IR 05000334/1999005
| ML20216J971 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley  |
| Issue date: | 09/30/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20216J967 | List: |
| References | |
| 50-334-99-05, 50-412-99-05, NUDOCS 9910070077 | |
| Download: ML20216J971 (20) | |
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l U. S. NUCLEAR REGULATORY. COMMISSION
. REGION 1 l
License No DPR-66, NPF-73 Report Nos.- 50-334/99-05,50-412/99-05 Docke No , 50-412 i
Licensee: Duquesne Light Company j Post Office Box 4 '
Shippingport, PA 15077 l Facility: Beaver Valley Power Station, Units 1 and 2 l
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Inspection Period: July 25,1999 through September 4,1999 i
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inspectors: D. Kern, Senior Resident inspector G. Dentel, Resident Inspector G. Wertz, Resident inspector l N. Perry, Project Engineer R. Lorson, Senior Resident inspector, Seabrook F. Arner, Reactor Engineer, DRS W. Maier, Emergency Preparedness Specialist l
, Approved by: P. Eselgroth, Chief !
Reactor Projects Branch 7
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9910070077 990930 PDR ADOCK 05000334 g PM
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EXECUTIVE SUMMARY Beaver Valley Power Station, Units 1 & 2 NRC Inspection Report 50-334/99-05 & 50-412/99-05 This integrated inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of resident inspection; in addition, it includes the results of supplemental inspections by regional inspector Operations
In two separate instances, valves were manipulated contrary to controls implemented previously for configuration control and troubleshooting. No adverse safety consequences resulted from the action.s. This Severity Level IV violation is being treated as a Non-Cited Violation, cc,sistent with Appendix C of the NRC Enforcement Policy and is addressed in the cor.ective action program as Condition Report 991896. (Section 01.2) .
The licensee eliminated a Unit 2 risk significant workaround associated with maintaining control rods in manual control. The cumulative impact of the operator workarounds was minimal. (Section O2.1) l Maintenance
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Two maintenance activities were conducted safely and in accordance with procedure Planning deficiencies for one of the activities were properly captured in the condition report program. (Section M1.1)
Seven surveillance tests were performed well. Some emergency diesel generator deficiencies were not captured in the material deficiency identification program. (section M1.2)
Additional contractor support and improved work order tracking were used to reduce the non-outage corrective maintenance backlog slightly to 975 items over the last six months. While no immediate operability concerr's were identified, the current backlog remains above the station's year-end goal of 800 items and maintenince schedule adherence remained bw. Degraded equipment has contributed to several forced shutdowns and continued material condition improvements are warranted. (Section M2.1)
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- The maintenance procedure reWsion backlog was high (380) Lut decreasing, with appropriate emphasis on the higher priority procedures. The program for controlling the procedures needing revisions was good. (Section M3.1)
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The engineering backlog remained high (1800 open items). The overall prioritization of the items was appropriate. Powever, the overall size of the backlog and number of resource intensive items (Unit 2 small bore piping evaluations, Unit 1 nitrogen backup modifications, etc.) resulted in other items being resolved slowly as compared to their safety significance. These included resolution of a possible unreviewed safety question and incorrect steam generator tube rupture analysis design assumptions. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy and is addressed in the corrective action program as CR 992491. (Section E2.2)
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The initial evaluation of elevated reactor coolant average temperatures above the normal programmed band during reactor startups, was not rigorous or documente Subsequent detailed evaluations were technically sound and confirmed that the units had not been operated outside of the design bases of the plant. (Section E8.1)
Plant Support
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The onsite emergency facilities were maintained ready for response to an emergenc Improvements tvere implemented to more efficiently make offsite nonfication CommunicAion testing procedures and inventories were completed as required. No deficiericies were noted in the 10 CFR 50.54(q) evaluations for the latest two emergency plan revisions. The licensee's annual EP program audits were comprehensive, organized, and detailed. (Sections P2, P3, and P7)
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The program for training the senior Emergency Response Organization members was effective as demonstrated by the four responders interviewed who showed excellent knowledge of their duties and responsibilities. The training and qualification of Emergency Response Organization members were effectively tracked and maintaine There was an indicated need for better training of an onshift communications coordinator based on the observed emergency scenario walkthrough. The efforts to determine the extent of the problem and possible corrective actions were timely. (Sections P4, P5, and P6)
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TABLE OF CONTENTS Page i EXECUT!VE SU MMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ...................ii ,
TABLE OF CONTE NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv ;
