L-98-074, Responds to NRC Re Violations Noted in Insp Repts 50-334/97-11 & 50-412/97-11.Corrective Actions:Suppl Work Instruction That Was Not Properly Controlled Was Removed from Work Package

Responds to NRC Re Violations Noted in Insp Repts 50-334/97-11 & 50-412/97-11.Corrective Actions:Suppl Work Instruction That Was Not Properly Controlled Was Removed from Work Package

ML20217D443
Person / Time
Site:	Beaver Valley
Issue date:	04/16/1998
From:	Legrand R DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-334-97-11, 50-412-97-11, L-98-074, L-98-74, NUDOCS 9804240319
Download: ML20217D443 (7)

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Telephone (412) 3934000

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Shippingport. PA 15077-0004 April 16,1998 L-98-074 U. S. Nuclear Regulatory Commission l

Attention: Document Control Desk j

Washington, DC 20555-0001 1

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Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 i

BV-2 Docket No. 50-412, License No. NPF-73 l

Integrated Inspection Report 50-334/97-11 and 50-412/97-11 Reply to Notice of Violation i

l In response to NRC correspondence dated March 17,1998, and in accordance with l

10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.

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If there are any questions concerning this response, please contact Mr. J. Arias at (412)393-5203.

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Sincerely, Ronald L. LeGrand Attachment c:

Mr. D. S. Brinkman, Sr. Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. C. W. Hehl, Director, Division of Reactor Projects, Region 1 9904240319 980416 PDR ADOCK 05000334

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s DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit No. I and No. 2 Reply to Notice of Violation Integrated Inspection Report 50-334/97-11 and 50-412/97-11 Letter Dated March 17,1998 VIOLATION A (Severity Level IV, Supplement 1)

Description of Violation (50-412/97-11-08)

TS 6.8.1 requires that written procedures be properly established and implemented covering activities recommended in Appendix "A" of NRC Regulatory Guide (RG) 1.33, Rev. 2, February 1978. NRC RG 1.33 states, in part, that maintenance which can affect the ~ performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures and documented instructions appropriate to the circumstances.

Contrary to the above, from January 26 to February 4,1998, repair activities for the 2-1 i

station battery were not properly pre-planned and implemented. Specifically, the work instructions contained in maintenance work requests (MWR) 69496 and 69526 were inadequate in that they did not provide sufficient detail to assure intercell connectors were properly controlled. Further, a supplemental work instruction for jumperirig cell

1. 40 from the 2-1 station battery was not properly controlled in that it did not receive appropriate reviews as part of the MWR planning and authorization process. Inadequate tightening of an intercell connector 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.

Reason for the Violation NPDAP 7.5, " Processing of a Maintenance Work Request," does not provide a clear standard for work package content or preclude the excessive use of supplemental work instructions in lieu of an approved procedure.

In addition, the field personnel performed work outside of the scope of the work instructions.

The job should have been stopped and additional supervisory input requested, in accordance with existing maintenance standards.

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• Reply to Notice of Violation i

' Inspection Report 50-334/97-11 and 50-412/97-11

' Page 2 i

Corrective Action Taken and Results Achieved

1. The supplemental work instruction that was not properly controlled was removed from the work package.

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2. The loose intercell connector was properly secured and a post maintenance discharge test was successfully performed. The battery was returned to an operable status on February 4,1998, after recharging.

Corrective Actions to Prevent Further Violations

1. A written communication will be issted to Maintenance Programs Unit (MPU) personnel by April 30,1998, which:

reinforces maintenance standards for review of work packages, including the need to ensure that the work instructions provide sufficient detail for the scope J

of work to be performed l

reinforces that the job should be stopped if the work instructions are not adequate, and that no work is permitted to be performed outside of the scope of t

the work instructions provides guidance for determining when a procedure change should be e

considered, instead of providing supplemental MWR work instructions.

2. The Work Planner Desktop Guide describes the planning process and provides information on the available site references to be used. It also provides some limited guidance on the level of detail required in the work instructions for various tasks. In order to improve the work planning standards and guidance provided, the Work Planner Desktop Guide will be revised by May 30,1998 to:

establish standards for work package technical content in order to provide consistency in work package quality

.. provide guidance for work package review within the work planning section, and also for work package review by field personnel for initial work j

instructions and also for supplemental instructions added after work has begun.

3. Training on the revised Work Planner Desktop Guide will be provided to maintenance planning personnel by June 30,1998.

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', Reply to Notice of Violation Inspection Report 50-334/97-11 and 50-412/97-11 Page 3 l

4. NPDAP 7.5 " Processing a Maintenance Work Request" will be revised by July 15, 1998, to strengthen the controls for work package content, and provide guidance on when nn approved procedure is required in lieu of supplemental work instructions.

5. The maintenance standards will be reinforced with active duty MPU craft personnel by July 15,1998.

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6. The station battery corrective maintenance procedure will be revised by July 15, 1998, to provide more details for replacing battery components, including enhanced controls over fastener configurations.

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7. An effectiveness review of the above corrective actions will be completed by December 11,1998.

