exists for defining troubleshooting. The safety significance of the items identified, for which a troubleshooting plan was not used, was minimal. The inspectors discussed the issue of poor corrective actions to the identified finding and the lack of a definition for troubleshooting with maintenance personnel. The work planning manager stated that a clear definition of troubleshooting would be developed and communicated to work planners and the maintenance supervisor This action was being tracked unaer the maintenance department commitment tracking system, Conclusions The corrective actions in response to the violation on control of troubleshooting, were effective in addressing the root cause of the violation. Troubleshooting activities in the field were properly controlled. Continued improvements were needed in troubleshooting plan use for lower risk significant item M8.2 (Closed) Violation 50-412/97-11-08: Inadequate Work Instructions and Improper Control of Supplemental Work Instructions in Maintenance Work Request (MWR) Insoection Scope The inspectors reviewed the response to the violation concentrating on the corrective actions. The inspectors verified that the corrective actions were completed by reviewing the procedure changes that were implemented, the training that was provided to the planners including a review of the lesson plan, and the

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effectiveness review and self-assessment that were performed. The inspectors interviewed a planner, a lead planner, and the Director of Work Planning to validate the corrective actions. Fif ty safety related MWR's were also reviewed for technical content and consistenc Observations and Findinas inadequate repair activities on the Unit 2 station battery 2-1 resulted in a high impedance location within the battery which had the potential to cause significant battery damage during a full capacity discharge test on January 31,1997. The reasons for the inadequate repair activities were determined to be the lack of a clear standard for work package content and inadequate control of supplemental work instructions. Additionally, the licensee performed work outside the scope of the work instruction Revisions to the Work Planner Desktop Guide, Nuclear Power Department Administrative Procedure (NPDAP) 7.5, " Processing a Maintenance Work Request,"

Rev.11, and Station Battery Corrective Maintenance Procedure "1/2 CMP-398YS/DC-BATTERY-1E,"Rev.5 were reviewed by the inspectors. The battery procedure changes incorporated very detailed controls for cell removal and installation. The Work Planner Desktop Guide added comprehensive information delineating the level of detail in work packages and implemented a lead planner review of planned MWR' NPDAP 7.5 added guidance for changing work instructions in the field and the use of supplemental work instructions. The inspectors noted that Work Group Supervisors were authorized to make " minor changes" to written work instructions in the field. However, no guidance existed for defining " minor changes." Unrelated to this violation, condition report (CR) 982083 had been initiated on November 17 to address recent discrepancies between MWR instructions and actual work performed in the field The Director of Work Planning and Director of instrumentation and Controlinformed the inspectors that the corrective actions from CR 982083 willinclude guidance on minor changes to MWR' Additional corrective actions included comprehensive training for the planners which provided sufficient instruction for delineating the required level of detail in MWR planning. The inspectors' interviews with the planners validated their understanding of the new requirements. The inspectors reviewed 50 completed safety related MWR's and did not identify any deficiencies associated with the level of detail or supplemental work instructions. The licensee performed a comprehensive self-assessment which identified 27 recommendations for improvements in maintenance pre-planning and implementation. These recommendations are captured in the maintenance commitment tracking system and are currently under management review. The effectiveness review identified a deficiency in the work package feedback forms. The feedback forms are being revised and another effectiveness review has been scheduled to re-evaluate the data next year.

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l 9 Conclusions In response to an NRC violation, the licensee took comprehensive actions to ensure that the appropriate level of detail was specified in maintenance work requests and that controls were established for supplemental work instructions. Corrective actions were appropriately implemented and effective. Guidance for minor changes to maintenance work requests was being handled appropriately through the corrective action progra Ill. Enaineerina E8 Miscellaneous Engineering issues (37551,92903)

E (Closed) Violation EA 50-412/97-517(01013): Failure to Prevent Gas Binding of High Head Safety injection Pumps Inspection Scoce (92903)