1. Ope ratio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O1 Conduc' of 0perations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . ..........1 01.2 ,mproper Operator Troubleshooting . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . ...2 i O2.1 Operator Workarounds . . . . . ... ........................2 I I . M ai nten an ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.1 Routine Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.2 Routine Surveillance Observations . . . . . ....................4 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . . 5 M2.1 Maintenance Backlog . . . . . . . . . . . . . . . . . . ................. 5 M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . . ..6 M3.1 Maintenance Procedure Revision Backing Review. . . . . . . . . . . . . . . . 6 Ill . Engineer ing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... .. ........ 7 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 7 E2.1 Preventive Maintenance Optimization Program Review . . . . . . . . . . . 7 :
E2.2 Engineering Backlog . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 I E Elevated Reactor Coolant Average Temperature above Program Values
......................................... ...... ....... 9 IV. Pla nt Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ................ . 10 I P2 Status of Emergency Preparedness (EP) Facilities, Equipment, and Resources
................................ ... .......................... 10 P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 P4 Staff Knowledge and Pedormance in EP . . . . . . . . . . . . ..............12 P5 Staff Training and Qualification in EP . . . . . . . . . . . ...................13 P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 P7 Quality Assurance in EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 i
V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 X1 . Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 )
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . _. . . . . . . . . . . . . . . . . . . . . 15 LI ST OF AC RONYM S U S E D . . . . . . . . . . . . . . . . . . . . . . . . . . . ............... .... 16
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Report Details
' Summary of Plant Status
' Unit i began this inspection period at 100 percent power and remained at or near full power i throughout the perio Unit 2 was in Mode 5 (Cold Shutdown) at the beginning of this inspection period while the plant continued troubleshooting problems associated with the emergency diesel generators and service water system. After resolution of the problems, the plant returned to pcwer operation,
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synchronizing the main generator to the offsite electrical distribution grid on July 27. The plant achieved full power operation on July 29 and remained at or near full power throughout the remainder of the inspection perio . Operations
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I 01 Conduct of Operations O1.1 General Comments (71707)
Using inspection Procedure 71707, the inspectors conducted frequent reviews of i 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. Lmorooer Operator Troubleshootina Insoection Scope (71707)
The inspectors examined operator actions taken to evaluate degraded condition Observations and Findinas On two different occasions, the inspectors identified that operators manipulated valves contrary to configuration control procedural requirements. On July 21 with the unit in Mode 5,' operators stroked two valves in the low head safety injection system to facilitate system engineering troubleshooting regarding a Unit 2 safety injection relief valve, which lifted on July 19. The nuclear shift supervisor (NSS) authorized the action since it was a short, simple evolution on a system not required by technical specifications in Mode On July 27 with Unit 2 in Mode 3, indication and control problems with two atmospheric s steam dump valves were observed. The NSS appropriately directed operators to isolate both valves. The NSS subsequently authorized mopening the atmospheric steam dump
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valves and manualisolation valves in order to troubleshoot / evaluate operability of the valve The inspectors determined that the valve manipulations were not routine activities and no urgent plant safety concems were present which necessitated quick action. In the past two years, the licensee modified the Operation Department procedures to improve
. configuration control, eliminate operator troubleshooting, and implemer' a sitewide l
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troubleshooting procedure (Nuclear Power Division Administrative Procedure 8.34,
" Control of Troubleshooting Activities," Rev. 2). The operators bypassed the controls and evaluations required by these procedures in these two example Operation Manual (OM) 1/20M-48.3.D, " Conduct of Operations, Administrative Control of Valves and Equipment," Rev.19, states that "All valve or equipment operation will be performed by one of the following methods: a) by an approved procedure under the direction of the Nuclear Shift Supervisor / Assistant Nuclear Shift Supervisor (NSS/ANSS);
b) by a clearance; c) by a caution tag; or d) as an entry logged in the " Daily Joumal (operator logs]." Under method "d," the OM states " component manipulation under this category shall be limited to tasks that are relatively short, simple, routine, considered to be within the capability of a qualified individual and will not degrade system operations beyond Updated Final Safety Analysis Report (UFSAR) requirements." Contrary to the above, troubleshooting on equipment which involved operation of the stated valves was not a routine activity and the manipulations were not logged in the operator logs. Failure to properly implement 1/2OM-48.3.D during troubleshooting activities was a violation of Technical Specification (TS) 6.8.1.a, which requires that, " written procedures shall be established, implemented and maintained covering . . the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Rev. 2, February 1978." This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. (NCV 50-412/99-05-01).
