IR 05000334/1979027
| ML19323E873 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/28/1980 |
| From: | Beckman D, Mccabe E, Rhodes G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19323E857 | List: |
| References | |
| 50-334-79-27, NUDOCS 8005270344 | |
| Download: ML19323E873 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION I
Report No.
50-344/79-27 Docket No.
50-334 License No.
DPR-66 Priority Category C
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Licensee:
Duquesne Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Facility Name:
Beaver Valley Power Station, Unit 1 Inspection At:
Shippingport, Pennsylvania Inspection Conducted:
Decamber 19, 1979 through January 11, 1980 Inspectors:
C 0. A %. b theNo D. A. Beckman, Resident Inspector date e.c./L W h.
alztlh G. G. Rhoads, Reactor inspector date
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date Approved by:
f,C. b M
'2.h.P /#'o E. C. McCabe, Chief, Reactor Projects date Section No. 2, RO&NS Branch Inspection Summary:
Inspections on December 19, 1979 to January 11, 1980 Report 50-334/79-27)
Areas Inspected:
Routine resident inspector review (49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />) of:
Action on previous inspection findings; plant operations; IE Bulletin followup; Physical Protection / Plant Security; and review of a plant modification.
Results:
Two items of noncompliance were identified (Deficiency - Inadequate implementation of radcon instrument control procedures, paragraph 5.d; and Deficiency - Failure to maintain records of surveillance testing, paragraph 1).
80052703k Region I Form 167 (August 1979)
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DETAILS 1.
Persons Contacted G. Beatty, QA Engineer R. Balcerek, Nuclear Engineering and Refueling Supervisor J. Carey, Director of Nuclear Operations C. Ewing, QA Supervisor W. Glidden, QA Engineer
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R. Hansen, Maintenance Supervisor J. Koslmal, Radcon Supervisor A. Lonnet, Associate Engineer R. Prokopovich, Reactor Engineer L. Schad, Operations Supervisor J. Sieber, Superintendent, Licensing and Compliance J. Starr, Station Engineer J. Werling, Station Superintendent D. Williams, Results Coordinator H. Williams, Chief Engineer The inspector also interviewed other licensee personnel during the course of the inspection.
2.
Licensee Action on Previous Inspection Findings (0 pen) Unresol;ed Item (79-12-02):
Nonconservative Type C Local Leak Rate
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Test Results. The item addressed the need to account for the minimum sen-sitivity of test measurement methods in the total containment leak rate (La) when the indicated local leak rate test results are zero.
The inspec-tor reviewed Operating Manual Change Notice (OMCN) No.79-100, issued on
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August 28, 1979 which revised Operating Surveillance Test (OST) 1.47.4 to require use'of the minimum sensitivity value of the test equipment as the measured leak rate if the indicated leak rate is zero.
This action satis-factorily addresses the above portion of the item.
This unresolved item also addressed the need for additional verification of test boundary leak tightness when the " downstream measurement method" of valve leak rate testing is used.
OMCN 79-100 revised the leak rate testing procedure to require verification of boundary valve position to ensure that no other leakage paths out of the test volume exist.
Review of this technique by the inspector could not account for quantification or identification of seat leakage through test boundary valves which could noncontervatively indicate reduced leakage through the valve under test.
The Operations Supervisor was informed that, if the downstream measurement method is to be considered valid, measures must be taken to either cap or blank poten-tial leakage paths or to measure all leakage out of the downstream test volume.
In the absence of eith?r or both the above measures, only the
upstream measurement method can be considered valid.
The Operations Super-
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visor acknowledged the inspector's comments and stated that the matter would receive additional licensee review.
This item will remain open pending NRC review of subsequent licensee actions.
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(Closed) Inspoctor Follow Item (79-12-03):
Incorporation of individual valve leakage rate acceptance criteria into Type C local leak rate test procedures per ASME XI, Paragraph IW 3420(f).
OMCN 79-100, issued August 28, 1979 incorporated requirements to OST 1.47.4 for review of actual valve leak rates following each test with each valve's previous trend data.
On the basis of that review, the Operations Supervisor and Maintenance Supervisor are required to determine what, if any, maintenance, is required for each valve and to determine if each valve meets the cri-teria of ASME XI cited above.
Although the procedure (OST 1.47.4) does not provide specific, individual valve acceptance criteria, the above guidance and the provisions of ASME XI appear to result in compliance with the stated code requirements by calculation of individual valve acceptance criteria for each test performance.
This matter was discussed with the Operations Supervisor on December 26, 1979 at which time the inspector co'1 firmed that the licensee was aware of the need to apply the acceptance criteria directly from ASME XI to each valve to ensure compliance.
The inspector further informed the Operations Supervisor that the possibility of inadvertant noncompliance with ASME XI due to oversight could be increased by the lack of individual acceptance criteria.
The licensee acknowledged the inspector's comments.
(0 pen) Unresolved Item (79-12-06):
Control of air lock door bypass leakage.
In order to establish containment integrity, manual isolation valve 1-VS-53
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must be maintained leak tight and shut during plant operation.
The inspec-tor determined that the subject valve had been added to OST 1.47.1, Air Lock Leak Test, via OMCN 79-99, to ensure that the valve is properly posi-tioned during and after each periodic leak test.
The licensee has not yet added provisions to the air lock annual Type B test procedure.
These procedure revisions are pending air lock modifications which are being installed during the current outage.
Pending revision to the above pro-cedure and subsequent NRC review, this item will remain open.
(Closed) Deficier.:y (79-12-09):
Failure ~to implement Local Leak Rate Test
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Procedures.
The inspector reviewed the implementation of corrective action
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(as stated in the DLC letter of September 4,1979) including control room records of Type B and C leak rate test results and the " Current Leakage Totals" as recorded on Test Forms C2-1 and C2-4.