The inspectors reviewed the response to the violation, examined a sample of corrective actions, and evaluated the long term effectiveness of the corrective actions, Observations and Findinas Between 1988 and September 12,1997, Unit 1 and 2 experienced repeated gas accumulation and gas binding of the high head safety injection (HHSI) pumps. The failure to take adequate corrective actions resulted in the violation issued on January 6,1998. The licensee determined the root causes to be design inadequacies and inadequate corrective actions including inadequate questioning attitudes toward past events. The corrective actions teken included: 1) the formation of a multi-discipline analysis team (MDAT) to . valuate the issue and perform an extent of condition review; 2) the installation of twenty two stage flow restricting orifices in the Unit 1 and 2 HHSI pump minimum flow recirculation lines; l 3) establishment of an acceptable gas void fraction limit; 4) establishment of l procedures for venting and monitoring gas accumulation in the HHSIlines; 5) )

formalization of the MDAT and a critique process; and 6) safety culture training for )

operations and maintenance personnelin addition to engineering personne The corrective actions were comprehensive and addressed the root causes of the violation. The new restricting orifices have eliminated the most significant source of hydrogen gas in the Unit 1 and 2 HHSI systems as evidenced by periodic ultrasonic testing. The procedures for monitoring and venting gas accumulation are

! appropriately controlled to ensure proper operability evaluation of the pumps (see i NRC Inspection Report 50-334(412)/98-03for more information on venting practices). The MDAT and critique process were formalized as NPDAP 5.10,

" Conduct of Critiques and Multi-Discipline Analysis Team investigations." The inspectors have observed successfulimplementation of this procedure during the i

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Unit 2 quench spray water hammer event (see NRC Inspection Report 50-334(412)/98-03). The safety culture training assisted in improving the questioning attitude of engineering personnel. Training for maintenance and operation personnel continues. Overall, the corrective actions have been effective, Conclusions Corrective actions in response to the violation on f ailure to prevent gas binding of the high head safety injection pumps were comprehensive and have successfully eliminated the .most significant source of hydrogen gas in the syste E8.2 (Closed) Violation 50-334/98-80-02: Failure To Promptly Correct Excessive Leakage Of Residual Heat Valve MOV-RH-75 The inspectors identified in NRC inspection Report 98-80 that excessive seat leakage of the Residual Heat (RH) flow control valve MOV-RH-758 was not corrected in a timely manner. In response, the licensee performed an event critique which reviewed the problem history and initiated troubleshoot:ng to determine if adjustment of the actuator position could reduce the seat leakage to an acceptable limit. The test resulted in no improvement in the valve seat leakage. The licensee has decided to replace the valve during the upcoming Unit 1 refueling outage, expected to occur in March,2000. The inspectors discussed the valve replacement planning with outage management and the RH system engineer and determined that it was adequate. An extent of condition review was also performed to identify other cases where non-throttle type valves were being used in a throttle-type capacity in the plant. The inspectors determined that the extent of condition review was technically soun ,

IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Implementation of the Radioloaical Environmental Monitorina Proaram (REMP) Inspection Scoce (84750)

The following areas of the REMP were assessed and reviewed: (1) selected sampling locations and stations; (2) selected REMP procedures; (3) 1998 environmental sample analytical results; (4) Land Use Census results; and (5) the Beaver Valley Power Station 1997 Annual REMP repor Observations and Findinas

! Several environmental monitoring stations were examined. The air samplers, water

compositors, and thermoluminescent dosimeters (TLDs) were placed at the locations designated in the Offsite Dose Calculation Manual (ODCM). The air sampling
equipment and water compositors were operable during 1998, as evidenced by the i

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sample logs and sample analysis results. Milk and food products were collected from the locations specified in the ODCM.

l The analytical results of the environmental samples were reviewed from January to l October,1998. Analyses were performed by the licensee's Environmental l Radiological Laboratory. The data indicate that the environmental samples were l collected and analyzed at the frequencies required in the ODCM. The licensee met the environmentallower limits of detection (LLD).

The annual Land Use Census was performed in 1997 and 1998, during the growing season, as required by the ODCM. A thorough land use survey, including a

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resident, garden, and milk animal census was performed. No significant changes l were made to the REMP program as a result of the censu The 1997 Annual Radiological Environmental Monitoring Report included results of the environmental monitoring program, program changes, land use census, and interlaboratory comparison program, as required by TS. The reports provided a comprehensive summary of the results of the REMP around the site and met TS reporting requirement Conclusion

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Overall, the licensee effectively maintained and implemented a radiological

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environmental monitoring program in accordance with regulatory requirements, i

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R1.2 Meteoroloaical Monitorina Proaram (MMP) Insoection Scope (84750)

i The following areas of the MMP were assessed and reviewed: (1) channel

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calibration procedures and results; (2) site operations logs and condition reports;

(3) channel checks and functional checks; and (4) maintenance records.