The inspectors concluded no safety consequences resulted from the operators' action The unit was in a shutdown mode in both instances and the action had little to no effect on system operation. However, significant corrective actions were taken during the last two years to strengthen the configuration control and troubleshooting programs. The actions taken bypassed those improvements implemented. The General Manager of Nuclear Operations concluded that additional changes were needed for the program and corrective actions would be developed as part of Condition Report (CR) 99189 Conclusions In two separate instances, valves were manipulated contrary to controls implemented previously for configuration control and troubleshooting. No adverse safety consequences resulted from the actions. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy and is addressed in the corrective action program as CR 99189 Operational Status of Facilities and Equipment O2.1 Operator Workarounds Insoection Scooe (71707)
The inspectors evaluated the cumulative effect of operator workarounds and the progress made to eliminate the Observations and Findinas The inspectors evaluated the progress made on workarounds from May 1999 until August 1999. During this period, two workarounds were eliminated and none were added. A site-wide effort (system engineers, design engineers, and maintenance engineers / technicians) resulted in the elimination of the highe.st priority Unit 2 workaround (rod control system in manual). In August, workaround backlogs were 11 and 14 for Unit 1 and 2, respectively. Tlie number of risk significant workarounds continued to decline (see NRC Integrated inspection Report 50-334(412)/99-02). The lower risk significant workarounds received minimal support during the period reviewe Thirteen of the 25 had their expected completion dates extended. The extensions were attributed to scope expansion for several issues and the low prioritization of the '
remaining workarounds. The extensions were of minor safety significance since compensatory measures were already in place and the cumulative impact on operators was minima Conclusions The licensee eliminated a Unit 2 risk significant workaround associated with maintaining cortrol rods in manual control. The cumulative impact of the operator workarounds was minima II. Maintenance M1 Conduct of Maintenance M1.1 Routine Maintenance Observations Inspection Scope (62707)
The inspectors observed selected maintenance activities on important systems and components. The work orders (WOs) observed and reviewed are listed belo *
WO 97-067203-003 Steam Generator "1 A" Blowdown Tank Bypass Valve 1BD-19 Leak Repair
WO 99-201533-000 Pressurizer Relief Tank Primary Water Supply Valve TV-1RC-519 Air Regulator Preventive Maintenance Observations and Findinas The steam generator blowdown tank bypass valve 1BD-19 leak repair was performed safely and in accordance with proper procedures. The repair instructions were accurately described in the work order and the quantity of leak sealant injected was well controlled. The pressurizer relief tank (PRT) primary water supply valve TV-1RC-519 preventive maintenance was performed well. However, several problems with the planning of the WO were noted by the technicians. Some items were corrected prior to
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the work being performed and others were corrected as the job was in progress. The !
maintenance supervisor did not feel that a Condition Report (CR) was necessary since 1 the items were identified on a feedback form. However, the inspectors noticed that one i of the problems documented by the work crew was that a technical evaluation report (TER) for non-safety related regulators was being used on the safety related PRT primary water supply valve. The inspectors discussed this issue with the Director of Work Planning, who initiated CR 99229 Conclusions Two maintenance activities were conducted safely and in accordance with procedure Planning deficiencies for one of the activities were properly captured in the condition i report progra ]
M1.2 Routine Surveillance Observations Inspection Scope (61726)
The inspectors observed selected surveillance tests. Operational surveillance tests (OSTs) and oms reviewed and observed by the inspectors are listed belo I
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10ST-3 " Diesel Generator No.1 Monthly Test," Rev. 20 :
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10ST-3 " Diesel Generator No. 2 Monthly Test," Rev.' 22 i
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10ST-47.3B " Containment isolation and ASME Section XI test," Rev. 21
+ 2OST-1.11A "Safegueds r)rotection System Train A Blockable Test," Rev. 6
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2OST-3 " Emergency Die al Generator Monthly Test," Rev. 24
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2OST- "PORV isolation valve Test and Position Check," Rev.10 '
2OM-6. " Isolation of a Power Operated Relief Valve," Rev.13 ,
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The testing was performed in accordance with operations procedures. A minor procedural deficiency with the Unit 1 emergency diesel generator (EDG) monthly surveillance test was c@ured in the corrective action system (CR 992101). System -
engineers and plant operators properly monitored plant equipment. The preevolution briefings were detailed with strong use of industry information. During testing of the Unit 2 EDG, the inspectors identified some minor material deficiencies including:
