IR 05000334/1980009
| ML19347B192 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/30/1980 |
| From: | Beckman D, Hegner T, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19347B183 | List: |
| References | |
| 50-334-80-09, 50-334-80-9, NUDOCS 8010010813 | |
| Download: ML19347B192 (41) | |
Text
O
-
U. S. NUCLEAR REGULATORY COMMISSION
-
-
OFFICE OF INSPECTION AND ENFORCEMENT
-
REGION I
Report No.
50-334/80-09 Docket No.
50-334 License No.
LPR-66 Priority Category C
--
Licensee:
Duquesne Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Facility Name:
Beaver Valley Power Station, Unit 1 Inspection At:
Shippingport, Pennsylvania Inspection Conduc d:
March 8-April 19, 1980 Inspectors:
bb d
J.D.Hegner/ Resident ns ctor date L
fk'd p~
C/k/Vo D.A.Beckmp1,Seniorfesi nt Inspector date date Approved by:
EObMh 6l'fo/80 t. C. McCabe, Chief Reactor Projects date SectionNo.2,R0ENSBranch Inspection Summary:
Inspections on March 8-April 19, 1980 (Inspection Report No. 50-334/80-09)
Areas Inspected:
Routine inspection by the resident inspectors (205 hours0.00237 days <br />0.0569 hours <br />3.38955e-4 weeks <br />7.80025e-5 months <br />) of:
actions on previous inspection findings; plant operations, IE Circular followup, in-office review of licensee event reports, licensee event followup, review of small break loss of coolant accident emergency procedures, utility disciplinary action for an NRC licensed o plant modification control. perator, radworker training program deficiencies, and Results:
FouritemsofNoncompliancewereidentified(Deficienc Failure to cahbrate and control dial indicators, paragraph 4; Infraction y ilure to imple-Fa ment and maintain Radiation Monitor surveillance tests, paragraph 10; Infraction -
Failure to implement document control measures, paragrap1 10; Infraction - Failure toimplementequipmentcontrol/jurisdictionprocedures, paragraph 10).
Region I Form 167 (August 1979)
8010010 gj3
.
e
.
.
.
.
.
,
DETAILS 1.
Persons Contacted R. Balcerek, Nuclear Engineering and Refueling Supervisor R. Burski, Senior Compliance Engineer S. Fenner, J. Griffin,QC SupervisorSenior Test Specialist i
R. Hansen, Maintenance Supervisor R. Prokopovich, Reactor Engineer
,
L. Schad, Operations Supervisor
'
J. Sieber, Superintendent, Licensing and Compliance P. Valenti, Station Engineer J. Werling, Station Superintendent H. Williams, Chief Engineer The inspectors also interviewed other licensee personnel.
2.
Licensee Action on Previously Identified Inspection Findings The NRC Outstanding Items List was reviewed with the licensee.
Items selected by the inspector were subsequently reviewed through discussions with licensee )ersonnel, documentation review, and held inspection to determine whetler licensee actions specified in the OIs had been satisfac-torily completed.
Outstanding items areaddressed below and on paragraph 3.
The overall status of the previously identified inspection finding; was reviewed and planned and completed licensee actions were discussea for those items not reported below.
(Closed) Inspector Follow Item 78-06-02:
Close-out of Test Program Open Items as Listed in JTG Meeting Minutes No. 63.
The inspector reviewed the outstanding items with licensee engineering staff and had no further cues-tions with the exception of licensee review of BVT 1.1-9.4.3, Net Loac Trip Test,in JTG Meeting Minutes No. 63 are resolved.
which is discussed as item 78-12-02 below.
All other outstand-ing items (Closed) Infraction 78-11-02:
Failure to Perform Air Surveys.
The item concerned inadequate air sampling on two occasions when individuals entered the containment at power.
The inspector reviewed Radiation Work Permits and associated air sampling documentation for containment entries made during the most recent period of power operation (August 20 - November 30, 1979) and noted no additional discr%e/.ies.
In addition, the inspector noted that Radcon Manual Change W 60-07, which promulgated the licens-ee's stated corrective action % gcified in DLC letter dated June 12, 1978, had been implemented.
(Closed) Deficiency 78-15-0D:
Failure to Monitor Chemical Sump During Discharge.
The inspector reviewed the action taken to prevent recurrence as specified in DLC letter dated August 7, 1978.
In addition the inspec-tor reviewed plant chemistry logs for 1979 to determine periods when pH was outside specified limits and compare this information to discharge
=
.
O
.
.
'
'3 records to verify that no uncontrolled discharges had taken place. Also, recorder traces for PHRS-WT-101 were examined to verify that strip charts were being annotated as required by Special Operating Orders 78-1 and 78-2.
The inspector had no further questions.
(Closed) Inspector Follow Item 78-ER-01: Technical Specifications to be Amende : for Flexibility with respect to Secondary Chemistry. Amendment 26 to License No. DPR-66 for Beaver Valley Unit #1 transmitted to the licens-ee by NRC letter dated February 29, 1980 deleted the TS on secondary water chemistry. The licensee will now implement a coordinated secondary che-mistry program with no specific TS requirements.
'
(0 pen) Unresolved Item 80-01-08:
Licensee to provide basis for acceptabi-lity of UT Technique "C" used for inspections pursuant to IEB 79-17. On April 17, 1980, the inspector reviewed a letter dated April 9, 1980 from the licensee's ISI contractor.
It did not appear to address the acceptabi-lity of the above procedure on the basis of acoustic similarity of the piping used to qualify the technique and the piping at BVPS. The letter did, however, indicate that the technique in question was used on piping that was required to have only liquid penetrant and visual inspection and therefore exceeded the requirements of the IEB. The licensee stated that a revised response to the IEB may be submitted reflecting that infomation and indicating that all requirements of the IEB have been satisfied.
The inspector acknowledged the licensee's statement and noted that such a resub-mittal should be made prior to restart from the current outage to permit timely NRC review.
(Closed) Unresolved Item 78-30-02:
Review Applicability of Unit 2 Liner Weld Problems to Unit 1 Containment Floor Liner Welds. The inspector reviewed DLC Structural Engineering Department Memorandum, R. J. McAllister to F. Salmon, dated January 22, 1980, which forwarded the architect engi-neer's evaluation of the above problem for incorporation into the plant's records. The information was consistent with that provided verbally during IE Inspectica No. 50334/78-30 and satisfies the documentation request noted therein.
(Closed)UnresolvedItem 76-26-03:
Licensee to determine the number of safety injection cycles acceptable for the Unit 1 design.
As discussed in IE inspection Report No. 50-334/80-06, the licensee was requested to vide a position with regard to an NRC letter, A. Schwencer (NRR: DOR) pro-to C. N. Dunn (DLC), dated December 9, 1979, which recommended actions for plants which experience 25 safety injection cycles.
On March 31, 1980, the DLC Senior Compliance Engineer informed the inspector that DLC will follow the guidance of the above letter if and when the facility experi-ences 25 injection cycles and that task has been entered into DLC internal coninitment control system for tracking. The inspector confirmed that the item had been entered as Item No. 493 on the DLC Licensing and Compliance Section commitment list.
The inspector informed the Senior Compliance Engineer that a plant specific review by NRR for BVPS is still pending in MRC:NRR and may be the subject of future NRC correspondenc. _ _ _..
.
_ _ _ - -.
_ __
-
.-
_
-_
__
_ _ _ - _ _.
. - - _ - -
-
=
.
.
o
.
.
'
(0 pen) Unresolved Item 78-12-02:
Review and Evaluate Final Test Report from Net Load Trip Test. This item was unresolved pending submittal of the final report and subsequent review by NRC staff. The review focused on recommendations listed on page 5 of the Test Results Reports associated with BVT 1.1-9.4.3 Revision 0.
The recommendations included, among other items, checking for proper operation and settings of:
the 51-VF116 Type COM-5 Auxiliary Feedwater Pump 3B overcurrent relay;
--
the 51-VC105 Type COM-5 Reactor Coolant Pump IC overcurrent relay;
--
and the overcurrent trips associated with the above-mentioned pumps.
--
The licensee was unable to demonstrate to the inspector that follow-up action on the recommendations listed above had been perfonned. All other recommended follow-up actions were documented, reviewed by the inspector, and found to be acceptable.
The licensee intends to reperform the recom-mended but undocumented checks to verify that the recommendations of the test group have been followed. This item will remain open pending NRC review of those tests.
(Closed) Inspector Follow Item 78-23-01:
Inspect licensee completed review of electrical component environmental qualification.
(Closed) Inspector Follow Item 78-23-02:
Licensee to incorporate design changes in environmental qualification review.
(Closed) Inspector Follow Item 78-23-05:
Licensee to provide documenta-tion to show qualification of transmitters and cable on safety related circuits and evaluate impact for flooded equipment.
The above items relate to inspections conducted pursuant to IE Circular No. 78-08, Environmental Qualification of Safety Related Electrical Equip-ment at Nuclear Power Plants.
Since the promulgation of the dove items, IE Circular 78-08 has been supplemented and superseded by IE Bulletins 79-01 and 79-01B, Environmental Qualification of Class IE Equipment which requires licensee action and information on the above matters in excess of the original scope defined by these items.
The inspector has confirmed that each of the above items will be addressed during the licensee and NRC review of IEB 79-01/79-01B. With respect to Item 78-23-02, the DLC Senior Compliance Engineer confirmed, on April 2, 1980, that all modifications implemented to date and all modifications which will be implemented prior to plant restart from the current outage will be included in the licensee's review and submittals to NRC.
On the basis of the foregoing, the above items are closed for administrative purposes and their subject matter will
<
be reviewed pursuant to IE Bulletin 79-018.
,
.-.
.
.
,
.
.
.
.
5-3.
IE Circular Followup The inspector reviewed licensee actions taken in response to the following IE Circulars in order to determine that the Circular was received by licens-ee management, that a review for applicability to the facility was performed, and that, for those applicable to the facility, appropriate corrective actions have been taken or planned for implementation. The following Cir-culars were reviewed:
IE Circular 79-08, Attempted Extortion - Low Enriched Uranium:
Inspector review of Onsite Safety Committee (OSC) minutes BV-0SC-37-79 determined that the OSC had noted the Circular as infomation.