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' Observations and Findinas The calibration results were within the acceptance criteria. The calibrations, channel checks, and functional checks were conducted as required by TS. The meteorologicalinstrumentation on the tower and the readout devices located in the l

control room, the technical support center, and equipment room at the base of the l tower were operable. The licensee completed a modification to upgrade the transmitters (wind speed and direction sensors, and the temperature sensors) and the recorder Conclusion The licensee effectively maintained and implemented a meteorological monitoring

program in accordance with regulatory requirements.

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R7 Quality Assurance in Radiological Protection and Chemistry Activities l

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R7.1 Quality Assurance Audit Proaram l Inspection Scope (84750)

The licensee's audit of the REMP and MMP was evaluated through a review of the quality assurance audit reports for 1997 and 199 l

, Observations and Conclusions '

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The audits were detailed in scope and effectively assessed the REMP and MM Performance of the audits was good, in that specific REMP and MMP activities were directly observed and timely feedback regarding performance of the activity was provided. Condition reports, observations, and recommendations were appropriate to provide guidance and ensure quality of the program. Responses were thoroughly investigated and timely. All 1997 audit condition reports were tracked and close The 1998 audit condition reports were recently submitted into the corrective action process. One audit finding identified a potential discrepancy between the methods used to perform wind speed sensor channel calibrations and the TS 3.3. surveillance requirement. The inspectors verified that this issue had been entered into the corrective action process (CR 98-2144)with an appropriate schedule for resolutio Conclusion The audits provided an effective assessment of the REMP and MM R7.2 Quality Assurance of Analvtical Measurements Inspection Scope (84750)

The quality assurance / quality control programs of the contract laboratory for 1998, including the Interlaboratory Comparison (cross-check) Program were reviewe Observations and Findinas The quality assurance program consisted of measurements of blind duplicate, spike, and split samples. The laboratory continued to participate in the EPA Cross-Check Program and the Interlaboratory Comparison Program provided by a vendor laboratory (Analytics, Inc.). The results of these programs were within the established acceptance criteri Conclusion The environmentallaboratory continued to implement effective Quality Assurance and Quality Control programs for the radiological environmental monitoring program

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samples, and continued to provide effective validation of analytical resultr. The I programs were capable of ensuring independent checks on the precisica and (

accuracy of the measurements of radioactive materials in environrr. ental sarnple medi R8 Miscellaneous RP&C lssues R (Closed) Violation 50-334/97-08-05: Failure to Establish Adequate Radiation Monitoring System (RMS) Calibration Procedures Licensee procedural guidance did not contain adequate guidance for establishing optimum RMS operating high voltage. The inspectors held a October 30,1998 telephone discussion with the Health Physics Protection Manager. Inspection activities were conducted in the Region I office. The following licensee procedures were reviewe * Radiological Instrument Procedure 2.29, "RMS Detector Response," Rev. 2

  • Radiological Instrument Procedure 2.35, "RMS/DRMS Plateau Evaluations "

Re Review of the procedures indicated that specific guidance had been included to established optimum operating high voltage for RMS during calibrations. NRC Inspection Report 50 334(412)/98-02 described other corrective actions to address this violation. In conclusion, the corrective actions appropriately addressed this issu R8.2 (Closed) Inspector Follow-up Item (IFI) 50-334/97-08-06 During NRC Inspection 50-334/97-08,the inspector questioned the licensee as to whether they could provide any information pertaining to new/ refurbished detector failures so as to explore whether there were any 10 CFR 21 implications with respect to Violation 50-334/97-08-05. During the October 30,1998 telephone call, the Health Physics Manager informed the inspector that there was no readily retrievable data pertaining to new or refurbished detector failures. No issue pertaining to 10 CFR 21 was identified because the suspect RMS was not used in a safety-related applicatio F2 Status of Fire Protection Facilities and Equipment F Facility Tours Insoection Scoce (64704)

The inspectors toured the plant, in concert with the respective fire protection system engineers, to evaluate housekeeping, combustible material control, and the material condition of the installed fire protection equipment.