- Multiple small oil leaks from EDG system component * The gage line was disconnected from the EDG fuel oil day tank level indicator (2EGF-Ll202B) located on the EDG ski * A minor offset (~2.5 inch) between the EDG fuel oil day tank level indicator (2EGF-LIS205B) and the tank sightglass readin The system engineer indicated that small EDG oil leaks are typically not repaired unless they present a potential operating problem, the tank level indicator (2EGF-Ll2028) on the front of the EDG was no longer used and was in the process of being formally ;
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abandoned, and the fuel oil day tank level indicator (2EGF-LIS2058) was scheduled for calibration. The inspectors concluded that although none of these material deficiencies presented an immediate operability concern, they reflected a deficiency in the station's use of the formal process for identification of material deficiencie Conclusions Seven surveillance tests were performed well. Some emergency diesel generator deficiencies were not captured in the material deficiency identification progra M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Maintenance Backloa Insoection Scope (62707)
The inspectors reviewed the effectiveness of ef' orts to reduce the non-outage corrective maintenance backlo Observations and Findinas The weekly completion rate of scheduled corrective maintenance work crders and the 4 percent of work orders completed on schedule remained low. During the previous two months, the average number of corrective maintenance work orders completed per weekly scheduled was 23 and 15 for Unit 1 and 2, respectively. Maintenance personnel completed an average of 64 percent of the scheduled corrective maintenance work orders. Planning deficiency problems contributed to low completion rates of work orders to the schedule and were documented in NRC Integrated Inspection Report 50-334(412)/99-04. Additional contractor support and improved work order trxking were used to reduce the non-outage corrective maintenance backlog from approximately 1000 <
to approximately 975 items over the last six months. The progress in reducing the l backlog was slowed by the Unit 2 refueling outage and the Unit 1 surveillance outag While no immediate operability concerns were identified, the backlog remains above the ;
station's year-end goal of 800 items. Degraded equipment has contributed to several i forced shutdowns and continued material condition improvements are warrante Conclusions . )
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I Additional contractor support and improved work order tracking were used to reduce the non-outage corrective maintenance backlog slightly to 975 items over the last six months. While no immediate operability concerns were identified, the current backlog remains above the station's year-end goal of 800 items and maintenance schedule adherence remained low. Degraded equipment has contributed to several forced shutdowns and continued material condition improvements are warrante !
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M3 Maintenance Procedures and Documentation e
M3.1 Maintenance Procedure Revision Backloa Review Inspection Scope (62707)
The inspectors examined the large outstanding backlog of maintenance procedure i revision requests for impact on conduct of maintenance activities and quality of procedures. The inspectors reviewed a sample of procedure change requests and examined long term backlog reduction plan l Observations and Findinos On August 9, the maintenance procedure revision backlog was 980. The inspectors reviewed approximately 100 procedure change requests in the electrical, mechanical and instrumentation and Control (l&C) groups, for various risk significant systems. The procedure change requests were grouped into priority 1, and enhancement. The priority 1 procedures were those requiring a revision before being performed; these procedures were pulled from use by maintenance personnel. As of August 9,188 of the 980 procedures were classified as priority 1. The enhancement procedures (792) were still available for use by maintenance personnel, since they did not require a revision before being performed. The decision on whether the revision was priority 1 or enhancement, was usually, initially made by the person requesting the revision, with a verification by the appropriate procedure writer. During review of the backlog, the inspectors concentrated on the appropriateness of the classification of the change request The inspectors did not identify any procedure change requests that were incorrectly classified. A few minor administrative errors were identified, whien were immediately l addressed by maintenance personnel. No procedures were identified as available for performance which should have been pulle The inspectors noted that since early in 1999, the maintenance procedure revision j backlog has been trending downward for priority 1 revisions, and has remained fairly stable for the enhancements.' However, maintenance personnel expect to get a large number of I&C priority 1 procedure requests in the near future due to a TS change request currently under NRC review. Adequate planning was in place to handle these upcoming procedures revisions. Overall, the goal for the backlog of priority 1 revisions was being met, and the goal for enhancements was not met due to maintenance personnel concentrating on the more important priority 1 revision Conclusions The maintenance procedure revision backlog was high (980) but decreasing, with appropriate emphasis on the higher priority procedures. The program for controlling the i procedures needing revisions was good.