IE Circular 79-10, Pipefittings Manufactured from Unacceptable Material:
Inspector review of OSC minutes determined that the licensee review did not include a review of A/E and subcontractor records. This matter was discussed with the DLC Senior Compliance Engineer. A subsequent review by the licensee of A/E and subcontractor records detennined that no mate-rial referenced in the Circular had been received onsite.
IE Circular 79-12, Potential Diesel Generator Turbocharger Problem:
Inspec-tor review of BV OM Chapter 36, Section 2, Revision 4; BV OM Chapter 55A, Section 4, Revision 15; and OST 1.36.3/4 Revision 14 determined that pro-cedures were in compliance with guidance provided in the Circular.
IE Circular 79-15, Bursting of High Pressure Hose and Malfunctions of Relief Valve and "0" Ring in Certain Self-Contained Breathing Apparatus (SCBA):
Inspector review of OSC minutes BV-0SC-58-79 ascertained that
~
the licensee stated that SCBA units as described in the Circular were not used at Beaver Valley. The inspector, accompanied by the Senior Engineer, confirmed this statement by conducting a visual inspection of all SCBA units at the station. The following locations and equipment were examined during on March 27, 1980.
Location SCBA Type No. of Units Fire Brigade Storage Room MSA Model 401
Turbine Building Wall Elevator MSA Model 401
Water Treatment Room MSA Model 401
Hot Lab Hallway MSA Model 401
Laundry Room Scott Rescue Pack
Laundry Room Chemox OBA
__
.
.
.
o
-
.
No equipment as described in the Circular was found during the inspection.
IE Circular 79-16, Excessive Radiation Exposures to Members of the General Public and a Radiographer: OSC minutes BV-0SC-58-79 were reviewed.
The OSC noted the Circular for information.
IE Circular 79-18, Proper Installation of Target Rock Safety Relief Valves:
The inspector reviewed BV-0SC-78-79 minutes.
The Circular concerned BWR facilities.
The OSC noted the Circular for information.
IE Circular 79-05, Moisture Leakage Thru Stranded Wire Connectors: During routine review of licensee action in response to IE Circulars, the inspec-tors noted that the subject circular had been received and reviewed by the Onsite Safety Committee on March 27, 1979. Applicability to Beaver Valley was established and the circular was forwarded to appropriate licensee staff for action. Through apparent administrative oversight, the responsible engineering staff had not performed the review of the circular.
It was determined that the subject circular had not been evaluated when the licensee was requested by inspectors to provide documentation to verify that appropriate action pursuant to the OSC directive had been accomplished.
Discussions with licensee personnel determined that no formal method existed within the licensee organization prior to January, 1980 to control dissemi-nation and licensee action on NRC and other significant correspondence.
The licensee committed to reviewing the subject circular by the end of the current outage and implementing necessary corrective action, or justifying why action would not be taken.
In addition, the licensee now incorporates circulars received subsequent to January 1980 in its Commitment Control System.
This item will remain open pending NRC review of licensee evaluation of IEC 79-05.
(79-CI-05)
4.
Review of Plant Operations a.
General Inspection tours of selected plant areas were conducted on the dates noted during the day shift with respect to housekeeping and cleanli-
ness, fire protection, radiation control, physical security and plant protection, operational and maintenance administrative controls, and Technical Specification compliance.
-
Acceptance criteria for the above areas included the following:
BVPS FSAR Appendix A, Technical Specifications
--
,
_
-_
__
_ - -. - _.
.-
.
.
,
-
..
,,
BVPS Operations Manual, Chapter 48, Conduct of Operations
--
OM 1.48.5 Section D, Jumpers and Lifted Leads
--
OM 1.48.6 Clearance Procedures
--
OM 1.48.8 Records
--
OM 1.48.9 Rules of Practice
--
BVPS Operations Manual, Chapter 55A, Periodic Checks - Operating
--
Surveillance Test BVPS Operations Manual, Chapter 54, Statien Logs
--
BVPS Maintenance Manual, Chapter 1, Conduct of Maintenance
--
Section J Housekeeping
--
BVPS Radcon Manual, various sections
--
SAD 25, Housekeeping and Cleanliness Procedure
--
10 CFR 50.54(k) Control Room manning requirement
--
Inspector Judgement
--
BVPS Physical Security Plan
--
b.
Areas Inspected Control Room (March 11 and 13; April 14 and 21)
--
Primary Auxiliary Building, except High Radiation Areas and
--
LooseSurfaceContaminationAreas(March 20)
Service Building (March 24)
--
Main Steam Valve Room (March 24)
--
Purge Duct Room (March 20)
--
East / West Cable Vaults (March 20)
--
Emergency Diesel Generator Rooms (March 20)
--
Containment Building, including High Radiation Areas (March 20)
--
,
,
-
.
.
.
-
.
Water Treatment Room (March 27; April 2)
--
Protected Area (March 27)
--
The inspectors also toured the Control Room on a daily basis to review logs and records and conduct discussions with operators con-cerning reasons for selected lighted annunciators and knowledge of recent changes to procedures, facility configuration and plant conditions, c.
Observations (1) Control Room Instrumentation Conformance with Technical Specifications Control Room monitoring instrumentatior: was ebserved to verify that instrumentation and systems required to support Mode 5/6 operations (as applicable) were in conformance with Technical Specification (TS) Limiting Conditions for Operations (LCOs).
The following instrumentation / indications were observed with respect to the LC0's indicated:
Boric Acid Flowpath (April 2, 16)
--
Boric Acid Transfer Pumps Operability
--
(March 10)
.
Boric Acid Storage Tank Level and
--
Temperature TS 3.1.2.7 Reactor Coolant System Boron Con-
--
centration (March 26)
TS 3.9.1 Residual Heat Removal Flow
--
(March 10, 16, 23)
TS 3.9.8 Radiation Monitor Operability
--
(March 13)
TS 3.3.3.1 RIS-LW104
--
RM-RW-100(March 4)
--
RIS-VS-106
--
RM-VS-103 A/B
--
RM-VS-104 A/B
--
__
_
..
_.
_
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _
.
.
.
.
.
s
,
AC/DC Electrical System Availability TS 3.8.1.2, 3.8.2.2,
--
and Distribution (April 10)
and 3.8.2.4 (2) Radiation Controls Radiation controls, including posting of radiation areas, the conditions of step-off pads, disposal of protective clothing, filling out radiation work permits, compliance with radiation work permits, personnel monitoring devices being worn, cleanli-ness of work areas, radiation control job coverage, area monitor operability (portable and permanent), area monitor calibration, and personnel frisking procedures were observed on a sampling basis in the following areas:
Primary Auxiliary Building (PAB) (March 20)
--
Containment Airlock Area (March 20)
--
Containment (March 20)
--
The following Radiation Work Permits (RWP) were reviewed for completeness:
RWP 6275 Containment Elevation 767
--
RWP 6463 PAB/ Safeguards Bldg., Low Rad. All Elev.
--
RWP 6026/6192/6478 PAB/ Safeguards
--
RWP 6479 PAB Safeguards / Fuel Building, All Elev., Non-High
--
Rad Areas (3)
Plant Housekeeping Plant housekeeping conditions including general cleanliness con-ditions and control of material to prevent fire ha m ds were observed in areas listed in paragraph b.
Maintenance of fire barriers, fire barrier penetrations, and verification of posted fire watches in these areas was also observed.
(4) Control Room Manning Control Room manning was observed on the dates noted in para-graph b. above and during other periodic Control Room visits.
During the Easter weekend, the licensee declared a three day holiday for all but essential personnel. The inspectors veri-fied that minimum manning requirements for Control Room person-nel, Emergency Squad, and Fire Brigade were met on April 4 (Good Friday).
-
.
.
.
-
(5) Surveillance Tests The inspectors reviewed completed surveillance tests available during control room tours to verify that surveillance tests were being completed that test results were being reviewed according to approved procedures, and appropriate corrective actions were initiated if necessary.
The following records of completed Opera-tional Surveillance Tests (OST) were reviewed:
OST 1.20.1 Spent Fuel Pool Level Verification, Revision 0,
--
performed April 4, 1980 OST 1.49.2 Shutdown Margin Calculation, Revision 8, per-
--
formed April 4, 1980 OST 1.11.3 BoronInjectionFlowPathValvePositionVeri-
--
fication, Revision 20, performed April 3, 1980 OST 1.45.3 Seismic Monitoring Instrumentation Monthly
--
Channel Check, Revision 10, performed April 3, 1980 OST 1.36.2 Diesel Generator No. 2 Monthly Test, Revision 15,
--
performed April 1, 1980 OSI 1.7.4 CentrifugalChargingPumpTest(1CH-P=1A),Revi-
--
sion 14, performed April 2, 1980 OSI 1.33.15 Eire Extinguisher Inspection, Revision 18,
--
performed April 2, 1980 OSI 1.7.8 Boric Acid Storage Tank and RWSI Level and Tem-
--
perature Verification, Revision 10, performed April 3, 1980 OST 1.43.1 Technical Specification Reguired Area and Process
--
Monitor's Channel Functional Test, Revision 5, performed March 9 and April 3, 1980 The following maintenance surveillance procedure was observed:
MSP 43.32 Reactor Coolant Letdown Line Liquid Activity,
--
Revision 0, performed April 4, 1980 (6)
Plant Security / Physical Protection Implementation of the physical security plan was observed during inspection of areas listed in paragraph b. with regard to the following:
__
_
-_
- - - - - -
-
.
.
.
.
.
,
Protected Area barriers were not degraded;
--
Isolation zones were clear;
--
Persons and packages were checked prior to allowing entry
--
into the Protected Area; Vehicles were properly search a and vehicle access to the
--
Protected Area was in accordance with approved procedure; and Security access controls to Vital Areas were being main-
--
tained and that persons in Vital Areas were properly authorized:
On March 27, 1980 the inspectors conducted a general security tour accompanied by licensee security personnel. Areas toured included:
Protected Area barrier perimeter
--
Isolation Zones
--
Central Alarm Station
--
Secondary Alann Station
--
All manned guard posts
--
Vital Area access control points in the PAB
--
Containment equipment hatch construction workers access
--
point General yard area within the Protected Area
--
Security personnel training class
--
Discussions were conducted with guards and watchpersons at each location to ascertain whether they possessed a working knowledge of their responsibilities and that Post Orders for each station were available. The inspector observed personnel and vehicle search and access procedures, manning, barriers, and compensa-tory measures during the tour.