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b. Observations and Findinas

! During tours of the facility, the inspectors noted that there were no accumulations

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of transient combustible materials outside of the designated storage cages. The inspectors also noted that the Unit 1 storage cages were located in areas protected by automatic suppression system Sprinkler system discharge heads were unobstructed, with one exception. The inspectors found one damaged sprinkler head, and one obstructed sprinkler head, above the catwalk on the south side of the lower level of the Unit 1 turbine building. There were no combustible materials, either transient or permanently installed, in the area. The Unit 1 fire protection system engineer made note of the deficiency for correction at the next opportunity. Deluge valves and sprinkler a! arm l check valves were in good condition and appeared well-maintaine I l

Since the last inspection, in August 1996, the plant has located and repaired a I number of leaks in the fire main system. The fire protection system engineer 4 informed the inspectors that this br.s resulted in improved performence of the hydro pneumatic tank which maintains system pressure. The facility is planning to proceed with a modification to provide a cross-tie between the filtered water system and the fire main system in the Unit 1 turbine building to provide a backup means of pressure maintenance for the fire mains. The fire pumps, hydro pneumatic tank, keepfill pump, and compressor in the intake structure were in a good state of preservatio c. Conclusions )

Housekeeping, control of combustible materials, and the material condition of the fire protection equipment in the plants were excellen i F2.2 Fire Barrier Penetration Seals i Is.soection Scoce (64704)

During f acility tours, the inspectors observed the condition of the penetration seals in various fire barriers in the plants. One seal was selected, at random, for detailed revie Observations and Findinas

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The inspectors did not observe any deteriorated fire barrier penetration seals during the plant tours. A penetration sealin the Unit 1 West Cable Vault was selected for detailed revie Penetration seal WCV-735-114is a silicone foam seal of an empty sleeve through the wall. The seal contains approximately two inches depth of ceramic fiber damming on both sides. This results in approximately a ten inch depth of foam in

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the penetration. The seal is shown on Drawing HK-119-33-CV1, Rev.1 (DLC Do File No. 8700-1.35-171)as a four inch sleeve sealed with silicone foa l

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Promatec Drawing B-465, Sheet 1 of 2, shows this type of seal as a Typical ES-1, using a ten inch depth of foam and one inch of damming. Promatec Drawing B-465, Sheet 2 of 2 shows ES-1 seals as 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated, and lists an American Nuclear insurers (ANI) Index 3 reference. The inspectors confirmed that the installed sealis smaller than the maximum area qualified for fire exposur Promatec document, "American Nuclear insurers (ANI) Acceptances," contains acceptance forms for fire endurance tests for penetration seals and protective envelopes, index #3, CTP-1001 A, shows that the real design successfully w thstood a 3-hour fire exposure and subsequent hose test on May 20,198 Conclusions l The fire barrier penetration seals in both units were in good condition. The fire

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barrier penetration seal reviewed conformed to the design configuration tha had been tested for a 3-hour fire rating.

F7 Quality Assurance in Fira Protection Activities ,

l F7.1 Fire Protection Proaram Audits I inspection Scope (64704)

The inspectors reviewed audits of the fire protection program conducted since the last inspection, and condition reports relating to discrepancies between the post-fire shutdown procedures and safe shutdown reports and analyse Observations and Findinas Since the last inspection, conducted in August of 1996, Duquesne Light Company (DLC) has performed two audits of the Fire Protection Program. The audits were performed in accordance with Section IV.0, " Program Review," of Nuclear Power Division Administrative Procedure (NPDAP) 3.5, " Fire Protection." The current revision of NPDAP 3.5 is Rev. 7, with an effective date of July 1,199 The 1997 program audit, BV-C-97-06, resulted in the issuance of eleven condition reports (CRs), including the identification of recurrent deficiencies in post-fire safe shutdown procedures. The auditors concluded that overall, regulatory requirements had been met, and implementation of the Fire Protection Progra n had been effective. The audit report contained several recommendations, including the development of a listing of the National Fire Protection Association (NFPA) code commitments and deviations for the fire suppression and detection systems installed at the statio The 1998 program audit, BV-C-98-09, resulted in the issuance of eighteen CR The audit report also contained six recommendations, and identified two program