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>b 111. Enaineerina E2 Engineering Support of Facilities and Equipment i
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E Preventive Maintenance Ootimization Proaram Review t . Insoection Scope (37551)
The inspectors interviewed personnel, and reviewed the preventive maintenance (PM)
optimization project summary document for the Unit 2 EDG system to determine the j status of the PM optimization progra !
1 Qhervations and Findinas i
The PM optimization program was initiated in February 1998 to optimize the frequency and scope of PM activities, and to improve equipment availability through more efficient scheduling of PM items. System engineers (SEs) were tasked to review the PM activities for their system, and to develop a project summary document describing their findings. The PM optimization project coordinator indicated that all system reviews have been completed, and that the next phase of the project was to incorporate the review ,
findings into the work planning and scheduling process. The inspectors concluded that l the proposed changes should reduce out of service time and thus improve equipment performanc )
The Unit 2 EDG PM optimization document was prepared consistent with the PM optimization program guidelines. The SE identified 10 functional equipment groups to coordinate future EDG PM activities. The inspectors reviewed selected PM activities and noted that they were assigned to the proper functional equipment group. The inspectors noted that no PM scope or frequency changes were identified by the review. The SE indicated that the existing PM program was considered adequate based on the good system performance at the time the review was complete Conclusions -
The PM optimization program implementation is in progress, and appeared to be a good
. Initiative to improve equipment performanc E Enaineerina Backloa Inspection Scooe (37551)
The inspectors reviewed the engineering backlog of open items and evaluated a select sample of the more significant backlog items. The review was to examine prioritization and to evaluate the timeliness of corrective action .
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b. - Observations and Findinos The engineering backlog, which includes CR investigations, CR corrective actions, commitment action tracking system (CATS) items, engineering memorandums (ems),
TERs, design change packages, and vendor technical information updates, remained high at approximately 1800 open items. The backlog has remained steady for the past year. The average age of corrective actions assigned to the nuclear engineering department was approximately one year. The inspectors identified that ceveral open corrective actions were several years old and had multiple extensions of the due date Overall the prioritization of the items was appropriate. However, the inspectors identified several items which have progressed towards resolution slowly as compared to their safety significance. For example, in May 1997, assumptions for a UFSAR steam generator tube rupture accident analysis were identified to be incorrect. The evaluation of whether the analysis remained bounding was not complete, and five extensions were granted for the due date. Nuclear engineers' initial assessment was that analysis should remain bounding based on similar nuclear plants having the same design assumptions reanalyzed. The current completion due date is January 200 In March 1997 a CR was initiated regarding the use of carbon steel fasteners in lieu of stainless steel fasteners for reactor coolant loop stop valves since initial Unit 1 startu The evaluation and determination of whether an unreviewed safety question (USQ)
exists were not completed. Nuclear engineering personnel's initial assessment was that minimal safety significance exists, however, a USQ may exist. The director of engineering plant support stated that the final determination shouH be completed by the end of September 199 These items and others reviewed show the significance of the large nuclear engineering backlog and the importance of working the items in a timely fashion. A large number of resource intensive items (Unit 2 small bore piping evaluations, Unit 1 nitrogen backup modifications, etc.) in the last two years resulted in the large backlog and caused resolution of some important items to be delayed.10 CFR 50, Appendix B, Criterion XVI,
" Corrective Action," requires in part that measures be established to assure that conditions adverse to quality such as deficiencies, deviations, and nonconformances are promptly identified and corrected. Contrary to the requirement, nuclear engineers failed to promptly evaluate and correct identified deficiencies for the two examples listed above and an additional example described in Section E8.1. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. (NCV 50-334(412)/99 05-02).
The nuclear engineering manager recognized the importance of reducing the backlog and was developing reduction plans. The plans were to reduce the backlog by developing criteria to screen out/ remove lower significance items from the backlog and from new open item o
9 Conclusions i
l The engineering backlog remained high (1800 open items). The overall prioritization of l the items was appropriate.' However, the overall size of the backlog and number of resource intensive items (Unit 2 small bore piping evaluations, Unit i nitrogen backup _
modifications, etc.) resulted in other items being resolved slowly as compared to their
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safety significance.' These included resolution of a possible unreviewed safety question .