On March 29, 1980 the inspectors observed licensee preparation for an announced non-violent demonstration to be held on March 29, 1980ontheanniversary(sic)ofThreeMileIsland.
Preparations included:
-__
_ _ _ _ _.
__
.
.
.
.
-
.
Review of plans for controlling site access;
--
Communications checks;
--
Review of proper legal authorities and responsibilities;
--
Coordination with local law enforcement agencies;
--
Deployment of response forces.
--
The demonstration, involving approximately 40 persons, took place as scheduled.
There were no incidents.
(7) Operational and Maintenance Administrative Controls Equipment control procedures used by the licensee to control plant equipment and activities were examined to verify that tags were properly filled out, posted, and removed as required by approved procedures.
The inspectors reviewed logs and records for complete-ness.
The inspr.ctors verified proper posting of the following tags / controls:
Out-of-servicestickersonannunciators(March 20)
--
Calibration stickers of portable and permanent radiation
--
monitors (March 13 and 20)
Danger Tags on control room ventilation system (March 24)
--
'
Calibration stickers on Fire Suppression System Water pres-
--
sure indicators (April 13)
(8) Maintenance Observations On March 24, 1980 the inspector observed portions of safety-related maintenance on the 48 Control Room Air Conditioning Compressor determine whether:
activities were violating limiting conditions for opera-
--
tions;
,
i
'
redundant components were operable;
--
required administrative approvals and tagouts were obtained
--
l prior to initiating the work;
l approved procedures were being used or the activity was
--
'
w1 hin the " skills of the trade s
__
_
_ - _
-
.
.
.
-
-
.
the procedures used were adequate to control the activity;
--
activities were being accomplished by qualified personnel;
--
replacement parts and materials being used were properly
--
certified; radiological controls were properly implemented;
--
ignition / fire p*otection controls were appropriate and were
--
implemented;
,
QC hold points were observed to provide independent veri-
--
fication of specific points.
,
d.
Findings (1) Control Room Air Conditioning Compressor Overhaul On March 24, 1980 the inspectors observed portions of main-tenance on a safety-related system involving overhaul of the 4B Control Room air conditioner comaressor using corrective maintenance procedure 1-44VS-E-4B-14, 4B Control Room Air i
Conditioner Overhaul, Revision 0.
The inspectors verified that required administrative appro-vals had been obtained prior to commencing work by reviewing:
Maintenance Work Request #732038,
--
Equipment Clearance Permit #423110,
--
Switching Order #205720,
--
and verifying that required Danger Tags were properly posted on 480Vbreaker(E-VS-9),
--
'
--
Local control switch,
--
'
as described in the above documentation and that the clear-ance points were adequate to protect workers.
The inspectors verified that replacement parts and mate-rialsbeingusedwereproperlycertifiedbyexaminingthe QC" Accept tag for Part #C-10995, Stock #C-0, " Condenser",
which was received on March 20, 1980.
The inspectors also reviewed QC documentation and verified that QC coverage was provided for the activity as require.
.
.
-
.
.
-14 While workers were performing activities to realign the compressor and motor coupling halves in accordance with Step XX of the referenced procedure, the inspectors noted that an uncalibrated dial indicator was being used to achieve a quantitative measurement, i.e., a maximum total misalignment of 15 mils.
The procedure reguired that the dial indicator control number and calibration date be recorded.
The ins)ector brought this to the attention of theQCinspectorw1owaswitnessingtheactivity.
The use of uncalibrated dial inciators on work involving safety related equipment was brought to the attention of the Maintenance and QC Supervisors.
Review of Maintenance Manual Chapter 1, Section E, Control of Calibration of Main-tenance and Test Equipment, Revision 10, established that dial indicators were not included as part of the calibration program.
10 CFR 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment requires that " Measures shall be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affect-ing quality are properly controlled calibrated,andadjusted at specified periods to maintain acc,uracy within necessary limits." The BVPS FSAR, Appendix A.2, Section A.2, Section A.2.2.12, Control of Measuring and Fist Equipment, states, in part, "the Operations Quality Assura. ice Program establishes measures to assure that tools, gages, instruments and other measuring devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods or prior to use to maintain accuracy within neces-sary limits.
Specific procedures shall include the identi-fication of the calibration technique, the calibration fre-and the method established for the tagging of measur-guency, ices to positively indicate their status..."
Ing dev Failure to use calibrated equipment on work affecting quality constitutes a noncompliance with 10 CFR 59, Appendix A, Cri-terionXII(80-09-01).
2)
Vital Area Access Control On May 2, 1980 licensee contractor personnel brought it to the inspector's attention that a 31 day access control list to a Vital Area (the Control Room) had expired, A)ril 30.
The inspector immediately notified the Security Slift Super-visor of the discrepancy.
On May 3, the inspector noted that a new list had not been issued.
Immediate discussions with the Station Office Manager revealed that corrective action was taking place.
As part of the issuance of a new list, licensee procedures required a review of the names on the
_ _ _ _ _
_-_
__
_
.-
__.
____ - _ _ _
_
__-
.
.
~
~
.
.
.
list to determine if access was still appropriate for the next 31 day period.
In the interim the Station Office Manager had recertified the expired list.
The inspector
.
verified that the new list was issued on that day and available to watchpersons at the appropriate access control point.
Subsequent discussions witn responsible licensee personnel revealed that there was no formal method to assure that the access lists were reviewed, approved and issuad prior to the expiration of the previous month's list.
i.e inspector requested that the licensee review the applicable procedures and establish a more positive methods for aauring that the access control list reissuance was handled in a timely manner.
On May 10, 1980 the licensee issued Security Instruction 1.8, Personnel Access Into Vital Areas, Issue 2.
The inspector reviewed the referenced instruction and had no further questions.
The inspector stated that issuance of subsequent access lists would be routinely monitored in future inspections.
3)
Radiation Controls During review of Radiation Work Permits (RWP) associated with the close-out of Item 78-11-02 discussed in paragraph 2 above, the inspector noted that RWP 006275, Containment Ele-vation 767, appeared to indicate that work was perfctmed on reassembly of a detaching tool without adequate radiological controls being implemented for the work conditions described.
Specifically, the RWP indicated contamination levels in both the 500,000 pCi/ general work area and the maximum level wereThe RWP a
dm.
were to be performed for each work step; however, no air survey data associated with the RWP was indicated.
The inspector discussed these concerns with the cognizant Radiation Control Foreman.
Additional information provided by the licensee determined that there was no radiological hazard associated with the actual work (which involved remov-ing and nplacing two bolts).
The tool had b o n covered except for the location to be worked on to prevent possible spread of contamination.
No activity that could result in a potential airborne contamination problem was performed.
Additional survey and air sampling information was made available to the inspector that had not been attached to the RWP at the time of the initial review.
General work
area contamination was found to be less than 450 pCi/dm,
Air sampling surveys performed during work activity showed no airborne contamination.
-
.
.
_.
.
.-
.
.
.
'
~
,-
,
chen guestioned concerning the discrepancies on the RWP,
'
.he licensee stated that the RWP had been prepared prior to turvey or actual work and that it had been written conser-vatively in the event special precautions were required as J
work progressed.
The inspector stated the position that RWPs were records that should adequately and accurately specify information to workers and document actual conditions.
Infor-
.
l mation required on RWPs was discussed.
The inspector had no further questions.
4)
Temporary Operating Procedures During routine review on March 11, 1980 of Temporary Operat-ing Procedures (TOPS) maintained in the Control Room, the inspector noted that the following TOPS did not include l
specific termination dates / terms of effectivity as required by OM Chapter 48 Section 3.h. Temporary Operating Procedures:
TOP 80-03 To Supply P/G Water Header from WT for
--
Spray Down of Reactor Cavity TOP 80-04 Temporary Incore Sump Pump Operation
--
The finding was discussed with the Chief Engineer and Opera-tions Supervisor.
It was noted that these were specific refueling procedures which would be terminated when refuel-ing was completed.
The inspector stated his concern that other expiration dates may not be as obvious.
Additional discussions with the Operations Supervisor indicate that future practice will assure that information is provided as required.
A standardized cover sheet is being considered as a vehicle to assure that required information is included.
The inspectors intend to follow licensee action in this area through review during future inspections (80-06-02).
5.
In Office Review of Licensee Event Reports (LER's)
The inspector reviewed LER's submitted to the NRC:RI office to verify that the details of the event were clearly reported, including the accuracy of the description of cause and adequacy of corrective action.
The inspector determined whether further information was required from the licensee, whether generic implications were indicated, and whether the event war-ranted onsite followup.
The following LER's were reviewed:
LER NUMBER EVENT DATE SUBJECT 80-12/01T March 12, 1980 Remote Shutdown Panel Channel Check
- 80-13/04T March 2, 1980 Cooling Tower Blowdown Temp. Indi-cator Out of Calibration
_
._
_ _ _ _ _ -.._
_ _ _
. _ - _
-- -.
.
.
'.
17.
'
.
LER NUMBER EVENT DATE SUBJECT 80-14/04T March 7, 1980 Liquid Waste Discharge Monitor Inoperable 80-15/04T March 8, 1980 Component Cooling Water Radiation Monitor Alarm Inoperable 80-16/03L March 11, 1980 No. 2 Battery Charger Input Breaker Trip 80-17/01T March 26, 1980 Potential Exceeded Pipe Stress During ORF
- 80-18/01T March 26, 1980 Fire Main Rupture 80-19/03L March 10, 1980 Liquid Waste Evaporator Bottoms Heat Ex. Crack 80-20/03L March 29, 1980 Closed VCT outlet valve Due to False Lo-Level Signal
- 80-22/01T April 7, 1980 Loss of RHR Flow
- 80-23/01T April 11, 1980 Loss of RHR Flow Special Report February 25, 1980 Apparent Seismic Instrument Malfunction
" Reports selected for onsite followup.
6.