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strengths. The audit findings were significant in that they found that the post-fire shutdown procedures were not adequate. The auditors concluded that overall, the Fire Protection Program at the Beaver Valley Power Station is not fully effectiv The audit report stated "This is the fourth consecutive QSU e.udit that identified discrepancies concerning the procedures used for a fire induced shutdown..."

The inspectors discussed the history of the post-fire shutdown procedure audit findings with the Quality Services Unit (OSU) auditor who led the audits. The deficiency reports (DRs) and problem reports (prs) which resulted from the 1995 and 1996 audits documented instances where the post-fire operating procedures did not properly implement required actions developed in the safe shutdown analysi Whiie a specific deficiency was not identified more than once, each audit found similar problems, that is, post-fire shutdown procedures did not properly implement actions specified in the safe shutdown analyses. The 1996 audit resulted in two DRs requiring Nuclear Engineering Department (NED) to review the post-fire operating procedures. These two DRs, QSAS-96-0101 and QSAS-96-0167 remained open at the time of this inspection. The PR which assigns the actions to NED is 2-96-789. The inspectors verified that the due dates for the PR had been extended in accordance with the requirements of the corrective action progra The required reviews were enveloped by a fire protection program review by NED, which was planned for the first quarter of 1999. Although the plan for the review had not been approved or issued at the time of the inspection, a draft of the plan attached to a memorandum from the Vice President, dated November 23,1998, appeared to have appropriate scope and depth of review to resolve the discrepancie The adequacy of the Engineering assessment of the Fire Protection Program to l resolve the issues resulting from the 1996 program audit will be reviewed in a !

future inspectiori. (IFl 50-334(412)i98-10-01)

c. Conclusions l I

The Quality Services Unit (QSU) has done an excellent job identifying areas for j improvement in the fire protection program through their program audits. The QSU is ahead of the industry in that they started reviewing post-fire safe shutdowrt procedures and moinodologies in 1995. Corrective actions for some of the identified deficiencies (particularly safe shutdown analysis actions not being j properly implemented in the post-fire shutdown procedures) had not been cotapleted for a significant time period. The Nuclear Engineering Department review of post-fire shutdown procedures against the fire protection design basis had not been started at the end of the inspection, nor had the plan for conducting the review been finalized and approve ,

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F8 Miscellaneous Fire Protection issues F8.1 (Closed) LER 50-412/98-05: Inadequate Fire Protection Safe Shutdown Analysis for i Boric Acid to Boric Acid Blender Valve,2CHS*FCV113 i Inspection Scoce (92700)

The inspectors performed an onsite review of the LER. The inspectors interviewed l engineers, examined a sample of corrective actions, and reviewed the operability I determination I Observations and Findinas On April 2,1998, during a review of a proposed modification, an electrical engineer identified that the existing fire protection safe shutdown analysis for the boric acid storage tank to the boric acid blender supply valve,2CHS*FCV113A, was deficien Due to errors in the valve control circuit analysis, boration via the boric acid tanks specified in the analysis and the plant operating manual would be unavailable for two fire areas (Cable Vault and Rod Control Area Cable Tunnel or the Primary :

Auxiliary Building Elevation 773'6"). The errors resulted from oversight of the support cables and equipment for 2CHS*FCV113A while developing the list of l electrical cables in specific designated fire areas for the fire protection safe l shutdown analysi '

During this report period, the inspectors reviewed station drawings and independently verified that although the boric acid tanks would be unavailable, the refueling water storage tank would remain available as a boration flow path. Using existing procedures, the plant could still achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as specified in the safe shutdown analysi The inspectors determined that the engineer demonstrated a questioning attitude in identifying the deficiency. Major corrective actions included a modification of the circuit to meet existing design requirements and an extent of condition review. The engineer examined safe shutdown components and cables for one boration flow path during the extent of condition review. The modification and extent of l condition review were appropriate to address the deficienc Section 2.F of the Unit 2 Facility Operating License No. NPF-73 requires that DLC shall implement and maintain in effect all provisions of the approved fire protection i program as described in the Updated Final Safety Analysis Report (UFSAR). The l fire protection safe shutdown analysis and UFSAR describe the equipment operability following fires in plant areas including the available boration flow path Contrary to the above, due to design errors in the valve control circuit, 2CHS*FCV113A would not be available during fires in the Cable Vault and Rod Control Area Cable Tunnel or the Primary Auxiliary Building Elevation 773'6". 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 50-412/98-10-02).