.and incorrect steam generator tube rupture analysis design assumptions. This Severity i Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of )
the NRC Enforcement Policy and is addressed in the corrective action program as CR j 99249 '
E8 Miscellaneous Engineering issues E Elevated Reactor Coolant Averaae Temoerature above Proaram Values l 'nspection Scope (92903)
The inspectors reviewed condition reports, an engineering memorandum, nuclear steam supply system (NSSS) vendor evaluations, and a safety evaluation associated with plant operation above reactor coolant average temperature (Tave) program values during reactor startup to verify that the units were not being operated outside their design base Observations and Findinas j Backaround ,
Prior to placing the main turt>ine on line, the steam dump system is used to remove the j heat from the reactor coolant system. The system is controlled during startup by 4 manually selecting a desired steam generator pressure. The licensee's operational strategy was to maintain a constant steam generator pressure from zero to approximately 18 percent power, prior to the main turbine being placed in service. This
- operational strategy effectively resulted in elevating Tave by as much as 7 degrees Fahrenheit above the normal programmed value for the corresponding reactor power level. Operation with a Tave deviation of this magnitude had not been assumed in the accident and transient analysis for the rod withdrawal even Effect on Shutdown Marain. Rod Withdrawal and Main Steam Line Break Accidents On January 21,1998, a CR was initiated which questioned whether operating with a Tave deviation at low power levels resulted in operation outside the plant design base Specifically, elevated reactor coolant temperatures resulted in a corresponding decrease in shutdown margin.- Therefore, an analysis of the available shutdown margin was required to ensure the TS minimum shutdown margin requirement was satisfied. Plant
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engineers had discussed this concern and concluded that the safety significance of this issue was low; however, the inspectors r.oted that a detailed, rigorous evaluation of the
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condition had not been performed or documented until June 25,1999, when EM 116131 was approved. The inspectors concluded the failure to perform a timely evaluation was another example of the non-cited corrective action violation discussed in Section E Nuclear engineers concluded that the units had not been operated outside of their design bases. The basis for this conclusion was a review of the UFSAR and an evaluation I provided by the NSSS vendor which determined that excess shutdown margin was l l
availabl The inspectors noted that the analysis did not include an evaluation of other accident scenarios that could be affected by the Tave deviation, such as a main steam line break accident. The licensee perfre.ed an additional safety evaluation (99-145), and determined that the elevated Tave conditions would not adversely affect the results of i the safety analysis for either rod withdrawal events or main steam line break accident l The inspectors noted that while the licensee properly concluded that the Tave deviation l was acceptable for the current cycle, this change in design inputs required evaluation for I future core reloads. Licensee personnel stated that this issue would be evaluated in future core reload analyse c. Conclusions The initial evaluation of elevated reactor coolant average temperatures above the normal programmed band during reactor startups, was not rigorous or documente Subsequent detailed evaluations were technicsy sound and confirmed that the units l had not been operated outside of the design bases of the plan IV. Plant Support P2 Status of Emergency Preparedness (EP) Facilities, Equipment, and Resources a. Inspection Scope (82701)
The inspectors observed the control room area, the technical support center (TSC), the emergency operations facility (EOF), the radiological operations center (ROC), and the operations support center to evaluate the readiness of these facilities. At each of these facilities, the inspectors performed a spot check of equipment and supply lockers to determine their conformance with NRC regulationo and the onsite emergency plan. Also reviewed were communication systems surveillances and inventories for equipment located in several of these facilitie b. Observations and Findinos The licensee has revised its method of performing offsite notification of emergency conditions by replacing the dedicated phone lines to the offsite agencies with lines using the Beaver Valley Emergency Response System (BVERS). BVERS is a computer-controlled communication system that uses an automatic dialing capability to rapidly establish a conference call between the licensee and the offsite authorities. This system, called the initial notification conference line, is supplemented by a group facsimile