Onsite Licensee Event Followup For those LER's selected for onsite followup (denoted by asterisks in para-gra)h 5), the inspector verifiea that the reporting requirements of the Tec1nical Specifications and Proccdures SAD 14 and SAD 23 had been met, that appropriate corrective action had been taken or planned, that the event was reviewed by the licensee as required by Technical Specifications and Procedure SAD 21, and that cor.tinued operation of the facility was con-ducted in accordance with Technical Specifications and did not constitute an ur. reviewed safety.iuestion as defined in 10 CFR 50.59(a)(2).
The follow-ing findings relate to the LER's reviewed onsite:
a)
LER 80-13 Cooling Tower Blowdown Temperature Indicator Out-of-Cali-bration.
While performing Maintenance Surveillance Procedure (MSP)
31.01 T-CW-101 Cooling Tower Blowdown Temperature Channel Test /
Calibrction on March 2, 1980 the instrumentation alarm st. ooint was l
.__
_ _ _
__
_
.
-
.
,
,
foundtobeoutofcalibration(high).
The instrument was immediately recalibrated.
Discussions with licensee personnel determined that a computer assisted scheduling system is employed by the licensee in order to track MSP due dates; however, the output generated is not in some cases suffi-cient to determine applicability in different TS operating modes (Due date for the subject MSP had been January 10,1980).
It appears that the individual responsible for scheduling MSPs had not realized that performance of the subject MSP was requires in Mode 6.
Further dis-cussion with the cognizant licensee engineer determined that all MSPs had subsequently been reviewed for applicability in the current mode (Mode 5) and, the data base was being corrected on a case-by-case basis, to better reflect actual surveillance requirements.
The inspec-tor had no further questions.
b)
LER 80-18 Fire Mine Rupture On March 26, 1980 plant operators were performing a surveillance test on a temporarily installed fire pump (Jaeger Model 6 CPH D HP, Centri-fugal Pump) that had been 11 aced in service due to the failure of the Motor-Drive Fire Pump (FP-3-1) on February 26, 1980.
During the sur-veillance, system pressure, nominally 120 psig, dropped to 95 psig, causing the normal Diesel-Driven Fire Pump (FP-P-2) to start.
System pressure increased and the pump was throttled back.
Again, system pressure dropped.
Pressure shortly thereafter dropped to 25 psig.
It was re70rted to the Control Room that a section of the 12 inch fire main norti of the Main Transformer inside the Protected Area had rup-tured.
The section was isolated.
Inspectors visually verified that the licensee had adequate fire pro-tection available from other mains and hydrants to provide coverage for the affected area.
The ruptured section of cast-iron pipe was excavated and sent to the licensee's metallurgical laboratory, for analysis to determine the failure mode.
A previous failure of a section of the fire main had occurred on July 17, 1979.
Because of the potential similarity in the failure mechanisms, on March 27, 1980 the inspectors requested the DLC Chief Engineer to pro-vide the following information when the investigation is completed:
Information on the type and specifications for the aiping
--
affected on March 26 and its similarity to piping w1ich rup-tured on July 17, 1979; Information which discusses the )ressure transients observed
--
during the Jaeger pump testing w1ich was in progress at the time of the~ rupture;
~
..~
..
. _..
.-
_ _ _ - _ - _
_ _ _ _ _ _ _ _ - _ _ _ _
__
__
.- _ _ __
_
___ _
..
.
.
.
.
the licensee's evaluation of the piping failure mode, initiators,
--
and susceptability of this type of piping to future failures; the licensee's intention for prevention and/or detection of
--
future similar piping failures; information on any o Mr similar failures of pressurized cast
--
iron pipina of the type used in the fire main, whether in the fire main or other pressurized service.
Ihis matter is unresolvea pending completion of the licensee inves-tigation into the failure made of the piping and NRC review of licens-ee preventive actions.
(80-09-03)
c)
LER 80-22/01I and 80-23/01T Loss of RHR Elow The licensee has experienced an increasing number of losses of RHR flow while operating the system with the RCS loops partially drained (references:
IE Inspection Reports Nos. 50-334/80-01 and 80-06).
The two events which occurred on April 8 and 11, if30 respectively exhibited similar characteristics of the RHR pumps becoming air bound and tripping.
In a previous case (LER 80-02/01T) the cause for air binding was not specifically determined but appeared to be related to operation of a reactor vessel head vent eductor system which induced RCS system level perturbations.
During the two April 1980 events, RCS level appeared to be stable and the pumps became airbound as operators attempted to increase RHR flow from approximately 2000 gpm to 3000 gpm.
The licensee has taken the following actions with respect to the above events:
RCS ioop level is now being maintained at 90% height in the RCS
--
hot leg piping to provide imprved NPSH over the previous 50%
height.
The system valve lineup was verified with no discrepancies noted.
--
The system is being vented on a once/ shift basis as long as resi-
--
dual air or gasses are observed at the pump vent during venting.
The system was checked for gross air inleakage with no indicat".n
--
of such leakage.
Temporary Operating Procedure (TOP) 80-11 was issued to provide
--
a temporary constant vent from the RHR pump vents to an RCS sys-tem highpoint in an attempt to p< ovide a more effective method of air removal than intermitteat venting.
At the close of this
_
_.
...
_
. _.
.
.
.
.
.
.
.
inspection the temporary equi) ment had been installed and unsuc-cessfully tested.
The flow tirough the temporary vent line appears to be insufficient to provide effective venting and the licensee is continuing to explore other short term methods for air removal / minimization.
The RCS loops must remained E.artially drained pending completion
--
of reactor coolant pump (RCP; motor overnaul and recoupling.
The licensee is investigating temporary methods of establishing RCP
'
seal integrity to permit contingency filling of the RCS loops
should a loss of RHR flow require refill.
BVPS OM Section 1.10.4.K, Abnormal Procedures, Loss of RHR with
--
RCS Drained to Midra n of the Loops, Revision 11, was issued to
'
provide operator d1'ection for establishing containment inte-r grity, providing RCS makeup, and restoration of an RCS loop for decay heat removal under conditions of long term loss of RHR flow.
The problem has been referred to DLC engineering for development
--
of a long term solution, potentially including the installation of a permanent constant vent system.
The insaectors reviewed the actions discussed above and noted that,
'
althougi a specific cause and effect relationship has not been estab-lished, the licensee appears to be taking proper action to preclude a long term loss of RHR flow.
To date each loss of flow has appar-ently resulted from pump air binding, p,ossibly due to vortex forma-tion at the RHR/RCS suction, and has been recoverable within minutes by venting the pumps.
The inspectors confirmed that, with the pre-sently assigned operating shift complements, sufficient numbers of operators familiar with the venting operation are available on all shifts.
The inspectors further noted that BVPS OM Section 1.10.4.K can require considerable time and resources to implement, including the available of plant systems which may be affected by outage activities. The efficacy of this procedure for implementation under existing condi-tions will be reviewed during a subsequent inspection.
(80-09-15)
7.
Review of Small Break Loss of Coolant Accident Emergency Procedures In accordance with commitments made to NRC, the licensee issued revised emergency procedures on November 29, 1979.
These are intended to improve the guidance available to plant operators for responding to a Small Break Loss of Coolant Accident (SBLOCA).
The inspector reviewed the with respect to ' procedure guidelines" issued by an NSSS Owner' procedures s Group and
'
approved by NRC:NRR.
The following procedures of the BVPS Operating Manual (0M) were reviewed:
_
-
.
.
.
-
-
Section 1.53.4, Procedure E-0, Immediate Actions and Diagnostics,
--
Revision 21; Section 1.53.4, Procedure E-1, Loss of Reactor Coolant, Revision 21;
--
Various other Sections of the BVPS OM pertinent to the normal and
--
abnormal operations of the various Engineered Safety Features (ESF)
systems and supporting systems required to be operated during imple-mentation of E-0 and E-1.
The E-0 and E-1 procedures were reviewed with respect to the following criteria or attributes:
The precedures follow the NSSS SBLOCA Guidelines and contain appro-
--
priate incorporation of accident symptoms, diagnostic guidance, immediate actions, subsequent actions, and precautions.
The procedures identify plant specific instrumentation needed to
--
carry out the operator actions and are viable for actual operator performance.
Use of RCS Loop isolation valves is prohibited to prevent automatic
--
pumping of radioactive fluids out of containment during a LOCA.
Theproceduresadequatelyensurethatswitchoverfrompost-LOCAinjec-
--
tion phase operation to recirculation phase operation can be conducted prior to loss of the RWST as a suction source.
The procedures provide adequate protection of ECCS pumps in the event
--
of a very small break which could result in deadhead operation of the pumps.
The procedures ensure that pumps, valves, and other vital ESF equip-
--
ment are loaded on the emergency electrical busses and that needed instrumentation is available in the control room should a subsequent loss of offsite power occur during accident recovery.
The methods used to arrive at the proper Reactor Coolant Pump (RCP)
--
trip pressure are consistent with the NSSS guidelines.
Plant operators have received training on the revised procedures.
--
a.
General Comments:
The inspector had the following general comments with respect to the above.
Specific comments are additionally provided below.
(1) The E-0 and E-1 procedures were issued about one day prior to the facility shutdown for an extended refueling and modification outage.
During this outage modifications to plant systems are being installed which will require significant revision of the
. _ _ -.
.
.
'
-*
procedures, e.g., modifications for automatic switchover from
.
injection to recirculation phase operation; an augmented chemi-
'
cal addition (NaOH) subsystem for the Quench Spray System; instal-lation of NUREG 0578, TMI Lessons Learned, equipment, etc.
In light of the revisions which appear to be necessary due to these modifications, review of operator training and other selected review items above will be performed (or reperformed) subsecuent to completion of the outage related modifications and proc.edure revisions (80-09-04).
(2) During this inspection the licensee was recalculating the pres-sure requirements for manual tripping of Reactor Coolant Pumps (RCP's) based upon the availability revised instrumentation data.
The calculations were in progress at the close of the inspection and the licensee was requested to provide them to the inspector,
'
when they become available, for completion of the above review.
This item will be reviewed during subsequent inspections (80-09-05).
(3) Procedures E-0 and E-1 are substantially verbatim incorporation of the NSSS guideline procedures into the plant manual, reflect-ing certain limited plant specific information and requirements.
As reflected by the more specific comments which follow, such verbatim incorporation of the NSSS provide the specific instructions (guidelines does not a) pear to valve-by-valve, switc1-by-switch, etc.) which are necessary to accomplish individual evo-lutions required by the procedures.