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8. A self-assessment will be completed by July 15,1998, to:

review the use of MWR work instructions to supplement existing procedures review the level of detail provided in various types of equipment maintenance e

procedures by reviewing a sampling of procedures review MPU pre-job briefing and shift turnover practices e

review the adequacy of post maintenance testing e

The findings of this self-assessment will be addressed under the corrective action program.

. Date When Full Compliance Will Be Achieved The 2-1 station battery was returned to operable status on February 4,1998.

The letter to MPU personnel will be issued by April 30,1998.

l The Work Planner Desktop Guide will be revised by May 30, 1998. Training on the revised Work Planner Desktop Guide will be completed by June 30,1998.

NPDAP 7.5 will be revised by July 15,1998.

The maintenance standards will be reinforced with active duty MPU craft personnel by July 15,1998.

The station battery corrective maintenance procedure will be revised by July 15,1998.

, Reply to Notice of Violation l

Inspection Report 50-334/97-11 and 50-412/97-11 i

Page 4 The self-assessment described above will be completed by July 15,1998.

The effectiveness review will be completed by December 11,1998.

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' Reply to Notice of Violation Inspection Report 50-334/97-11 and 50-412/97-11 Page 5

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VIOLATION B (Severity Level IV, Supplement I)

Descrio6on of Violation (50-334/97-11-02)

TS 6.8.1 requires that written procedures be properly established and implemented covering activities recommended in Appendix "A" of NRC Regulatory Guide (RG) 1.33, Rev. 2, February 1978. NRC RG 1.33 states, in part, that administrative procedures should cover shift and relief turnover and log entries.

Licensee procedures 1/20M-48.5.A, " Logs and Reports," Rev.10, and 1/2OM-48.1.C,

" Shift Turnover and Relief," Rev. 2 implement shift and relief turnover and log entry requirements. Specifically,1/20M-48.5.A requires that entering and exiting TS action statements, limiting condition of operations and action numbers are recorded in operating i

logs. In addition,1/2OM-48.1.C requires that the nuclear shift supervisor and assistant l

nuclear shift supervisor certify that their narrative and tour logs are accurate, clear, concise and complete.

Contrary to the above, on January 21, operators failed to log TS 3.3.1.1 and TS 3.0.3 l

limiting condition of operation entry and exit in response to identified isolation of l

feedwater flow channels and a resultant inoperable reactor protective system reactor trip function. In addition, the nuclear shift supervisor and assistant nuclear shift supervisor failed to recognize the incomplete log entries during shift turnover.

Reason for the Violation

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The on duty operations shift personnel failed to complete the logging requirements in procedures 1/20M-48.5.A " Logs and Reports" and 1/20M-48.1.C " Shift Turnover and Relief" due to cognitive personnel error.

Corrective Action Taken and Results Achieved

1. The Nuclear Shift Supervisor and the Assistant Nuclear Shift Supervisor involved with the event were counseled on February 11,1998, concerning the failure to meet operations logging standards.

2. Condition Report 980290 was written on February 12,1998, to document the failure to properly log the entry and exit into Technical Specification 3.0.3 on January 21, 1998. This condition report was reviewed by the active licensed operations staff and Shift 1echnical Advisors (STAS) by March 23,1998.

3. The General Manager of the Nuclear Operations Unit re-emphasized management

- expectations for log keeping and shift turnover during discussions with all active luty

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.,., Reply to Notice of Violation J

Inspection Report 50-334/97-11 and 50-412/97-11 l

Page 6 1

licensed personnel and STAS in the Operations Department. These discussions were held between February 22,1998, and March 10,1998.

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4. Beaver Valley Unit I Licensee Event Report (LER) 98-002-00 was issued on February 20, 1998, and reported the conditions prohibited by the technical specifications as a result of the inadequate recovery from a calibration of the feedwater flow transmitters. Included in the LER analysis of the event was:

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discussion of the entries into Technical Specifications 3.3.1.1 and 3.0.3, and the 1

l failure to log the entry and exit of Technical Spe::ification 3.0.3.

Corrective Action to Prevent Further Violations i

1. Operating Manual procedure 1/20M-48.1.I,'" Technical Specification Compliance" was issued on February 9,1998. This procedure provides instructions for assessment l

of entered technical specifications and recommended actions, in the form of a i

l checklist, to take upon entering a technical specification action statement that requires a unit shutdown. This checklist includes specific guidance on operator log entries.

2. Technical Specification Compliance Training is currently being conducted for designated site personnel including licensed operations personnel. The purpose of the training is to baseline the understanding of the technical specifications, including ownership and management standards and expectations for full compliance. Topics covered include the relationship of technical specifications in the overall licensing l

process, specific examples of proper technical specification compliance and examples i

l of past non-compliances with technical specifications. Management standards for the logging of technical specification entries and exits are also being reviewed. This training will be completed for designated personnel prior to entry into Mode 4 from the current outage at either unit. Designated personnel who do not successfully complete this training will be restricted from independent technical specification related duties until remediated.

Date When Full Compliance Will Be Achieved Full compliance was achieved with the reporting of the conditions prohibited by the technical specifications by LER 98-002-00 dated February 20,1998, which documented the technical specification entries and exits on January 21,1998, as a result of this event.

The completion of the Technical Specification Compliance Training for designated personnel will be completed prior to entry into Mode 4 for either unit.