This data reflected incorporation of test data from testing conducted in accordance with OST 1.47.29, Penetration #38 Type C Leak Test, performed on August 15, 1979.
Test Form C2-1 was noted to have previously had an incorrect date for the last performance of the reference test which had been corrected by the licensee.
The Shift Operating Foreman responsible for coordination of such testing stated that no additional retests have been performed on the subject penetratior since the August 15, 1979 test.
The data for OST 1.47.83, Personnel Airlock Type B Test, performed on August 10, 1979 was also confirmed to have been entered in the forms as noted in the DLC letter above. With regard to the licensee's commitment for action to prevent recurrence, the inspector confirmed that OST 1.47.4, Containment
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Isolation Valve Leakage Test, Type C, Revision 22, dated November 7, 1979, now requires Nuclear Services QC and maintenance technician signature veri-fication of calibration of test equipment prior to each performance.
No tests have been conducted in accordance with the procedure since the date of noncompliance.
Additionally, consistent with the DLC letter of September 4,1979, the Operations Supervisor on September 7,1979, issued letter no. B'.:PS: LGS:59, which reiterates policy and practices for verifying completion of a procedure action.
(Closed) Unresolved Item (79-16-08):
Operations Department to implement a periodic review cycle for departmental letters pertinent to plant ope-ration.
The inspector reviewed a package of selected Operations Depart-ment letters which had been routed to all Shift Supervisors for review
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during October - November 1979.
The Operations Supervisor provided the inspector documentation of the completed reviews.
Recurrent annual reviews
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have been incorporated in the facility's computer scheduling program.
The letters selected for the 1979 review included these issued during the period of March 17, 1979 through May 18, 1979.
The inspector considered the letters selected for review to be appropriate and had no further questions on this matter.
(0 pen) Deviation (79-20-01):
Failure to implement corrective action for lost surveillance documentation per DLC response to Deficiency 79-04-01.
The inspector reviewed the corrective action as stated in the DLC letters of April 5 and November 23, 1979 and found the actions to have been imple-mented as stated.
During this inspection, the efficacy of the preventive action implemented was discussed with the Nuclear Engineering and Refuel-ing Supervisor, who had been responsible for maintenance activities during the time of the previous findings, and with the current Maintenance Super-visor, who had been appointed to the position in December 1979.
On the basis of these discussions, the inspector determined that, although the documented preventive action appeared to address the finding, additional measures appeared necessary to prevent recurrence.
As a result of these discussions, the incumbent Maintenance Supervisor committed to imple-ment a departmental records control policy which will require all Mainte-nance Surveillance Procedure or Calibration Procedure records to be main-tained under the control of the Maintenance Department clerk until all required supervisory reviews are completed.
Subsequent to completion of these reviews, the records will be copied for routine distribution and forwarded for archival storage.
The Maintenance Supervisor stated that this policy will be placed in effect about February 4, 1980 under the general provisions of the BVPS Maintenance Manual, Appendix A, Section 15.
Similar controls will be established by revision of existing procedures on or before March 30, 1980. The inspector acknowledged the above licens-ee commitments and confirmed the Superintendent's concurrence with it.
This item will remain open pending NRC review of the licensee's committed actions.
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(Closed) Unresolved Item (79-20-04):
Licensee to provide data from OST 1.11.1 performed on September 10, 1979 for inspector review and take addi-tional actions to ensure that records of surveillance testing which docu-ment deficiencies are maintained.
On September 10, 1979, deficiencies in flow of the 1A Low Head Safety Injection Pump were identified as a result of performing OST 1.11.1 (further discussed in IE Inspection Report No.
79-20).
The licensee was unable to provide the inspector with the record copy of OST 1.11.1 on which the flow deficiencies were documented.
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ther review by the licensee and inspector determined that the subject procedure and associated data were lost during plant staff review of the data.
On January 8, 1980 inspector reviewed the control room surveillance test files, the station Document Control Room Files, and periodic record transmittal data sheets for the period of September - October 1979.
No evidence of the subject test records having been entered into the plant records appears to exist.
Failure to maintain records of surveillance testing required by Technical Specifications is contrary to Technical Specification 6.10.1.d and constitutes an item of noncompliance (79-27-01).
In response to previous inspector concerns, the licensee issued a Special Operating Order, OST Documentation Retention, dated September 14, 1979 which identifies existing requirements in the BVPS Operating Manual (OH)
Chapter 1.S5A for documentation and retention of aborted or unsuccessful l
surveillance test data.
The inspector verified that this Special Operat-
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ing Order was promulgated to all onshift personnel and was posted conspi-
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cuously in the Shift Supervisor's office from the date of issue through December 19, 1979.
The inspector additionally performed a sampling review of approximately 25 OST files to determine whether aborted or unsuccess-ful test records were being retained.
The inspector found that such data is being retained in the plant records on a routine basis.
On the basis of the above action by the licensee and the corrective action for degraded LHSI pump flow discussed in the inspec-tion report referenced above, no response to this item of noncompliance is required.
(Closed) Unresolved Items (79-22-07 and 79-22-08):
DLC to issue supple-mental reports for LER 79-29/03L and Special Report - Fire Main Rupture.
During an exit interview for IE Inspection No. 50-334/79-22, the Superin-tendent verbally committed to issue the subject supplemental reports on or before December 7, 1979.
The reports were requested by the inspector to provide additional, clarifying data not originally included in the reports. On December 19, 1979, the inspector informed the Superintendent that the subject reports had not yet been issued and requested that issu-ance be expedited.
The Superintendent stated that the commitment to issue the reports had been inadvertantly overlooked due to the existing station workload and an in process station reorganization cich reassigned the report preparation to a different individual than was previously assigned.
The Superintendent also stated that, as of December 19, 1979, the station
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staff had not yet received IE Inspection Report No. 50-334/79-22 which docmented the commitment, contributing in part to the oversight.