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transmission function that sends printed notification of the emergency conditions simultaneously to all of the offsite agencies. The BVERS conference line verifies the agencies' receipt of the fax and orally transmits the data as a backup in the event the fax is not reliably receive The onsite emergency response facilities were maintained in a condition of readiness with the required equipment and supplies in place. Locker seals, to detect entry into the emergency supply lockers, were controlled better than during the last emergency preparedness inspection. The inspectors noted, however, that the ROC had three lockers labeled for emergency use containing equipment and supplies that were not controlled by any inventory sheets. These lockers contained dosimetry, emergency lodine air filters (silver zeolite), survey instruments, and protective clothing. The inspectors reported this item to the Emergency Planning Director, and he agreed to
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investigate these lockers and their function for possible inclusion on emergency planning inventory sheet Communication circuit testing and equipment inventories were conducted as required by the emergency plan and NRC regulations. The inspectors identified a minor procedural problem associated with communication circuit testing. The Emergency Planning Director initiated CR 991947 to investigate and correct the proble ,
' Conclusions The onsite emergency facilities were maintained ready for response to an emergenc Improvements were implemented to more efficiently make offsite notification Communication testing procedures and inventories were completed as require P3 EP Procedures and Documentation Insoection Scope (82701)
The inspectors rev:ewed revisions 10 and 11 to the Emergency Preparedness Plan, as well as several revisions made to the procedures which implement the plan. The
~ inspectors reviewed these revisions to verify their conformance with 10 CFR 50.54(q) of NRC regulations. This regulation allows licensees to make changes to their emergency plans, that do not decrease the effectiveness of the plans, without obtaining prior NRC approva ' The inspectors also reviewed selected evaluations the licensee had performed for recent changes to the emergency plan and implementing procedures. Finally, they discussed the nature of some of these changes with management representative Observations and Findinos The inspectors noted that the licensee performed effectiveness reviews for the two revisions made to the plan. These effec:iveness reviews were adequate in their documentation of the bases for the revisions. Since the licensee has determined that the
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changes do not decrease the effectiveness of the plan, prior NRC approval of these changes was not require Conclusions No deficiencies were noted in the 10 CFR 50.54(q) evaluations for the latest two emergency plan revision P4 Staff Knowledge and Performance in EP Insoection S.c_ggg (82701)
The inspectors interviewed four senior emergency response organization (ERO)
members to determine their knowledge of their duties and recent changes to the emergency preparedness program. The inspectors also observed an emergency
- scenario walkthrough and critique conducted for the on-shift ERO on the Beaver Valley Unit 2 plant simulato Observations and Findinas The four senior ERO members, two emergency recovery managers and two emergency directors, knew their duties and responsibilities. They also knew about the recent enanges made to the emergency preparedness procedures and system j Tne simulator walkthrough was conducted with a Unit 2 shift crew and included the four li:ensed operator pos!tions in the control room as well as a shift technical adviser and a communications coordinator. The crew satisfactorily performed the emergency ,
response duties required of them with one exception. The communications coordinator ;
was unfamiliar with the procedure for initiating the conference call function for making i offsite notifications. The first offsite notification of the scenario was not completed to all offsite agencies within the 15-minute time limit. Also, the call to initiate pager activation j for the onsite ERO was not mad !
The licensee critiqued the performance after the walkthrough and determined that the communi s coordinator was not proficient with the equipment or procedures used for offsita cy notification and for onsite ERO paging. The Emergency Planning
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Director initiated CR 991967 to document the problem and pursue evaluation and corrective action. The emergency planning department tested other communications coordinators on other shifts to determine if the problem was widespread. Initial results were that the problem was limited to the one individual, but the investigation was continuin Conclusions -
The program for training the senior Emergency Response Organization members was effective as demonstrated by the four responders interviewed who showed excellent knowledge of their duties and responsibilities. There was an indicated need for better
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i training of an onshift communications coordinator based on the observed emergency scenario walkthrough. The efforts to determine the extent of the problem and possible corrective actions were timel P5 Staff Training and Qualification in EP a. Inspection Scope (82701)
The inspectors evaluated the effectiveness of the EP training program for the ERO. The inspectors utso reviewed the list of qualified ERO responders to verify that they were qualified in accordance with station procedure l Observations. Findinas and Conclusio_n_s The training and qualification of ERO members were effectively tracked and maintaine )
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An audit of qualifications for the current ERO list showed no qualification discrepancie P6 EP Organization and Administration