This comment also appears to be germane to Procedures E-2, Loss of Secondary Coolant, Revision 22, and E-3, Steam Generator Tube Rupture, Revision 22, which were issued during this inspection and read by the inspec-tor. On a case by case basis, the need for additional specifi-city should be reviewed by the licensee for the inclusion of either detailed instructions or direct procedural reference to other applicable plant procedures as appropriate.
This matter is considered to be part of Unresolved Item 80-09-06 discussed below.
(4) During the inspector's initial review of E-0 through E-4, the inspector noted that the guidance of E-3 and E-4 were not con-sistent with that of E-0 and E-1 with respect to accident dia-gnostics, ECCS termination criteria, etc.
Similerly OM Section 1.11.4.M, Recovery from Inadvertant Safety Injection, Revision 13, did not appear consistent with the new guidance of E-0 and E-1.
Although revised versions of E-3 and E-4 have been issued, this matter will remain unresolved pending further review by the inspector (80-09-06).
The inconsistencies associated with OM 01.11.4.M are further discussed below.
(5) Containment isolation features which prevent automatic pumping i
of radioactive fluids out of containment during a LOCA were l
_
._
.
.
..
-
.
. - -. _ -
- - 1
.
.
.
.
.
.
previously reviewed by the inspector during IE Inspection No.
50-334/79-09.
The licensee is currently performing a review of the effect of ESE reset functions on these circuits in accord-ance with IE Bulletin 80-06, ESE Reset Controls.
Eurther inspec-tion followup will be performed pursuant to that Bulletin.
(6) Discussions with Operations Department and Training Department
,
)ersonnel indicated that the existing versions of the procedures lave been the subject of a significant number of technical com-ments provided by the licensee staff.
These comments have not yet received a systematic review for incorporation into the pro-cedures.
At the exit meeting conducted on May 24, 1980, the inspector requested licensee management to provide information regarding the review and disposition of these comments prior to plant restart.
The completion of that action will be considered as an Unresolved Item (80-09-07) pending NRC review.
At the exit meeting conducted on May 24, the inspectors advised the licensee that, as presently written, procedures E-0 through E-4 did not appear adequate to support plant restart with respect to the general comments above and the specific comments below.
The acceptability of these procedures will remain unresolved ending resolution of issues identified in paragraphs above.
80-09-06)
b.
Specific Comments:
(1) The NSSS owner's group guidelines provide an accident diagnostic chart in E-0 to assist the operator in analyzing accident symp-toms.
The existing licensee procedure, without the chart, includes sufficient instructions to complete such analyses but is in a written form which is not as immediately readable as the chart.
The licensee indicated that the chart was inadver-tantly omitted from the issued procedures and will be incorpo-rated into a revision prior to station restart.
(2) The BVPS OM 1.11.4.M, Recovery from Inadvertant Safety Injection, Revision 13,,provides instructions which are not consistent with current requirements for tarmination of safety injection flow and system recovery.
Although the existing emergency procedures address the correct termination criteria and provide, general instructions for recovery from inadvertant safety injection, standing alone, they do not provide sufficiently detailed instruc-tions te direct the detailed operations necessary to complete the evolation.
(3) Pursuant to general comment a(3), E-0 and E-1 include general, individual steps which require substantial operation of plant sys-tems but do not provide detailed instructions which appear ade-quate to permit safe, consistent implementation.
Examples include:
,
--
-
-
-
- - -.
,
- ---
y
I
.
.
.
.
.
.
.
E-0, Followup Action 7.i - shutdown of SI pumps and maintenance of operable SI flowpaths.
7.j - isolation of cold leg SI flow and establishment of normal charging lineup.
7.k - Restablishment of normal makeup and i
letdown.
E-1, Followup Actions, 6.a&b - Plant cooldown evolutions for a small leak i
E-1, Followup Action, No step - Previous issue of E-1 (Revision 18)
required individual verification
,
of equipment starts and valve posi-
'
tions via a checklist but similar provisions not been required in the existing E-1.
(4) Previous revisions of E-0 (Revision 18 and prior) included plant specific information and precautions regarding Emergency Diesel Generator operation, loaded and unloaded, which has not been transferred to the reviewed version.
The information which has been carried over to the revised procedures does not appear to address the minimum information necessary to assure proper ope-ration and minimize damage to EDG's for expected operating modes.
(5) Previous revisions of E-0 and E-1 included precautionary steps for Sup Control /plementary Leak Collection System Main Filter Bank Damper Operation during resetting of ESF signals intended to prevent automatic repositioning of dampers to their non-accident positions.
The licensee intends to implement design changes to eliminate the need for such steps but has not completed such to date.
The revised procedures do not include the subject steps.
(6) An NRC leuter (D. F. Ross to C. Reed, November 5, 1979) required each licensee using the NSSS owners group procedure guidelines to be able to establish that sufficient RWST volume exists to prevent losses of ECCS pump suction during the switchover from injection 1hasetorecirculationphasepost-LOCAoperations.
Although t1e licensee is currently installing a modification which will automatically initiate and perform the valve opera-tions necessary for switchover, no information was available to address the above, including the adequacy of RWST volume or pro-cedures necessary to effect the switchover should manual actions be required as a result of normal operation or equipment failures.
.
The licensee was requested to provide the information above prior to plant restart.
'
,
i l
[
-
.
-
_
.-
-
.
. _ _
-_
-
_-
- -
.
.
.
.
'
~
(7)
E-1, Step 1, Page 9, includes a note which req"uires the operator to switch the auxiliary feedwater pumps to an alternate water supply source" upon reaching a low level in the Demineralized Water Storage Tank (WT-1K-10) but fails to provide any guidance as to acceptable alterna.'.e sources.
Discussions with licensee personnel indicate that, for certain circumstances, guidance would be appropriate, e.g., admission of river water (a conve-nient alternate source) would be extremely undesirable if time and water inventory permitted use of either main feedwater or makeup to WT-TX-10 from the water treatment plant.
Discussion with various licensed personnel indicated a broadly differing range of opinion and intentions for dealing with this situation which appears to make additional guidar.ce in the procedure from licensee management particularly appropriate.
(8)
E-1, Step 3.e, Page 9, Caution A e,te power occur, all safe-appears confusing in that it states that should loss of offsi guards equipmen,t, except the shutdown LHSI pumps, will automa-tically load onto the diesel powered emergency busses.
The last stated condition of the i.HSI pump control in E-1 appears to be
"after start" with the pumps in operation.
This caution note appears to mislead the operator and does not address rechecking equipment that might not otherwise restart following a loss of offsite power.
(9)
E-1, Step 11.a, Page 12, appears to require a check of specific valve positions for the cold leg recirculation mode operation but does not list nor refer to a list of the affected valves.
Step 11.b refers to the use of banana clips (shorting plugs)
which is necessary to enable valve control circuits to be used in the switchover to the hot leg recirculation mode.
The step does not stipulate which valve circuits are affected.
Addi-tionally, the inspector was unable to determine that a systema-tic method of ensuring that a sufficient number of the proper type of banana clips are available at all times.
The supply of such clips appears to be maintained in the Shift Supervisor's desk.
(10)
E-1, Table E-1.1, provides the detailed instructions for shift-ingsystemalignmentsfromtheinjectiontotherecirculation phase.
The currently issued version does not follcw the NSSS owners group guidelines and does not reflect the automatic switchover modification previously mentioned.
With respect to the guidelines, the existing procedure does not include pre-cautions or prerequisites equivalent to those in the guidelines applicable to BVPS, does not include alignment verification steps, and does not appear to address contingency actions for single failures in line with the philosophy of the guideline.
_..
_.
.
.
.
.
.
(11)
E-1, Step 3, Page 9 provides the criteria for terminating safety injectionflow. The next one and one half pages provide addi-tional instructions for the actual termination.
E-1, Step 4, Page 11, provides the instructions to the operator for cases wheresafetyinjectioncannotbeterminatedbecausetheStep3 criteria have not been met.
A conspicuous reference to step 4 could eliminate the need to at least scan the intervening pages and minimize the time and confusion potential for continuation fo the accident response.
(12) Previously existing instructions in E-1, Step 8 (Revision 18)
J provided guidance for spray down of the pressurizer relief tank and contingency actions for tank rupture disc failure.
Similar instructions have not been included in the revised procedure.
(13) BVPS OM'1.13.2, Containme'nt Depressurization System Precautions, limitations, and Setpoints, cautions the operator to stop Quench Spray pumps at 3 ft. 9 in. indicated RWST Level (decreasing) to prevent pump damage.
This appears to be in conflict with E-1, Steps 8.a and 8.b, Page 12 which assumes the pumps "run dry" as
'
RWST level decreases.
(14)
Item 5 of IE Bulletin 79-06C requires definition of the conditions necessary to restart Reactor Coolant Pumps which have been tripped due to low system pressure.
The DLC Letter of August 28, 1979 issued in response to IEB 79-06C stated that this matter remained under study.
Discussions with station personnel ind hated that the matter has not yet been resolved.
The inspector reguested the licensee to provide their position and intentions with regard to this matter for plant restart.
(15) Neither E-0 nor E-1 appear to provide guidance or reference to procedures for plant operation with Reactor Coolant Pumps Tripped.
Although procedure E-19, Loss of RCS Flow, could be considered applicable, discussion with plant personnel indicated that E-19 is not applicale in all cases.
The licensee was requested to
identify the appropriate guidance or references necessary to address the post-trip plant conditions.
(16)
E-1, Step 4, Page 11, Caution, stipulates that LHSI should be restarted when RCS pressure decreases below the LHSI Pump shutoff head but does not indicate the actual or approximate value of shutoff head.
The information should be considered for incor-poration to permit ready access by the operator.
(17)
E-0, Step 2b, Page,3, requires operator verification that the IAE and IDF Electrical Bus Voltages indicate energization and that all intended loads are being powered but does not indicate that any specific loads of interest should be verifie _
.
.
.
3,
<
.
.
,
(18)
E-0, Step 7.t, Page 6, requires verification of reactor coolant indicated subcoolin late the method (s) g to be greater than 50F but does not stipu-of desired determination.
The licensee intends to install direct indication of subcooling during this outage, but has not yet done so.
During the week of April 21, the inspector provided an informal listing of the above comments to the licensee Reactor Engineer for review and disposition.