The inspector emphasized the need to pursue all commitments made to the NRC unless specific relief from the commitment is arranged with the NRC repre-sentative involved.
The supplemental licensee reports were issued on January 7 and January 11, 1980 respectively.
(0 pen) Unresolved Item (79-24-02):
Review implementation of action taken to prevent recurrence of LER 79-26/03L.
This licensee event involved the attempted calibration of a reactor protection instrument with superceded calibration data.
Revision of maintenance procedures to ensure that only current pro edures and data are available at work locations was in progress and previously scheduled for completion by January 4, 1980 as discussed in IE Inspection Report No. 50-334/79-24.
In December 1979, a new station Maintenance Supervisor was appointed who, upon review of the information associated with this event, chose to increase the scope of the action taken to prevent recurrence and requested an extension of the above commitment to February 8, 1980.
The Maintenance Supervisor committed to implement compensatory measures on an interim basis to ensure that maintenance pro-cedures are properly controlled until such time as the formal procedure revisions are issued.
This item will remain open pending review of the above licensee actions.
At the close of this inspection, the Maintenance Department has required, on a interim basis, that all procedures issued for field use be obtained from the cognizant maintenance procedure engi-neer, thus providing additional assurance that only current procedures are available to working crafts.
(Closed) Unresolved Item (79-23-02):
Review remedial training implemented for a licensed individual delinquent in Operator Requalification Training assignments.
IE Inspection Report No. 50-334/79-23 documented verbal commitments made by the Superintendent on October 22, 1979 regarding com-pletion of specific remedial training for the delinquent individual by November 15, 1979.
On January 4, 1980, the Superintendent informed the inspector that, due to an apparent misunderstanding of the commitment, the training had not yet been completed as stated in the report.
This apparent discrepancy had been identified to the Superintendent by the Training Coordinator upon his receipt of the referenced inspection report.
Station management stated, on January 4, 1980, that the subject training would be completed on that date.
On January 11, 1980, the inspector reviewed the training records for the involved individual and determined that the training commitment had been fulfilled as stated on January 4, 1980, including:
attendance at training lectures and completion of post-lecture quizzes in the individual's areas of demonstrated weakness; com-pletion of self-study guides which were identified as delinquent; and com-pletion of study guides issued subsequent to the date of the original finding.
The inspector again reemphasized the need to clearly establish a mutual understanding of the scope and schedule for any commitments dis-cussed with NRC representatives.
The Superintendent acknowledged the
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inspector's comments and requested that representatives of NRC:RI take additional effort to ensure a clear understanding of their positions regarding commitments exist prior to closing conversations with licensee representatives.
The inspector informed the Superintendent that his request would be pursued to the extent practical but that facility manage-ment retained the responsibility for commitments to which they have agreed.
(0 pen) Unresolved Item (79-24-05):
Review implementation of fire barrier integrity program and revisions to associated surveillance procedures.
The inspector reviewed BVPS OM Chapter 1.56B, Fire Prevention and Control, Issue 1, dated December 31, 1979, including Section 1.568.4, Implementation Procedures, and Appendix A to 1.568, Fire Area Tables and Figures.
The procedures were reviewed to establish that identification and control of fire barriers and fire doors are established.
The inspector further con-firmed that the procedures provide for definition of barriers, periodic surveillance, and control of fire doors.
The procedures as issued appear to adequately identify safety-related areas and pictorially depict the boundaries of fire areas and zones.
As part of the identification effort, the licensee has posted tnose doors identified as fire barriers with signs that provide instructions for maintaining the doors closed.
The Senior Safety Engineer further stated that a specific list of fire barrier doors will be incorporated into logs and surveillance procedure (s) for periodic verification of integrity.
This matter will remain unresolved pending completion of the above activities.
3.
IE Bulletin Followup a.
The inspector reviewed licensee actions taken in response to the fol-lowing IE Bulletins (IEBs) in order to determine that the written response was submitted within the required time period, that the response included the information required including adequate correc-tive action commitments, and that licensee management had forwarded copies of the response to responsible onsite management.
The review included discussions with licensee personnel and observe; ions and review of items discussed below.
IEB 79-02 - Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts:
Revision 2 to IEB 79-02 was issued on November 8, 1979 and addressed, in part, requirements for licensee review of expansion anchor bolts used in concrete block (masonry) walls.
The licensee's letter, dated December 6, 1979, stated that such installations will be evaluated utilizing allowable anchor bolt loads which are to be determined by extrapolating the bolt manufacturer's recommended ulti-mate values to the required compressive strength for the concrete block used in the walls and applying the appropriate safety factors.
As a result of an NRC task force review of that licensee submittal, the inspector informed the DLC Superintendent of Licensing and com-pliance on January 7, 1980 that the methods of evaluation discussed l
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in the DLC letter appeared to be unacceptable.
NRC tesk force review determined that extrapolation of manufacturer's data appears inappro-priate due to the lack of correlation between the data, generally used for reinforced concrete structures, and the actual installations in block walls.
The inspector requested that the licensee reevaluate
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the position stated in the December 6, 1979 letter and provided a
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revised response which either justifies the above position or which provides an alternative, acceptable method of evaluation.
At an exit
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meeting on January 11, 1980, the Superintendent of Licensing and Com-p11ance acknowledged the above NRC comments and stated that a revised response would be prepared as soon as practicable.
The present licens-ee schedule for IEB 79-02 activities requires completion of all evalua-tions and any resulting plant modifications or repairs prior to the station restart (scheduled for July 1980).
The licensee stated that this matter will be pursued with the facility architect engineer on an expedited basis and the results will be directed to the NRC on a
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time frame to ensure resolution prior to station restart.
This matter i
will remain unresolved pending receipt of the above information in
writing from DLC (79-27-02).