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18 Conclusions An electrical engineer identified a deficiency in the fire protection safe shutdown analysis which affected a boration flowpath. Corrective actions were appropriat t

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V. Manaaement Meetinas  ;

X1 Exit Meeting Summary .

The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on December 31,1998. The licensee acknowledged the findings presented. The licensee did not indicate that any of the information presented at the exit meeting was proprietar ,

X2 Duquesne Light Company Organization Changes Effective December 9,1998, Mr. Mark P. Pearson assumed the duties of Manager, Quality Services Uni X3 NRC Organization Changes Effective December 14,1998, Mr. Dan S. Collins assumed the dutias of NRC Project Manager for Beaver Valley Power Station, Division of Nuclear Reactor Regulatio X4 NRC Management Meetings On November 16,1998, Mr. R. Crlenjak, NRC Region I, Deputy Director, Division of !

Reactor Projects, and other members of the Beaver Valley Oversight Panel, met with Mr. Cross and other DLC representatives at Beaver Valley Power Station. The NRC presented the exit results for NRC Inspection 50-334(412)/98-09and DLC personnel presented a self '

i assessment of Beaver Valley Units 1 A&2 Restart Plan Performance. A copy of the slides presented by DLC at this meeting is attached as enclosure (2).

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PARTIAL LIST OF PERSONS CONTACTED Duauesne Liaht Comoany J. Cross, President, Generation Group R. Brandt, Vice President, Nuclear Operations Support Group S. Jain, Vice President, Nuclear Services  ;

M. Pearson, Manager, Quality Services Unit J. Macdonald, Manager, System & Performance Engineering K. Beatty, General Manager, Nuclear Support Unit W. Kline, Manager, Nuclear Engineering Department B. Tuite, General Manager, Nuclear Operations R. Hansen, General Manager, Maintenance Programs Unit R. Vento, Manager, Health Physics D. Orndorf, Manager, Chemistry M. Ackerman, Director, Safety & Licensing NRC D. Kern, SRI G. Dente!, RI G. Wertz, RI I

j INSPECTION PROCEDURES USED

l lP 37551: Onsite Engineering l lP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 64704: Fire Protection Program '

IP 71707: Plant Operations IP 71750: Plant Support IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 90712: Inoffice Review of Written Reports of Power Reactor Facilities IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities l IP 92901: Follow-up - Operations

, IP 92902: Follow-up - Maintenance

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IP 92903: Follow-up - Engineering IP 92904: Follow-up - Plant Support

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ITEMS OPENED, CLOSED AND DISCUSSED ->

Opened / Closed 50-412/98-10-02 NCV inadequate Fire Protection Safe Shutdown Analysis for Boric Acid to Boric Acid Blender Valve 2CHS*FCV113A

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

Onened 50-334(412)/98 10-01 IFl Scope and adequacy of NED review of Fire Protection Program to resolve issues in PR 2-96-789 (Section j F7.1)

Closed 50-334/98-28 LER - Automatic Reactor Trip On 'A' Steam Generator Low !