The inspector has requested the licensee to address their disposition or comments on the above to the inspector during a future inspection.
c.
As part of an ongoing NRr, d ew effort associated with IEB 79-018, Environmental Qualifica%. cf Class IE Equipment, the inspector extracted those instrwencs, controls, and e'uipment required to be q
operated or monitoret during performance of E-0 and E-1 from the pro-cedures and provided the listing to NRC-RI for subsequent use in IEB 79-01B reviews.
This matter will be further addressed during future inspections of IEB activities.
8.
Utility Disciplinary Action - Licensed Operator As a result of an incident in the control room on April 1,1980, the Duquesne Light Co. took displinary action, including a two day suspension without pay, against a licensed Nuclear Control 0)eratar.
This action was based upon an apparent act of insubordination.
T1e inspectors reviewed the circumstances surrounding the incident, including its proximate cause, corrective and preventive actions, the licensed individual s training and performance history, and the actual and potential consequences of the incident.
On April 1, 1980, the facility was in cold shutdown (Mode 5) with the RCS loops drained to the hot leg, piping centerline for maintenance.
The RHR System was in service Minimal Engineered Safety Features (ESF) providing decay heat removal. equipment was requ Specifications (TS).
TS 3.1.2.1.a, Boration Systems Flowpaths - Shutdown, reguired that a flow path from the boric acid storage system via a boric acid transfer pum) to a chargir,1g pum) to the RCS be operable.
TS 3.1.2.3, Charging Pump - Slutdown, required tlat, as a ainimum, one charging pump be operable.
The action statements for both specifications require that, if the required equipment is inoperable, all operations involving core alterations or positive reactivity changes must be suspended unti opera-l bility is restored.
On the 16-2400 watch on April 1, 10 CFR 50, App. J, Type C leak testing of charging header containment 1 solation valves was in progress in accord-ance with OST 1.47.14, Penetration #15 Valve No. ICH-31, MOV-1CH-289 Type C Leak Test, Revision 19.
The area under test was isolated in accordance
_.
.
.
.
-
-
with Equipment Clearance Permit No. 218913.
The test area isolation valves, however, leaked by under the head supplied by the Volume Control Tank.
In order to accommodate the testing (while maintaining an operable borationSS (NCO) path,theShiftSupervisor flow to shut the VCT outlet valves, isolating the charging pum) suction.
The valves were to be maintained shut under the cognizance of t1e NC0 and were to be opened only under emergency conditions requiring initiation of flow.
The inspectors confirmed that no plant operations were in progress during this time which would have normally required boration flow to be established, that there were no operations involving core alteration or which would have resulted in positive reactivity changes, or which adversely affectedtheoperabilityofthesubjectequipmentbeyondrequiringnormal o)erator action to initiate flow.
The valves, MOV-1CH-115C and -115E, were slut from the main control board at 2220 hrs. and their status logged (including the reason for closure) in the NCO log.
.
.
The offgoing NCO briefed his relief on the above system configuration and the associated background information during shift turnover.
After some discussion, the oncoming NCO apparently concluded that, with the VCT out-let valves shut (but operable from the main control board), the TS operabi-lity of the charging pump had been compromised.
Without consultation with
,
the Shift Supervisor (still on duty from the 16-2400 watch),theoncoming NC0 assumed the watch and opened the valves at 2248 hrs., causing a small spill of slightly contaminated water at the test rig in the Primary Auxi-11ary Building.
Within approximately two minutes, the SS became aware of the valve operation and directed the NC0 to reshut the valves.
The NC0 initially refused to follow this direction but, after a brief discussion, did reclose the valves and made an NCO log entry that the valves had been shut under specific direction of the 55.
During the above valve operations, the test ri A short time after the valve mani-pulations, g was apparently unattended.a Radcon Technician found water f was immediately isolated and controlled radiologically.
During April 3-5, 1980, the inspectors and licensee management become aware of the general circumstances of the slight spill and began separate reviews of the administrative control and TS compliance aspects of the event, being unaware of the specific operations and personnel interactions
~
involved.
On April 18, licensee management informed the inspector of the detailed circumstances above and of the company's intentions to formally disci)line the NCO for insubordination with respect to the direction of the SS.
rom April 8-14, the inspectors reviewed the licensed individuals'
performance, essentially substantiating the company's findings.
On April 14, 1980 the compnay issued a two day suspension to the NCO for the period of April 16-17,1980.
The company's evaluation and actions in this matter are documented in a n9quesne Light Co. Memorandum of Perscnnel Problem, dated April 12, 1980.
ihis document presents the information discussed above and concludes that, althoug'in this case were unwarranted, in that he took. th able operator, his actions
.
.
.
action contrary to prior supervisory direction when there was no need to take immediate action without consulting his supervisor.
The inspectors reviewed the logs and records associated with the above inci-dent and conducted interviews and discussions with the personnel involved, the Operations Supervisor, and Station Superintendent, and made the follow-ing additional determinations.
A review of the individual's licensed operator requalification program
--
training records established that he currently met all program require ments and had displayed satisfactory performance in all areas.
Inspector interviews with the individual on April 11 and 15 established
--
the individual's concerns and reasoning which led to reopening the sub-jectvalves.
Although the individual understood the reason for the valves being shut, he perceived an urgency to reopen them to minimize the time which the charging pump was 1solated and, in his opinion, inoperable.
The individual explained his rationale and acknowledged that, based upon the counseling received and his review of his own performance, that he had acted incorrectly.
The individual appeared to recognize the radiological implications of effectively inducing a slight leak by opening the valves, and stated that he had intended to notify Radcon and the work party immediately upon reopening the valves.
That notification had apparently been diverted by the ensu-ing discussions with the SS.
A review of data associated with the slight spill caused by the opera-
--
tion showed that approximately 3 liters of water had been spilled into thetestrigandadjacentworkareawithapproximately1.literspill-ing onto the floor.
The gross gamma activity of the liquid was deter-mined to be 2.1E-4 uCi/ml and was principally in the form of Co-60, C0-58, Cs-134, and Cs-137.
No personnel or airborne contamination resulted from the spill and the area was decontaminated to less than 450 uuCi/100 cm.
The test rig, which had been internally contami-
nated, was subsequently decontaminated.
No significant radiological hazard resulted from the spill.
A review of applicable TS requirements and BVPS Operating Manual
--
requirements determined that the regulatory requirements for adminis-trative control of system configuration and Limiting Conditions for Operation had been satisfied.
BVPS OM Section 1.48.7.B.1.2 permits minoradjustmentsinsystemlineupstobeperformedviaoralpermis-sion of the SS.
The licensee's practices with regard to deviating from normal system alignment valve or switch positions in accordance with the above procedure were reviewed and found to be inconsistently implemented.
Although all such operations appear to be routinely authorized by the SS, the actual practices for documenting such mani-pulations and ensuring their return to normal are not addressed by licensee procedures and do not appear to be consistently implemented
.
__._ _
_
-
.
.
_..
_ _ _ _ _ -_
. _ _ _ - _ _ _
.
.
.
.
.
.
.
by onshift personnel.
Review of control room practices indicated that, while such manipulations are of the control room narrative logs, generally logged in one or more no single, consistently imple-
mented mechanism exists to ensure that the new system configuration information is carried from shift to shift and the equipment returned to normal at an appropriate time.
The inspectors informed the Super-intendent and station staff at an exit meeting on April 24, 1980 that such practices had an unacceptably high potential for error and requested the licensee review the applicable procedures for possible revision.
The inspector stated that the existing system for use of Caution tags described in the BVPS OM appeared to be an appropriate mechanism for documenting and tracking such manipulations and that, based on discussions with RI management, Caution tags or a similar/
equivalent method of control should be applied to similar system alignment changes which must extend past the end of the shift on which
'
they are initiated.
The licensee acknowledged the inspector's state-ments and agreed to review the above for potential implementation.
This matter will remain unresolved pending NRC:RI review of the licensee's actions (80-09-08).
As a result of discussions with the involved individual and members of
--
the station operating staff, the inspectors determined that onshift operators appeared confused with respect to their individual 10 CFR 55 license responsibilities and their responsibilities to company super-vision in matters immediately affecting plant safety.
As a result of the incident described above and an event on November 27, 1979 which resulted in enforcement action by NRC for two licensed personnel at the facility (reference:
IE Ins)ection Report No. 50-334/79-30),the station's operators appeared to )e acutely sensitive to the responsi-bilities of their individual licenses as described in IE Information Notice No. 79-20, NRC Enforcement Policy - NRC Licensed Individuals, to the extent that both licensee management and the inspector shared a concern that the sensitivity could result in improper operator actions.
In order to clarify the station management and NRC positions with regard to the above, the Senior Resident Inspector and licensee Ope-rations Supervisor conducted onshift meetings with all licensed and unlicensed operations on all three shifts during the period of April 16-17, 1980.
During these discussions the content of IE Infor-mation Notice No. 79-20, the circumstances surrounding the April 1 incident and its ramifications, the control room chain of command, and methods for resolution of differing technical opinions between licensed personnel were discussed, including:
Referral of plant problems upward through the chain of command
--
as time and need dicate; recognition of the authority of SR0 licensed supervision over subordinate watch position ___
.__
_ _ _ _
.
.
,
,
.
Individual operation responsibility to take unilateral action
--
when time or circumstances dictate, including the need for uti-lization of all available resources as soon as possible.
The recourse available to individuals when disagreements on tech-
--
nical issues affecting nuclear safety are not resolved and actions are directed by management or supervision under the protest of the individual.
Individual operator responsibility to utilize all available
--
resources and guidance when making decisions, including Techni-cal Specifications, plant procedures, consultation with other, particularly senior, licensed personnel, and assimilsation of all available and pertinent operating information from plant instrumentation and indication.
At the conclusion of the briefings, the operators appeared to have a betterunderstandingoftheabovesubjectsandindicatedthatthe discussions had, at least in part, ameliorated individual concerns with respect to the above and NRC enforcement policy for licensed individuals.
In addition to the above meetings, the licensee committed to include similar discussions in workshop training sessions for operators and supervisors which are being conducted pursuant to commitments made by the licensee to NRC as discussed in IE Inspection Report No. 50-334/
80-04.