IEB 79-03 - Longitudinal Weld Defects ~in ASME SA-312 Type 304 SS Pipe Spools Manufactured by Youngstown Welding and Engineering Co.:
The inspector reviewed the licensee's response to IEB 79-03, dated April 11, 1979, which stated that no pipe of the type described in the IEB had been used in safety related systems at BVPS-1.
Discussions with the Senior Compliance Engineer indicated that the basis of this determina-tion was a review of " Pipe Specification, Class 153A" which stated that al' stainless steel piping would be procured to specifications
which ad not include ASME SA-312, Type 304 SS piping.
At the close of this inspection, piping procurement and receipt inspection records
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were being identified and retrieved at the inspector's request to pro-vide documentary evidence that no such piping had actually been pur-chased and/or received onsite from either principal contractors or
subcontractors.
The IEB will remain open pending completion of the
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above inspection activities (79-BU-03).
IEB 79-10 - Requalification Program Statistics:
The DLC letter, dated May 23, 1979, issued in response to the subject IEB was reviewed by the inspector and determined to include the information required.
The inspector reviewed the development of the supplied data with the station Training Coordinator and performed a sampling inspection of training records in order to substantiate the data provided in the licensee's letter.
The inspector had no further questions on th~s matter.
IEB 79-14 - Seismic Analysis for As-Built Safety Related Piping Sys-tems:
As of November 2,1979, NRC:NRR had completed technical reviews of DLC submittals in response to IEB 79-14 which are dated July 30,
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g September 11, and September 27, 1979.
NRC:RI has additionally reviewed a subsequent licensee submittal dated October 30, 1979.
As a result of these NRC reviews, the inspector held discussions with the DLC Director of Nuclear Operations and Superintendent of Licensing and Compliance on January 7 and January 11, 1980 in order to clarify the scope of piping inspections being performed by DLC pursuant to the IEB.
The DLC submittals of July and September 1979 indicate that all piping within containment was not to be inspected in accordance with IEB requirements.
The OLC submittal of October 30, 1979 stated that portions of the piping within containment had been inspected previously as part of the' activities associated with seismic reanalysis pursuant to an NRC Show Cause Order issued on March 13, 1979.
These inspections, although not as detailed as the current IEB 79-14 effort, are considered
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by DLC to be adequate to permit use of the results to satisfy the c
requirements of IEB 79-14.
The October 30, 1979 letter further states that these previously inspected lines will be reviewed to ensure their acceptability.
The discussions with the DLC representatives above indicated that all piping in containment not previously inspected but subject to the requirements of the IEB will be inspected in accord-ance with current procedures.
The inspector requested the licensee to sutmit a supplemental response to the bulletin clarifying the positions taken in the previous submittals and detailing the above position as soon as practicable.
The Director of Nuclear Operations stated that such a submittal would be made on a time frame consistent with the licensee's schedule for completion of IEB 79-14 inspections and the resulting engineering evaluations or plant modifications.
The inspector requested the licensee to expedite the resolution of the above NRC comments to avoid any potential impact on the plant outage and restart schedule.
This matter will remain unresolved pending receipt of the supplemental submittal (79-27-03).
IEB 79-17 - Pipe Cracks in Stagnant Borated Water Systems at PWR Plants:
The licensee response to this IEB by letters to NRC:RI dated August 28, 1979, October 29, 1979, and January 3, 1980.
The inspec-tor reviewed Inspection Procedure NSD-ISI-90, Manual Ultrasonic Pro-cedures for Investigating for Presence of Intergranular Corrosion, various revisions.
This procedure was developed and implemented by the licensee's inservice inspection contractor specifically h meet the requirements of-IEB 79-17.
During inspector review, quc.,tions regarding the acceptability of inspection techniques including equip-ment calibration and frequency settings were identified.
These ques-tions have been referred to NRC:RI for further review, including a copy of the subject procedure and associated correspondence.
Review of Table I of the licensee's January 3, 1980 submittal revealed that only 17 of 19 welds on safety injection line 12"-SI-5-153A-Q2 had been visually inspected with no reason given for excepting the remain-ing two welds.
Inspector review of Nuclear Services Quality Control
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General Inspection dated December 4, 1979 and Maintenance Work Request No. 797243 indicated that the two excepted welds were identified and listed as uninspectable due to their imbedment in concrete.
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The inspector informed the Station Superintendent and his staff that this bulletin would be subject to further NRC inspection.
The accept-ability of the ultrasonic test technique discussed above will remain unresolved pending additional NRC review (79-27-04).
IEB 79-24 - Frozen Lines:
The inspector reviewed the licensee's response to IEB 79-24 dated November 1, 1979.
Inspection of the licensee's activities in this regard were still in progress at the close of this inspection.
The inspector confirmed that a Cold Weather Bill has been issued as stated in the above letter.
NRC review of the implementation of the Cold Weather Bill and its acceptability will be completed during the next inspection period.
The IEB will remain open pending completion of these inspection activities (79-BU-24).
IEB 79-23 - Potential Failure of Emergency Diesel Generator (EDG)
Field Exciter Transformer:
The licensee's response to NRC:RI, dated October 24, 1979, stated that connections of the type described by the IEB as being prone to cause exciter failures do not exist in the BVPS-1 equipment.
The inspector reviewed documentation which veri-fled that the subject connections did not exist at BVPS.
The EDG testing required by the IEB was conducted on both generators on
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December 11-12 and 21-22, 1979 in accordance with Beaver Valley Test No. 1.1-2.36.1, Revision 0.
The inspector noted, upon review of that procedure, that the licensee had performed the tests on both diesel generttors using the one-half hour load rating for the units vice the two hour rating as discussed in IEB 79-23.
Discussion with licensee personnel indicated that the units do not have a specified two hour racing as confirmed by the inspector's review of the BVPS FSAR and vendor technical manuals.