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a. Inspection Scope (82701)
The inspectors interviewed EP management on the changes made to the EP program since the last inspection as well as planned changes resbiting from the upcoming merger of the station with the First Energy Nuclear Operating Company (FENOC). The inspectors also discussed EP staff changes with the EP Directo b. Observations and Findinos The EP Director informed the inspectors that, as a result of retirements, he had lost two persons from his organization. One position was filled by one of the EP irstructors i7 the Nuclear Training Department. This individual was knowledgeable in the radiological protection and assessment functions in EP and is a qualified senior ERO member. The EP Director plans to compensate for the loss of the other position by realignment of the duties of his staff to make it more efficien The upcoNiIg merger of the station with FENOC is scheduled to be in place by the beginning of December of this year. The EP Director has planned for transfer of services currently being provided by Duquesne Light Company to FENOC or other entities. He is a member of a transition task force which includes other FENOC EP managers, and meets periodically to discuss challenges and success strategies for the transition. Both the EP Director and the Manager of Management Services are aware that they need to communicate with the site human resources department to anticipate and compensate for the effect of any personnel changes on the emergency response roster "
14 Conclusions l
The EP organization management is aware of the challenges presented by recent and
. upcoming changes in the licensee organization and is preparing adequately for the P7 Quality Assurance in EP Activities Insoection Scope (827011 Observations and Findinas The inspectors reviewed the Quality Services Unit (QSU) audit reports (report numbers BV-C-98-03 and BV-C-99-03) of the EP program for calendar years 1998 and 1999 and interviewed the lead auditor. The audit met all regulatory requirements of 10 CFR 50.54(t) of NRC regulations, and the audit and its attendant report continued to be comprehensive, organized and detaile The inspectors noted that the lead auditor, by virtue of her ERO position, is responsible i for the maintenance of the offsite Joint Public Information Center and Alternate EOF. As part of this responsibility, she performs communication testing of telephone circuits at these facilities. The inspectors questioned whether this role afforded sufficient independence from the responsibility for implementation of the EP program as required by 10 CFR 50.54(t) of NRC regulations. After discussion with the lead auditor about the nature of her roles and the conduct of the annual audits, the inspectors concluded that
. there was sufficient independence between the auditor's implementation and independent oversight roles. This conclusion was based on the fact that other auditors inspected the area in which the lead auditor had responsibilities and their signatures were on the audit report indicating their agreement with its contents. The inspectors ;
concluded, however, that the lead auditor's EP responsibilities created additional I administrative burden on the QSU to show compliance with NRC regulations. They discussed this item with QSU management at the exit interview. The licensee intended .
to discuss this matter further for resolution and entered this into the corrective action i program (CR 991980). Conclusions The licensee's annual EP program audits were comprehensive, organized, and detaile Y._Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the
- conclusion of the inspection on September 10,1999. The licensee acknowledged the findings presented. The licensee did not indicate that any of the information presented at the exit meeting was proprietar I
15 l lNSPECTION PROCEDURES USED IP 37551: Onsite Engineerin IP 61726: Surveillance' Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 82701 Operational Status of the Emergency Preparedness Program IP 92903 Followup - Engineering ITEMS OPENED, CLOSED AND DISCUSSED Opened / Closed -
50-412/99-05-01 NCV Improper Operator Troubleshooting (Section 01.2)
50-334(412)/99-05-01 NCV Failure to Promptly Evaluate and Correct identified Engineering Deficiencies (Section E2.2 and Section E8.1)
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LIST OF ACRONYMS USED l ANSS Assistant Nuclear Shift Supervisor l
BVERS Beaver Valley Emergency Response System CATS Commitment Action Tracking System C Condition Report
.EDG - Emergency Diesel Generator L EM Engineering Memorandum EOF Emergency Operations Facility EP: Emergency Preparedness ERO Emergency Response Organization FENOC' First Energy Nuclear Operating Company l
l&C - Instrumentation and Control NCV- Non-Cited Violation NRC Nuclear Regulatory Commission NSS . Nuclear Shift Supervisor NSSS Nuclear Steam Supply System
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OM Operation Manual
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OST Operational Surveillance Test l PM Preventive Maintenance . !
PRT' Pressurizer Relief Tank - l QSU Quality Services Unit !
ROC Radiological Operations Center l SE System Engineer l Tave Reactor Coolant Average Temperature TER Technical Evaluation Report TS . Technical Specification
'TSC Technical Support Center UFSAR Updated Final Safety Analysis Report USQ Unreviewed Safety Question ,
WO Work Order