The workshops are directed at providing a heigtned sense of awareness of job and supervisory responsibilities in response to the previously referenced incident of November 27, 1979.
The inspector will review completion of the licensee's actions in this regard during a future inspection (80-09-09).
9.
Radworker Training Program Deficiencies - Review of Allegation On March 24, 1980, the inspector was notified by the Station Superintendent that DLC had become aware that forty-seven individuals who had attended Radworker practical training had not received hands-on training, fitup, and testing for full face respirators as required by BVPS Training Manual lesson Plan No. LP-RC-I, Revision 1.
The issue had been raised by two contractor employees who were no longer employed onsite but had, during their employment at the facility, worn respirators.
The individuals involved had alleged to licensee canagement that they had been required to use filter mask repsirators but had not received the requisite classroom training prior to their use.
The licensee had com-pleted an investigation of the matter and, on March 22, 1980, had issued a report of their findings to the Station Superintendent (Memorandum BVPS:JAK:196).
The inspector reviewed the findings documented in the above report and reviewed training requirements, training records, and exposure
-
. - -
.
-. - -
-
--
-
--
..
i
.
'
,~
,
,
!
l l
'
records, on a sampling basis, to confirm the licensee's findings as dis-t cussed below.
The licensee found that, during three Radworker practical training classes on December 11, 13, and 14, ired by the lesson plan,d 1979, personnel did not participate in the hands on respirator training requ apparently due to the relatively large class sizes (13, 14, and 10 indivi uals respectively) and class tinie constraints.
All other training was completed, including demon-strationofrespiratordonningIngwasno,tdocumentedonthetrainingrecords removal fitting, and seal testing.
The incomplete status of the train associated with the classes.
Because of the absence of any notation, the training clerk entered all individuals into the Respirator Issue Authoriza-
'
tion computer program used for respirator issuance as having received all required training.
During review of the licensee's respiratory protection training program, the inspector noted that the training provided by the Radworker practical training requirements did not constitute qualification to utilize respira-tory equipment in atmospheres which required assignment of a protection factor in accordance with NUREG 0041 but merely provided sufficient train-ing for use c,f filter mask type equipment in areas of low airborne radio-activity concentrations as a precautionary measure or to maintain exposures as low as reasonable achievable.
A separate training program, required by the BVPS Radcon Manual, Section 10.1, Respiratory Protections Program, j
Revision 0, is established to provide qualification of personnel for use of respiratory equipment in areas of high airborne radioactivity concen-trations which require assignment of protection factors.
The two individuals discussed above and seven others were found to have actually worn respirators during onsite work without benefit of complete classroom training.
In all cases, the respirators were not issed on the basis of assigned protection factors but were used only as precautionary measures.
The two subject individuals had cuestioned the proper use of the equipment prior to their first usage anc received on the spot training including a seal test from a Radcon Foreman prior to their use.
Review of licensee records indicates that the two individuals worked in plant areas which had airborne radioactivity sample results of approximately 4.4% of the maximum permissible concentrations permitted in unrestricted areas by 10 CFR 20.
The licensee itinediately implemented the following corrective actions:
The individuals who attended the three classes above have been removed
--
from the Respirator Issue Authorization computer printout.
All personnel who attended the three classes and are still onsite were
--
being retraine _ _ _ _ _ _ _
___________
=
.
I
'
.
.
Memorandum BVPS:JAK:195 was issued on March 23, 1980 to all Radworker
--
training instructors specifying that lesson plans must be followed and completed and requiring,any deviations to the lesson plan to be explicitly annotated on training roster records.
Class sizes will be adjusted when necessary to ensure that all train-
--
ing can be completed in the allotted time.
The inspector reviewed the implementation of the abnve corrective actions and considered them to be appropriate and effective.
The inspector notad, however, that Memorandum BVPS:JAK:195 did not appear to provide long term assurance that the corrective actions would be consistently implemented.
The licensee stated that similar provisions would be incorporated directly into appropriate sections of the training manual to assure long term com-pliance(80-09-10).
10.
Review of Design Change Packages 201/202 a)
Summary Inspector review of modifications to the fuel handling building and containment ventilation systems in order to mitigate fuel handling, accidents and which are collectively designated as Design Change Packages 201/202 resulted in findings in three interrelated areas:
Surveillance tests
--
Design Control
--
Document Control.
--
Initial review of surveillance test results identified discrepancies in operator notations on the tests performed.
Followup revealed that operators were performing surveillance test of safety-related systems required to be operable by TS using procedures that had not been revised to reflect as-built systems.
The same procedures, with ope-rator notations that existing procedures did not reflect as-built systems were signed off by licensee supervision without comment con-
,
cerning,their adequacy.
In addition, procedures which had been revised to reflect as-built conditions and which were subsequently approved and issued for use also did not correctly reflect the as-built condition of the system.
Further review during succeeding weeks resulted in inspector findings of inadequacies in the method employed by the licensee in the control of design change turnovers and control of documents associated with the modifications.
Specific findings in each of the three areas are discussed belo _
.
.
.
.
.
'
.
.
a)
Surveillance Test As a result of inspect'or review of surveillance test data during a routine control room tour on April 4,1980 discrepancies were identified in operators' notations on the record copies of OST 1.43.1, Technical Specification Reguired Area and Process Moni-tor Channel Functional Test, Revision 5, performed between Janu-ary and April,1980.
Specifically:
OST 1.43.1 Rev 5 performed January 9, 1980, prior to entry
--
into the Refueling Mode, was noted as satisfactory.
The same OST performed February 6, 1980 had operation
--
notations to the effect that the procedure did not reflect design changes made to the fuel building and containment ven-
'
tilation systems with respect to damper and fan alignments.
The same OST performed March 9, 1980 was annotated as
--
satisfactorily completed with no reference to any system changes or procedure deficiencies.
The same OST, performed April 3, 1980 again had operator
--
notationthatthereweremajorchangestothesystemswhich rendered portions of the surveillance test inapplicable or incorrect.
In addition, OST 1.44C.1, Containment Purge and Exhaust Isola-tion, Rev 1, performed during the same time period did not reflect actual system configuration and did not provide for testing of all required trip functions since it too did not reflect the system as modified by DCP 201/202.
Actual operability of the modified system prior to entry into Mode 6 on January 29, 1980 had been determined through perfor-mance of BVT 1.1-1.16.5 Rev 0 on January 12-14, 1980 and Proof Test T-44-201-4 performed January 12, 1980 as part of the modifi-cation preoperational test program.
i These observations resulted in inspector review in areas discussed in paragraphs b) and c) below.
Preliminary findings in all three areas were brought to the attention of licensee management on April 15, 1980.
On April 17, 1980, the Operations Supervisor directed that the cognizant personnel review the subject OSTs and make appropri-ately dated notations on them indicating actual status of the system at the time the OST was performed.
Portions of the March 9, 1980 OST for determining operability of damper actua-tion VS-D-4-1A/8; -2A/B on a hi-hi alarm from radiation moaitor i
!
l
_
-_
_.
-
_
.
,
.
.
RM-IVS-103A/B (Fuel Handling Building Ventilation alarm) could not subsequently be validated by an operator.
i Another matter closely related to this and discussed in greater detail in paragraph c) below regards, Revision 8 to OST 1.43.1.
Initial preparation of Revision 8 was accomplished in November-December 1979.
This revision was intended by the licensee to incorporate changes to the system test resulting from DCP 201/202.
The arocedure was written, reviewed, approved, and issued on Marc 1 31, 1980 without adequately reflecting the as-built system.
Specifically, the OST did not require the operator to verify posi-tion of dampers VS-D-4-1A/B; and -2A/B on a hi-hi alarm from radiatien monitor RM-1VS-104A/B (Containment Purge).
In addition, the losition of Inlet Damper VS-D-5-2 as shown on the Data Sheet for ) retest, Test Verification, and Reset Verification was incor-rect.
Damper actuation and damper position were modifications associated with DCP 201/202.
A corrected revision to the sur-veillance test was finally issued April 17, 1980, a) proximately 3 months after the system was required to be opera)1e to support fuel transfer operations.
The failure to maintain procedures that accurately reflect as-built system conditions and the failure of licensee supervision to react when procedural inadequacies were identified appears to be the result of two factors:
1) TS required that the containment and FHB ventilation systems be directed through the Main Filter Banks whenever fuel was being moved.
The licensee had diverted venti-lation through the MFB during all of Mode 6.
This placed the eqJipment affected by DCP 201/202 in the tripped configuration required by the OST's.
In addition, licensee supervision was aware that Revision 8 to OST 1.43.1 was in to be issued and idantified no need to take any additional action.
TS 6.8.1.c requires that written procedures be implemented and maintained for surveillance and test activities of safety /4.3.3.1 related equi) ment, including the surveillance requirements of TS 3
-
for IM-1VS-103A & B and -104A & B.
The following items consti-ture examples of noncompliance with requirements:
(1) OST 1.43.1, Revision 5, and OST 1.44.C1, Revision 1, per-formed during the period January through April 1980, were inadequately maintained in that they did not reflect the system configuration resulting from recent modifications and did not provide for testing all required trip functions.
The surveillance testing of these components was required by TS during operations in Mode 6 (refueling) during that time period.
.
.
_ _. _
_ _ _ _.
_ _ _
~
.
.
.
(2) OST 1.43.1, Revision 5, aerformed on March 9, 1980 was inade-quately implemented in tlat the tests for RM-IVS-103A and B were documented as having been satisfactorily completed with-out identification of either procedure or system deficiencies even though the procedure did not reflect actual system con-figuration at the time of the test.
Existing documentation is inadequate to verify the operability of the equipment with respect to the subject surveillance requirements.
(3)
OST 1.43.1, bility of systems modified by DCPRevision 8, whi verify opera 201/202 was improperly maintained in that the procedure was not issued in revised and approved form until April 17, 1980.
The affected Fuel Building Ventilation and Containment Purge subsystems were placed in operation in January and required to be operable by TS for fuel handling activities during the period of January 29-February 23, 1980.
(4) OST 1.43.1, Revision 8, in issued form, was inadequately maintained in that it was reviewed, approved and issued in a form which failed to adequately test the operation of the dam er/ radiation monitor trip functions modified by DCP 201 202.
With respect to the examples above and foregoing discussion, the inspectors confirmed that immediate corrective action was imple-mented by the licensee for examples (1), (2), and (4).