The inspector determined that the test results were acceptable on the basis of data review and use of the plant specific load ratings actually used.
During review of test data, the inspector noted that procedure steps had not been consistently initialed signifying completion of the steps.
This was brought to the attention of the Technical Supervisor - Nuclear who immediately issued Memorandum (No. BVPS:RTZ:23, dated January 11, 1950) to all station test engineers reemphasizing existing require-ments for documenting the completion of procedure steps as each is completed.
Review of test data and narrative test logs confirmed that all procedure steps had been satisfactorily completed, includ-ing those without initials.
The licensee's actions in this regard were found to be acceptable.
The inspector 5d no further questions regarding this IEB.
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IEB 79-28 - Possible Malfunction of NAMCO Model EA-180 Limit Switches at Elevated iemperatures:
The inspector reviewed the licensee's response to the IEB dated January 4, 1980 which stated that no switches of the type and vintage discussed by the IEB were installed or located in the company stock system.
The inspector confirmed by inspection of switches and review of records that all switches installed in plant systems, in the stock system, or available as shop spares were not manufactured during the period noted in the IEB.
The inspector interviewed Stores Department personnel and determined that the individuals were know'edgeable of the notential problem dis-cussed by the IEB and were aware of the informat ion contained in an internal memorandum forwarded by licensee management to alert them to the matter.
Based on the foregoing, the licensee's actions appeared acceptable.
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The following IEB's had been forwarded to the licensee for informa-tion only and required no specific action.
The inspector confirmed that the bulletins had been received by licensee manage.nent, that a review of applicability had been performed, and that no further action was required.
The following bulletins were reviewed:
IEB 79-05/05A/05B - Nuclear Accident at Three Mile Island;
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IEB 79-12 - Short Period Scrams at BWR's; and,
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IEB 79-26 - Boron Loss from BWR Control Blades.
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No items of noncompliance were identified.
4.
Review of Design Changes / Modifications The inspector reviewed activities associated with the preparation and implementation of Design Change No. DPC-0130, Auxiliary Feedwater System Recirculation Line Modification to establish that the required aspects of the licensee's Operations Quality Assurance Program have been and are being implemented.
During this inspection, installation of the modification was in progress concurrent with engineering design.
The inspector reviewed the following references associated with DCP-0130-l DCP-0130/BVPP No. 25.2, Mechanical Installation for Auxiliary Feed-
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water Recirculation Modification; DCP-0130/BVPP No. 15.2, Electrical Installation for Auxiliary Feed-
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water Recirculation Modification; DCP-0130/BVPP No. 27, Pressure Test for Auxiliary Feedwater Recircu-
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lation Modification;
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TS-1, Duquesne Light Company Hydro Procedure for Feedwater Recircu-
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lation Modification; Construction Division Nuclear (CDN) Procedure No. 3.24, Installation
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of Concrete Anchor Bolts, Revision 1; CDN Procedure No. 3.26, Core Drilling;
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Schnieder Project Procedure Manual, Section 3.6, Control of Modifica-
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tion Activities; DLC Quality Assurance Operating Procedure OP-4, Station Design Control;
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DLC Quality Assurance Operating Procedure OP-10, Maintenance and Modification Planning; Engineering Management Procedure (EMP) 2.7, Requests for Station
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Modifications; EMP 2.8, Handling of Design Change Packages;
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Statica Engineering Procedure No. 2.10, Station Engineering
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Transmittals; DLC Quality Assurance Procedure OP-3,' Administrative Controls,
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ANSI N45.2.6-1973, Qualification of Inspection, Examination, and
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Testing Personnel for the Construction Phase of Nuclear Power Plants; ANSI N45.2.3-1973, Housekeeping During the Construction Phase of
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Nuclear Power Plants.
The inspector reviewed the above references, toured associated work areas, and observed work in progress to establish that:
Administrative centrols were applied to the removal and return to
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service of the systems involved; Work procedures included quality control hold points for inspection,
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audit, and signoff by inspection personnel; Appropriate housekeeping controls were implemented in all work areas;
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Provisions are established for cleaning of safety-related system
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components following maintenance and modification activities; Provisions exist for assuring that system / valves and breakers are
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aligned for normal service following maintenance and modification activities;
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Responsibilities are identified for reporting to licensee management
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the details of any design or construction related deficiencies iden-tified during the maintanance and modification activities;
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Provisions exist for testing the modified system upon completion of
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installation; Installation procedures are available and are adequate for the iden-
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tified function (s);-
Inspection personnel and persons performing special processes possess
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the appropriate qualifications required by the 0QA program;
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i Administrative controls for design document control have been estab-
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lished and implemented; Field changes are being controlled in accordance with the require-
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ments of the 0QA program.
The inspector's review determined that the above provisions were addressed in the procedures and documentation reviewed.
The inspector also observed work in progress to verify that it was being completed in accordance with approved procedures, using approved drawings, and being performed by qua-
lified personnel. Work observed included the installation of concrete expansion anchor bolts for pipe supports and the welding of a hanger. base-plate.
Personnel qualification recoids were reviewed to verify the quali-fications of the welder and quality control inspector assigned to these tasks.
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During review of the Design Change Package, the inspector noted that the
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change had apparently not yet been reviewed in accordance with the require-ments of 10 CFR 50.59 to establish that no unreviewed safety que:tions exist.
This review must be acmpleted prior to preoperational testing as required by the OQA prcgram.
7he inspector also noted that changes to operating procedures had not yet been initiated.
Station Engineering Pro-cedure No. 2.10 provides the requirements and accountability for complet-ing such changes.
On the basis of that program, the inspector had no further questions at this time.
I No items of noncompliance were identified.
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4.
Shift Log and Operating Records a.
