ML20236X856

Forwards Insp Repts 50-334/98-03 & 50-412/98-03 on 980426-0627 & Novs.One Apparent Violation Was Identified & Being Considered for Escalated EA

ML20236X856
Person / Time
Site:	Beaver Valley
Issue date:	08/05/1998
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J DUQUESNE LIGHT CO.
Shared Package
ML20236X857	List: IR 05000334/1998003 ML20236X856 ML20236X863 ML20236X866
References
50-334-98-03, 50-334-98-3, 50-412-98-03, 50-412-98-3, EA-98-359, NUDOCS 9808100323
Download: ML20236X856 (4)

See also: IR 05000334/1998003

Text

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e

August 5,1998

EA 98-359

Mr. J. E. Cross

President

Generation Group

Duquesne Light Company (DLC)

Post Office Box 4 '

Shippingport, Pennsylvania 15077

SUBJECT: NRC INTEGRATED INSPECTION REPORT 50-334/98-03,50-412/98-03

NOTICES OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION

,

Dear Mr. Cross:

The NRC conducted an inspection of the Beaver Valley Power Station (BVPS) facilities from

April 26 to June 27,1998. The enclosed report presents the results of that inspection.

During the 9-week period covered by this inspection report, you maintained both units in a

safe shutdown condition while your organization worked to identify and resolve degraded

equipment and design conditions. Our inspectors observed that your engineering,

operations, and maintenance personnel typically implemented appropriate actions to

resolve identified mode hold constraints. Unit 2 pressurizer power operated relief valve

(PORV) corrective maintenance and testing were safely performed. Identification of

nonseismically qualified capacitors in the high energy line break isolation circuit, during

routine preventive maintenance, demonstrated a good questioning attitude. In addition,

prioritization processes for maintenance and engineering backlogs generally demonstrated

appropriate risk insights.

You have developed and implemented an effective program for the calibration and repair of

radiological survey instrumentation, air sampling devices and electronic dosimeters, and for

maintaining an inventory of radiological sources at the facility. The program for periodic

leak testing of radiological sources was conducted in accordance with plant Technical

Specifications (TS). Controls for PORV work in the Unit 1 containment were determined to

be effectively established and implemented. The program for training and qualification of

radiation protection technicians was effectively established.

Notwithstanding these areas of good performance, based on the results of this inspaction,

the NRC has determined that two violations of NRC requirements occurred. These

violations are cited in the enclosed Notices of Violation (Notices) and the circumstances

surrounding them are described in detail in the subject inspection report. The violations are

i

of concern as follows. In the first instance, an increasing trend of human performance

errors involving inadequate procedure implementation occurred which challenged operators'

capability to maintain adequate plant configuration control. in the second instance, past

practices of venting the high head safety injection pumps prior to surveillance testing g

I

9808100323 900805 $

PDR

G

ADOCK 05000324

PDR

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.

.

Mr. J. E. Cross 2

l preconditioned the system because adverse conditions were revealed through the venting

process and not assessed and, as a result, invalidated the tests.

l

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements. A response to the second violation is not required because our

inspectors verified your corrective actions during this inspection.

-

Our inspectors also reviewed several longstanding deficiencies associated with the testing

i of safety related logic circuits and your actions to identify and correct these items. Each

l deficiency represented a violation of the respective TS surveillance testing requirement.

l

The NRC is exercising discretion in accordance with Section Vil.B.3 of the Enforcement

Policy and is not issuing a Notice of Violation for these Severity Level IV violations

involving inadequate surveillance testing. Discretion is warranted because: (1) the

inadequacies were self-identified as a result of your initiative in response to NRC Generic

Letter 96-01, (2) you implemented timely and effective corrective actions, (3) the testing

deficiencies were not likely to be identified by routine efforts, and (4) the actions that

caused the testing deficiencies are dated and not reflective of current performance. The

exercise of discretion acknowledges your good effort to identify and correct subtle

violations, that would not be identified by routine efforts, before the degraded safety

systems are called upon.

l In addition, an apparent violation was identified and is being considered for potential

l

enforcement action. This issue involved instances between 1990 and present, in which

your staff identified that the TS were not adequate to assure station compliance with the

design basis as described in the Updated Final Safety Analysis Report. Despite identifying

these adverse to quality conditions, in some instances, you failed to establish appropriate

l

i administrative controls and failed to request revisions to your TS to properly resolve these

l conditions. Accordingly, no Notice of Violation is presently being issued for these

!

inspection findings. In addition, please be advised that the number and characterization of

apparent violations described in the enclosed inspection report may change as a result of

further NRC review. Additional NRC inspection, as well as assessment of your ongoing

investigations and corrective actions is necessary to determine the safety and regulatory

l significance of these issues. You will be advised by separate correspondence of the

results of our deliberations on this matter. No response regarding the apparent violation is

required at this time.

I

r

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.

.

Mr. J. E. Cross 3

!

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter l

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and its enclosures will be placed in the NRC Public Document Room (PDR).

Sincerely, j

Original Signed By:

4

I

Charles W. Hehl, Director

Division of Reactor Projects

l Docket Nos. : 50-334,50-412 l

i License Nos.: DPR-66, NPF-73

Enclosures:

1. Notice of Violation

2. Notice of Violation with No Response Required I

3. Inspection Report 50-334/98-03,50-412/98-03

cc w/encis:

S. Jain, Senior Vice President, Nuclear Services Group

l D. Brandt, Vice President, Nuclear Operations Group and Plant Manager

!

R. LeGrand, Vice President, Operations Support Group

W. Kline, Manager, Nuclear Engineering Department

B. Tuite, General Manager, Nuclear Operations Unit

M. Pergar, Acting Manager, Quality Services Unit

S. Hobbs, Director, Safety & Licensing Department

J. Macdonald, Manager, Systeni and Performance Engineering

M. Clancy, Mayor, Shippingport, PA

Commonwealth of Pennsylvania

State of Ohio

State of West Virginia

l

l

,

1

L.______________ - _ _ _ _ .- - _ - _ -

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e

.

Mr. J. E. Cross 4 1

l

Distribution w/encts:

Region i Docket Room (with concurrences)

PUBLIC

Nuclear Safety information Center (NSIC) )

NRC Resident inspector

H. Miller, RA/W. Axelson, DRA

M. Evans, DRP

N. Perry  ;

'

D. Haverkamp, DRP

C. O'Daniell, DRP

D. Holody, EO, RI

l

Distribution w/encls (VIA E-MAIL):

B. McCabe, OEDO

R. Zimmerman, ADPR, NRR  ;

J. Goldberg, OGC (AEN, LFD)

J. Lieberman, OE (OEMAIL) ,

D. Holody, EO, RI

R. Capra, PD1-2, NRR

D. Brinkman, PM, PDI-2, NRR

V. Nerses, PDI-2, NRR

R. Correia, NRR

F. Talbot, NRR

DOCDESK

Inspection Program Branch, NRR (IPAS)

DOCUMENT NAME: G:\ BRANCH 7\BV\lR98-03.BV ,

To receive e copy of this document, indicate in the boa: "C" = Copy without ottachment/ enclosure 'E" = Copy with attachment / enclosure

"N" = No copy ,

( " OFFICE Rl/DRP Rl/DRP l Rl/DRP q lc (Rl/ORAyff

NAME DKern/al gg, MEvans EE CHeht. 1/A n fTWalker' '

DATE 07/3098 07/3U98 9/ggg OgF,g981 '/ 0%/i/98

OFFICIAL RECORD COPY

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