Accord-ingly, licensee response to these items need only be address actions taken to prevent recurrence.
The inspectors further noted that the example (4) circumstances appear to be symptoma-tic of the practices. problems identified in the review of document control Actions taken to prevent recurrence may be addressed inconjunctionwiththatitemofnoncompliance(80-09-11).
b)
Design Control / Equipment Release and Turnover Transfer of responsibility for use of the systems affected by DC 201/202 took placc en January 19, 1980 via a hand-written memo random from Duquesne Light Construction Division-Nuclear (CON)toDu management)quesne Light Power Stations Department (station This was confirmed the next working day by telecon
.
between appropriate CDN and Power Stations personnel and noted on the CON System Release #44-201-1 for DCP 201/202 as a " con-
,
ditional" acceptance.
The inspectors reviewed the following documents during their examination of the licensee's design control system.
.
~
.
'-
,
,
QA Procedure OP-4 Design Change Control, Revision ~6.
--
QA Procedure OP-10 Maintenance / Modification Handling,
--
Revision.
SEP 1.3 Design Change Coordination, Revision 1.
--
EMP 2.8 Handling of Design Charge Packages, Revision 3.
--
CDN 3.7 Administirative Procedure for the Conduct of the
--
Construction Proof Test Program, Revision 3.
Review of CDN 3.7, which controls the use of System Releases, /
should that documentation of transfer of system responsibility jurisdiction did not appear to require that responsible person-nel address 1) the conditions or terms of such use; and 2) the
.
scope of responsibilities for continued operation, maintenance, testing, and further system modifications.
As a result, the understanding between CDN and Power Stations personnel appeared, to the ins)ectors, to differ with regard to which organization held the a]ove responsibilities.
This is substantiated by discussions with CDN personnel who indi-cated that, to them, a conditional acceptance meant that modifica-
- ions on a system had been completed and that the system was being turned over for preoperational testing, with only completion of minor, incomplete construction items which would not affect sys-tem operability remaining outstanding.
Discussions with Power Stations Department personnel, however, indicated their understanding to be that a system turned over on a conditional acceptance was under Power Stations jurisdiction during only the period or activity for which the condition was in effect, i.e., refueling and reverted to CDN jurisdiction upon termination of the condition or activity.
Except for operation of the system, neither organization acknowledged a responsibility for the maintenance and periodic testing of the system subsequent to conditional turnover.
CDN understood all work to have been completed except those items listed as outstanding on the System Release package.
The Power Stations Department, although, had not signed for acceptance of the DCP's and had, in fact, subse-quently expanded the original DCP scope by modifying DCP 201/202 to include the scopes of DCP's 307, 330, and 334 which were sub-sequently cancelled.
10 CFR 50, Appendix B, Criterion XIV, requires, in part, that measures be established for indicating the operating status of structions systems, and components....
The BVPS FSAR, Appendix A.2, Operation Quality Assurance Program, Attachment to A.2,
-
.
.
.
endorses the guidance of ANSI N45.2.8, Draft 3, Revision 2, September 1973, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants.
ANSI N45.2.8 provides requirements for the temporary use of equipment that is to become part of the permanent facility but has not been completely turned over from construction and/or testing.
The standard requires that authorization for usage be provided via a written approval which shall include:. (1) conditions for use or operation; (2) maintenance requirements; and (3) inspec-tions and tests required to maintain operability and quality during the period of temporary use.
The standard also speaks to other details of evaluation of the temporary use required to assure the maintenance of equipment cuality.
QA Procedure No.
OP-11, Control of Maintenance and Mocification, Revision 3, Sec-tion 11.4, requires, in part, that station administrative direc-tives and detailed implementing procedures establish the necessary measures to identify the status of insgections, tests, and opera-bility.
Station Administrative Directive No. 5 Equipment Turn-over, Issued August 1, 1974, requires that Beaver Valley Proof Test Manual Procedure 1-4 be the official detailed administrative procedure for equipment turnover.
Contrary to these requirements, the transfer of responsibility for the temporary use of the systems affected by DCP 201/202 took place on January 19, 1980 via a " conditional system release" in order to support the Technical Specification requirements for refueling and associated activities.
Neither Procedure 1-4 nor any other procedure available to the inspectors was utilized to control the transfer of responsibility with respect to the require-ments of ANSI N45.2.8 cited above.
This constitutes an item of noncompliance (80-09-12).
The inspectors noted that, independent of the findings discussed above, the licensee had already begun preparation of an improved turnoverprocedurewhichwas,judgednecessarypriortothis inspection.
The licensee indicated that, based on the results of this inspection, the new procedure would incorporate consid-eration of the problems discussed herein.
Document Control During review of the circumstances discussed above, the inspectors determined that as-built engineering information associated with DCP 201/202 was not being properly controlled, distributed and used with respect to the preparation, review and approvel of operating and surveillance procedures and was not available to support the opera-tion and maintenance of the eguipment as current reference documents.
The inspectors reviewed the licensee's document control activities with respect to the following procedures:
__
..
-
.
'
.
.
QA Procedure No. OP-8, Document Control,' Revision 0
--
QA Procedure No. OP-4, Station Design Control, Revision 6
--
BVPS Operating Manual (0M) Chapters 48 and 55.
--
Review of these procedures and discussions with licensee management and operations Department personnel responsible for the development and review of the aforementioned surveillance procedures indicated that the plant procedures (specifically the OM) does not appear to stipulate that properly approved and controlled as-built engineering information be utilized in the preoaration, review or approval of
~
safety-related procedures or revisions thereto, nor does there appear to be any method of confirming the use of proper documents in that no record of document use appears to exist.
As a result, for the examples previously discussed, procedure writers and reviewers appear to have used information which had been issued for construction as design
'
change output documents that, in some cases, predated actual construc-tion activities and which did not reflect the eventual as-built confi-guration of the system.
In addition to the use of incorrect information, it a ears that con-trolled information which did reflect the actual as-b lt configura-tion of the system was not released and distributed in a sufficiently controlled manner to adequately ensure its availability to groups responsible for the safety-related activities which required the information.
The following specific examples were identified:
Construction information, including design change output docu-
--
ments, was transferred to the station but was not distribated nor made reasonably available to or used by personnel responsible for operating and surveillance procedure preparation.
Station and control room files contained obsolete drawings con-
--
cerning systems required to be operable by TS.
For example, with respect to DCP 201/202, the following elementary electrical drawinas were transmitted to the station via Controlled Document Transmittal Sheet DCP 201/202-46, dated March 5, 1980.
8700-RE-21-MQ, Fuel Building Ventilation, Revision IB-6.
8700-RE-21-MS, Leak Collection Ventilation, Revision 1A-3.
8700-RE-21-MH, Purge and Exhaust Ventilation, Revision 18-4.
On April 11, 1980, the control room controlled drawing files con-tained Revision 1 (issued in 1976) of each of the drawings abov.
..-
-
.__
.-
--.
.-
--
..
...
-. -
_
,
'
.
.-
'
,
.
.
.
..
The as-built drawings listed above were not forwarded to/ received
--
by the station until March 17, 1980 and were not introduced into the station files system until April 9,1980.
The Controlled Document Transmittal Sheet (above) was annotated to indicate that the drawings transmitted had not yet received final engi-neering checking.
As a result of the station files containing obsolete information
--
goncerning the modified systems, the information utilized for procedure preparation and system operation appears to have been obtained by informal means, including verbal communications between operators and contruction personnel.
The above examples are contrary to the requirements of 10 CFR 50, Appendix B, Criterion VI, the BVPS FSAR, Appendix A.2.2.6, QA Proce-dure OP-4, Section 4.6.2, and QA Procedure OP-8, Sections 8.3.1,.8.3.2, and 8.3.3 and constitute an item of noncompliance (80-09-13).
With respect to the above findings, the inspectors also expressed concern regarding past practices for the use of controlled drawings and engineering information in operations, maintenance and procedure writing activities.
The results of this inspection and the findings documented in IE Inspection Report No. 50-334/79-18 indicate that a long term problem with the availability of as-built information affected by the design change program may exist.
Additionally, discussions with senior licensee personnel and station management indicate that con-struction phase field change information may not be consistently incor-porated into issued drawings and further affects their quality.
Accordingly, by copy of this inspection report and its accompanying letter, the licensee is requested to respond to the following requests for information:
Provide an assessment of past practices with regard to the qua-
--
l lity of information utilized in the preparation of operating,
'
maintenance, test, modification, etc. procedures with respect to the availability of accurate as-built information.
Such an i
assessment should be based upon a systematic review of the l
potentially affected safety-related activities and should provide the bases for the conclusions drawn.
The discussion should also include these activities or systems which can result in the radia-L tion release to the environment.
!
Provide an assessment of and the plans and schedules for correct-
--
ing any deficiencies in issued drawings and engineering documents which have resulted from construction phase changes which are not currently reflected in controlled documents available at the station.
This assessment should address the capability to per-form safety-related operations, maintenance and engineering
i
-.
... _.
-
.
_
, -.
.. -..
_ _.. _ _. _.. _ _ _. _.. _,. _ _... _
-
_. -..
__
__
-
~
s
.
.e
~
-
-
,
.
,
.
,
activities, and respond to plant emergencies with currently available information.
These matters will remain unresolved receipt and review of the licensee's response by NRC:RI (80-09-14).
11.
ERRATA - IE Inspection Report 50-334/80-01 In IE Inspection Report No. 50-334/80-01, Paragraphs 8.a and 8.c discussed the inspectors' reviews of two radiological events.
Both paragraphs included quantitative data reported in units of microcuries per cubic centimeter (uC1/cc) or microcuries per milliliter (uCf/ml).
The report, as issued, erroneously reported all such data using scientific notation with positive powers of ten vice negative powers of ten.
For example, in paragraph 8.a(1), the air grab sample from the area of the Solid Radwaste Area door should have been reported as 1 x 10 10 uCi/cc vice 1 x 1010 (as issued).
Only data with the units discussed above was incorrectly reported.
All other units and orders of magnitude are correct.
12.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, items of noncompliance or devia-tions.
Unresolved items addressed during this inspection are discussed in paragraphs 2, 4, 6, and 7 of this report.
13.
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 conclusion of the report period.