Logs and operating records were reviewed to pursuant to the licensee's administrative procedures to verify that:
log sheet entries are filled out and initialed;
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log entries involving abnormal conditions are sufficiently
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detailed to communicate equipment status, lockout status, cor-rective action, and restoration; log book reviews are being conducted by the staff;
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operating orders and temporary procedures do not conflict with
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the Technical Specifications; jumper log entries do not conflict with Technical Specifications;
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and, logs and records are being maintained in accordance with Tech-
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nical Specifications and the procedures below.
b.
Acceptance criteria for the above review included inspector judgement, the requirements of the applicable Technical Specifications, and the following procedures:
BVPS Operating Manual (0M) Chapter 48, Conduct of Operations;
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OM 1.48.3, Section H, Temporary Procedures;
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OM 1.48.5, Section D, Jumpers and Lifted Leads;
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OM 1.48.6, Clearance Procedures;
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OM 1.48.8, Records; and,
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OM 1.48.9, Rules of Practice.
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The following logs and records were reviewed for the periods indicated; c.
G1-1 (Superintendent's Daily Record), S1-1 through S1-9 (Shift
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Operating Reports), L1-1 through L1-5 (Reactor Operator Log),
L5-13 through L5-15 (Surveillance Verification Log) for the periods December 19-31, 1979 and January 7-11, 1980.
Logs S1-1 through S1-3 were also reviewed for the period January 1-10, 1980.
Jumper and Bypass Log Entries for the period from December 19,
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1979 through January 3,1980.
Selected Clearance Log entries active up to and including
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January 3, 1980.
Equipment Clearance Permits Nos. 417049, 417044, and 417074, their associated Switching Orders and tag-l outs were reviewed in detail and posting of tags verified.
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Records of selected Operating Surveillance Tests and Maintenance
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Surveillance Procedures were reviewed to establish that the sur-veillances required for concurrent pl_ ant operating modes were performed when and as required.
The following tests were reviewed
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on January 3, 1980:
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OST 1.10.1, RHR Pump Performance Test, Revision 5, per-formed December 8, 1979.
OST 1.10.3, RHR System Monthly Valve Exercise and Posi-tion Verification, Revision 8, performed December 24, 1979.
OST 1.10.4, RHR System Refueling Valve Exercise, Revision 3, performed December 11, 1978.
MSP 10.01, RHR Automatic Isolation and Pressure Interlock Test, Channel III, Revision 0, performed December 14, 1978.
MSP 10.02, RHR Attomatic Isolation and Pressure Interlock Test, Channel II, Revision 0, performed December 15, 1978.
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Except as noted below, inspection results were acceptable.
During review of the Equipment Clearance Permits noted above, the inspector observed that Switching Order Numbers and other information pertinent only to personnel or records identification (such as titles)
were not consistently referenced on the Equipment Clearance Permit forms.
This matter was referred to the Operating Supervisor on January 3,1980 for his action.
The Operating Supervisor reiterated the need for proper form completion in his night orders to on-shift personnel for January 3, 1980.
5.
Plant Tours a.
Inspection tours of selected plant areas were conducted on the dates noted below on both day and night shifts.
The acceptance criteria for tour observations, unless otherwise noted, were as follows:
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BVPS Unit 1, Systems Valve Lists and Valve Operating Drawing
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Markups;
OM 1.48.5, Safety Related Systems, Valves, and Equipment;
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MM Chapter 1, Section J, Housekeeping;
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MM Chapter 1, Section H, Cleaning and Maintenance Cleaning;
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SAD 25, Housekeeping and Cleanliness Procedure;
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BVPS Radcon Manual, Various Sections;
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Technical Specifications; and,
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Inspector Judgement.
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b.
The areas toured are:
December 20, 1979 Safeguards Pump Area
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(Night Shift)
West P',;e Tunnel Primary Auxiliary Building (PAB)
722' and 735' Levels January 3, 1980 Control Room
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Vital Switchgear Rooms Main Steam Valve Room January 4, 1980 PAB - All levels (except Locked High
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Radiation Areas and Loose Surface Contamination Areas)
Safeguards Pump Area East and West Pipe Tunnels Penetration Areas January 7, 1980 PAB/ Safeguards Area
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January 8, 1980 North and South Yard Areas
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Guard House Protected Area Perimeter Turbine Building Feedwater Regulating Valve Room January 10, 1980 Control Room
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In addition to the above, the inspector visited the control room on a daily basis during the normal work week and made general observa-tions of activities in progress and plant status.
c.
The following observations were made:
(1) Control room monitoring instrumentation and controls were observed to verify that instrumentation and systems required to suppcrt Mode 5 (Cold Shutdown) operations were in confor-mance with Technical Specification LCO requirements.
The follow-ing were observed with respect to the requirements indicated:
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January 3, 1980 RCS/RHR Flow TS 3.1.1.3
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Boric Acid Flow Paths TS 3.1.2.1
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Boric Acid Transfer Pump Operability TS 3.1.2.5
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Specific Iodine Activity
~S 3.4.8
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RHR System Operability TS 3.7.11
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AC Electrical Power Sources TS 3.8.1.2
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(Shutdown)
AC Distribution (Shutdown)
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D.C. Distribution (Shutdown)
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January 10, 1980
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Charging Pump Operability TS 3.1.2.3 i
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Borated Water SonNes (Shutdown)
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RHR Flow and Temperature / Boron Dilution TS 3.1.1.3
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DC Distribution (Shutdown)
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RHR/RCS operation in accordance with BVPS Operating
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Manual, Chapter 1.6.4.N, Draining the RCS to the Center-line of the Hot Leg Loop for Maintenance, Revision 10.
The inspector reviewed administrative controls and main control board indicetions of system alignment and process parameters for RCS makeup and drain paths, measurement and control of RCS level, and status of necessary system components not specifically addressed by Technical Specifications.