Level Coincident With Steam Flow / Feed Flow Mismatch Signal From Manually Tripped Transmitter Bistables of ;

F-MS-475 (Section 08.1)

50-334(412)/97-05-05 VIO Inadequate Control of Troubleshooting Activities Leads to ESF Actuation (Section M8.1)

50-412/97-11-08 VIO Inadequate Work Instructions and Improper Control of Supplemental Work Instructions in Maintenance Work Request (MWR) (Section M8.2)

50-412/97-517(01013) EA Failure to Prevent Gas Binding of High Head Safety injection Pumps (Section E8.1)

50-334/98-80-02 VIO Failure to Promptly Correct Excessive Leakage of Residual Heat Valve MOV-RH-758 (Section E8.2)

l 50-334/97-08-05 VIO Failure to Establish Adequate Radiation Monitoring l System (RMS) Calibration Procedures (Section R8.1)

l l 50-334/97-08-06 IFl Documentation of RMS Detector Failures (Section R8.2)

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! 50-412/98-05 LER Inadequate Fire Protection Safe Shutdown Analysis for Boric Acid to Boric Acid Blender Valve, 2CHS*FCV113A (Section F8.1)

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LIST OF ACRCid MS USED ,

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ANI American Nuclear Insurers CR Condition Report CREBAPS Control Room Emergency Bottled Air Presurization System DLC Duquesne Light Company DR Deficiency Report EA Enforcement Action '

gph Gallons Per Hour  ;

HHSI Hy Head Safety injection l IFl inspector Follow-up ltem LC0 Limiting Condition of Operation LER Licensee Event Re port LLD Lower Limits of Detection MDAT Multi-Discipline Analysis Team MMP Meteorological Monitoring Program 1 MPS Maintenance Planning Scheduling MSP Maintenance Surveillance Procedure MWR Maintenance Work Request NED Nuclear Engineering Department NFPA National Fire Protection Association NPDAP Nuclear Power Division Administrative Procedure NRC . Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual i OST Operating Surveillance Test PR Problem Report QA Quality Assurance QC Quality Control QSt 8 Quality Services Unit REMP Radiological Environmental Monitoring Program RH Residual Heat i RMS Radiation Monitoring System ROC Radiological Operations Center RP&C Radiological Protection and Chemistry SG Cteam Generator SJAE Steam Jet Air Ejector TLD Thermolumhescent Dosimeter TS Technical Spacifications UFSAR Updater; final Safety Analysis Report VCT Volume Cont al Tank VIO Violatior:

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Management Meeting Nuclear Regulatory Commission

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Duquesne Light Company

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HEgg Beaver Valley Power Station f ^"i November 16,1998- ,,

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Management Meeting Nucl-Mentatory Commission

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L some Light Company Beaver V4;cy Power Station November 16,1998 I

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l Slide 2 Agenda i i

e introduchum & l Opomns Remarks Jun Cros e Plant Statta Kevm Ostrowski e Restart Act an Plan Kewm Ostmwaki e Lassarmtmarnadard Organg Areas ofEmplosis Satul Jam o Licane Amadnad Schedule Mark Ackerman

. o ,sua.e s a a summ.,y 3,m c, >

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l Introduction Jim Cross President, Generation Group

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m v Slide 4 Plant Status and Restart Action Plan Kevin Ostrowski Vice President, Nuclear Operations

Slide 5 Plant Status

+ Unit ! Status

+ Unit 2 Status

+ Unit 2 Shutdown l

l * Outage Schedule

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Slide 6 Restart Action Plan

+ Restart Act.on Plan Milestones

  • Restart Action Plan Follow-up

+ Technical Specification Knowledge

+ Technical Specification Compliance l *

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l Slide 7 )

i Lessons Learned and Ongoing Areas of Emphasis Sushil Jain Sr. Vice President, Nuclear Services

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Slide 8 Lessons Learned

+ Peiformance Standards

+ Technical Specification Knowledge

. + Recognition and Resolution of Degraded Conditious

+ Corrective Action and Operatmg Experience Programs

  • Processes and Procedures a 1 l

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!. I Slide 9 Corrective Actions

  • Safety Culture Training l + Technical Specification Training

+ Strong Corrective Action / Operating Experience Programs i

+ Process and Procedure Reviews

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Slide 10 ,

Ongoing Areas of Emphasis l

+ Problem Solving Process

+ llaman Performance Program

+ Operations Procedures Backlog !

+ 12 Week Schedule l

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License Amendment Schedule Mark Ackerman !

Manager, Safety and Licensing l i

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i License Amendment Schedule

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+ Requests With Admmistrative Control i

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+ Priority 2 and 3 Requests l.

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>V Slide 13 Divestiture Status and Summary Jirn Cross President, Generation Group l l

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