The inspector also interviewed onshift operators regarding i
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the above and other LCO's applicable to plant conditions,
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including maintenance of minimum RHR flow for RCS dilution operations adjustment of CVCS.boration/ dilution controls, and administrative control of makeup and drain paths.
(2) Radiation controls established by the licensee, including the
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posting of radiation areas, the conditions of step-off pads, and the disposal of protective clothing were observed.
Selected
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Radiation Work Permits posted at work locations were reviewed.
Locked barriers to High Radiation areas were also confirmed to b2 secure.
The areas listed in paragraph b above which are suoject to radiological controls were observed on the dates noted.
(3) Plant housekeeping conditions including general cleanliness conditions and control of materials to prevent fire hazards were observed in the areas listed in paragraph b above.
Main-tenance of fire barriers was also observed to confirm compliance with TS 3.7.15.
(4) Systems and equipment in all areas toured were observed for the existence of fluid leaks and abnormal pipe vibration.
(5) Fire hose and extinguisher stations in all areas toured were observed on a sampling basis to determine that equipment appeared operable, had been inspected / tested at the required frequency, and equipment and alarm stations did not have obstructed access.
These observations were made during the tours of January 4 and 8, 1980 as noted in paragraph b above.
(6) Control room manning was observed on the dates noted in para-graph b and during other periodic control room visits.
Shift turnovers were observed on January 3 and 10 in order to confirm that continuity of system status information was maintained.
Turnovers sere observed for both Shift Supervisors and Nuclear Control Operators on January 10 (7:00 a.m.) and for Shift Super-visors on January 3, 1980 (7:00 a.m.).
(7) During the tours of radiologically controlled areas and posted
"nu smoking" areas the inspector confirmed that the areas did not exhibit evidence of smoking.
Except as further discussed below, the inspection findings were acceptable.
d.
Findings (1) At approximately 6:00 p.m. on December 20, 1979, the inspector was informed that the pump element for the 1A Low Head Safety Injection (LHSI) Pump had been inadvertently dropped during pump disassembly.
The ir.spector and the on duty Shift Supervisor toured portions of the PAB and Safeguards Pump area and inspected the affected pump.
The pump was being disassembled as part of Design Change Package No. DCP-0188 and in accordance with Maintenance Work Procedure No. 188-1, Disassembly of LHSI Pumps 1A and 18, Revision G.
The pump is of a deep draft, vertical centrifugal
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design having a pump casing (can) approximately 52 feet tall.
The pump was being progressively disassembled by lifting the internals from the can and removing the vertical shaft and inter-nals segments while temporarily supporting on the asembly 4"x6" wooden cribbing laid across the opening of the vertical pump can.
During this operation, craft personnel were disassembling the last two pump segments when work was stopped to resolve a pro-cedural question and the pump element and one shaft section were left resting on the cribbing at the top of the pump can.
The cribDing, not secured or restrained to prevent slippage, apparently slipped, causing the pump element to drop from the top of the can into about seven feet of standing water in the bottom of the can.
The pump element was astimated by the licens-ee Maintenance Foreman to weigh approximately 1500 lbs.
During the inspection tour on December 20, 1979, the inspector noted no visible damage to the pump or can.
Due to the inaccessibility of the pump can, only limited observation could be made frons the top of the pump.
On December 22, 1979, the inspector met with the DLC Superinten-dent of Construction to review the licensee's evaluation of the event and was informed that the licensee was establishing a program for retrieval of the dropped element, internal inspec-tion of the pump can, evaluation of any damage identified, and repair and realignment of the pump per DCP-0188.
The inspector was informed by the Superintendent of Construction that a pro-cedural inadequacy had been identified with regard to the instruc-tions for installation and restraint of the wooden cribbing pro-vided by Section 9.34 of MWP 188-1.
Although the procedure step was intended to result in restraining the cribbing with all-thread tie bolts, the step was poorly written and misdirected the craft personnel.
This resulted in no restraint being pro-vided.
The Superintendent of Construction stated that the sub-ject procedure was in the process of revision to clarify the procedure step and provide illustrative sketches to prevent recurrence on subsequent similar evolutions.
With rega"" to the A tential damage tu the pump element and cas-ing, the ~ censee stated that a new replacement pump element was previous'., planned and available for installation with all parts
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being replaced except the pump's suction bell. The original suction bell will be extensively inspected to ensure its inte-grity prior to reir;stallation.
The evaluation of any damage noted on the pump can and associated equipment will be referred to DLC Engineering for disposition.
The inspector requested that the Superintendent of Construction or his designee inform him when the above evaluations are completed to permit NRC:RI review
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The Superintendent of Construction acknowledged the inspector's request and stated that the notification would be made. This item will be followed during subsequent inspections.
(79-27-05)
(2) During the above plant tours and on other routine passage through plant areas, the inspector noted that personnel performing con-tamination self-monitoring (frisking) were not consistently per-forming whole body frisks at the Monitoring Room exit from the PAB.
The facility has monitoring stations selectively located throughout the PAB but relies substantially upon the Monitoring Room location to ensure that potentially contaminated perscanel receive a final complete survey prior to exiting the radiologi-cally controlled areas.
The inspector periodically observed personnel performing only partial (hand and foot) frisking.
The inspector was informed by DLC Radcon Foremen that plant policy requires each individual to perform personal frisking on the basis of his activities within the building and does not necessarily require a whole body frisk upon exiting the PAB.
The individuals selectively identified as having performed mar-ginally acceptable monitoring satisfactorily repeated the pro-cess with no contamination identified.
The inspector expressed concern that, unless consistent monitoring was conducted, an undesirable potential for the spread of radioactive contamina-tion existed.
The Radcon Supervisor and Foremen acknowledged the inspector's comments and initiated periodic surveillance of the exit point by Radcon and other departmental supervision to ensure proper, whole body frisking.,0n January 7, 1980, the inspector was informed that these surveillances would also be performed by contractor supervision and contractor safety engi-neers for those organizations which have large numbers of craft personnel working in radiologically controlled areas.
During subsequent tours and routine observations, the inspector noted that the surveillances discussed above were being performed and appeared to result in improved self-monitoring performance.
The inspector observed the exit point on January 8 and 11, 1980, during which time no stpervisory surveillance was in process and founa no inadequacies in observed frishing techniques.
The inspector had no further questions at the close of this inspec-tion but will continue to routinely monitor the above activities during future inspections.
(3) During a plant tour on January 4,1980, the inspector identified concerns with regard to vital area access controls as discussed in paragraph 7 of this report.
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(4) During the tour of January 4, 1980, the inspector observed an
"Out Of Service" (0.0.S.) Tag No. 3-362 for a Radcon RM-14 Rate-meter (Frisker) attached to a wall in the Auxiliary Feedwater Pump Room and informed Radcon supervision of the finding.
Fol-lowup by Radcon Department supervision determined that the sub-ject tag had been associated with an instrument administratively removed from service for storage but the tag had not been pro-perly cleared from the tag log when the instrument was routinely returned to service.
Failure to properly control Out of Service tags is contrary to TS 6.11 and the BVPS Radeon P'.nual, Appendix 10,Section II.B.3, Radcon Instrument Deficiency Log, Revision 10, and constitutes an item of noncompliance (79-27-06).
The inspector further noted that the Radcon Department Review had identified several other Instrument Deficiency Log entries and 0.0.S. tags which had not been properly closed by return of the used tags and signoff of the associated log entries.
These deficiencies were corrected by Radcon on January 9, 1980 and confirmed by inspector review on that date.
The Radcon Supervisor informed the inspector that, prior to the date of the above inspection finding, the Radcon Department had prepared a new procedure for control of instrument deficiencies and would issue that procedure as part of the corrective action for the item of noncompliance pending receipt of new format Out of Service Tags from a ven Q r.
The inspector acknowledged the above information.
(5) Minor housekeeping items were identified to Radeon and Mainte-nance Department supervision for resolution, including:
Light trash accumulating in the Quench Spray Pump area;
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An open can of non-flammable solvent found in Quench Spray
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pump area; Loose, clean Anti-C clothing lying about the Auxiliary
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Feedwater Pump Room; Piles of bagged trash awaiting disposal (767' Level of PAB)
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included bags of general, uncontaminated trash mixed with internally contaminated bags of trash; Light trash was found accumulating on top of the Contain-
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ment Purge filter housing; Damaged door latch / door knob hardware was identified on
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the door from the Containment Airlock area to the Steam
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Generator Blowdown Tank Room and on the stairwell door into the East Cable Vault.
Prior to the close of the inspection, the inspector confirmed that corrective action had either been completed or was in pre-gress for all items listed above and had no further questions on
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these matters.
6.
Foreign _ Material in Emergency Diesel Generator (EDG) Fuel Oil Tanks
During performance of the twenty four hour load test required by IE Bul-letin 79-23 (reference paragraph 3), the No. 2 EDG electric fuel oil pump was found to have 0 psig indicr.ted discharge pressure.
During investiga-i tion of the apparent pump problem on December 10, 1979, the licensee found
a bag of silica gel dessicant in the engine mounted fuel tank and blocking the electric fuel pump suction pipe.
A similar bag of dessicant was found in the No. 1 EDG fuel oil tank.
During this inspection the licensee's actions to investigate and t
, ate the event were reviewed on a continu-
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ing basis.
The licensee was in the process of reviewing construction and
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preoperational test records in order to establish the source of the mate-rial, its time of introduction into the tanks, and a review of the adminis-trative controls which should have prevented its remaining in the tanks.
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Concurrent with the licensee's reviews, the inspector reviewed portions of
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the above records including:
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GM-EMD Engineering Test Instruction M&I-416, Testing Model 999 Generat-
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ing Plant Units, Revision D.
Instructions regardina preparation for shipment of factory tested units included no installation of dessicant.
Various Stone and Webster Engineering Corporation Shop QC Inspection
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Reports and Field QC Installation Checklists associated with the sub-ject equipment.
No reference to the installation or presence of dessicant was noted.
Equipment Storage History Cards for the EDG units and associated
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Fuel Oil Day Tanks were reviewed.
Although only a partial collection of the records were available to the inspector, no reference to the installation or presence of dessicant was noted.
Equipment Release for Initial Operation - EDG's, dated June 17, 1974,
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included records of preoperational inspections and deficiency items.
No reference to the installation or presence of dessicant was noted.
System Release for Preoperational Testing and Final Acceptance - EDG's
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dated September 17, 1974 was reviewed.
No reference to the installa-
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tion or presence of dessicant was noted.
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At an exit meeting on January 11, 1980, the inspector informed the licensee representatives present that the above matter appeared to be a reportable occurrence of a significant breakdown in quality assurance program controls in accordance with TS 6.9.1.9.c and that, subject to completion of DLC evaluation of the occurrence, a licensee event report should be submitted.
The Superintendent acknowledged the inspector's comments.
The completion of the licensee's evaluation and submission of a licensee event report will be reviewed during subsequent inspections and is considered to be an unresolved item (79-27-07).
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THIS PAGE, CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLANK.
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THIS PAGE, CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLANK.
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8.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are accepta'le, items of noncompliance or deviations.
Unresolved items addressed during this inspection are discussed in para-graphs 2, 3, 5 and 6 of this report.
9.
Exit Interview Meetings were held with senior facility management periodically during the course of this inspection to discuss the inspection scope and findings.
A summary of inspection findings was also provided to the licensee at the
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conclusion of the report period.
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