IR 05000334/1981007
| ML20004E936 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/16/1981 |
| From: | Beckman D, Caphton D, Napuda G, Petrone C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20004E931 | List: |
| References | |
| 50-334-81-07, 50-334-81-7, NUDOCS 8106160201 | |
| Download: ML20004E936 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-334/81-07 Docket'No. 50-334 Category C
License No.
OPR-66 Priority
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Licensee:
Duquesne Light Comoany 435 Sixth Street Pittsburgh, Pennsylvania 15219 Facility Name:
Beaver Valley Power-Station-Unit 1 Inspection at:
Shippingport and Pittsburgh, Pennsylvania Inspection conducted:
March 2-6, 1981 Inspectors:/-
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0.L. Caphton, Chief, Management Programs Section
Insoection Summary:
Inspection on March 2-6,1981(Report No. 50-334/81-07)
Areas Inspected: Special, announced inspection by two region-based inspectors I
and a resident inspector of the Quality Assurance Program implementation including: design changes / modifications; offsite support staff; organizaticn and administration; procurement control (engineering services); audits; and, followup of previously identified items. The inspection involved 26 inspector-hours onsite by two region based inspectors and 65 inspector-hours at the corporate offices by two region-based and one residcut inspector.
Results: No items of noncompliance were identified.
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Region I Form 12
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(Rev. April 77)
8106100 %
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DETAILS 1.
Persons Contacted F. Arnold, Construction Specialist G. Beatty, QA Enginner S. Bikulege, Supervisor-Station Engineering B. Dawson, Site QA Manager (Schneider Inc.)
- C. Davis, QA Supervisor
- M. Haddad, Senior Project Engineer
- E. Huesmann, BV Project Team
- H. Jimenez, Electric Stations Engineer R. Kight, Project Engineer-Mechanical
- L. Knapp, Senior Project Engineer J. Kowalski, Project Engineer-Nuclear
- E. Kurtz, Supervising Enginsar
- J. Latshaw, Structural Design Engineer
- R. Mafrice, BV Project Team
- R. Martin, Nuclear Engineer A. Miria, Senior QA Engineer
- F. Salmon, Mechanical Engineering Department Head
"H. Siegel, OEG Supervisor R. Stojanovic, Project Engineer S. Stovic, Compliance Engineer
- H. Van Wassen, Project Manager
"J. Walsh, General Superintendent-Construction
- E. Woolever, Vice President B. Zini, Project Engineer The inspectors also held discussions with and interviewed other members
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of the Power Station and Duquense Light Company administrative and technical staff and, contractor technical staff.
- denotes those present at the exit interview 2.
License Action on Previous Insoection Findings (Closed) Infraction (78-08-01):
Failure to execute inspection program for plant modifications. Based on licensee response to IE Bulletin 79-14 a-d the manner in which modifications are presently controlled, the taspectors concluded that such failures should not recur (Referenc 'tragraphs 3 and 6 and IE Inspection Reports 334/80-08 and 14).
(Closed) Infraction (79-18-05):
Station not maintaining as-built drawings showing most recent modifications. Based on the results of this inspection described in Paragraph 3 this item is closed.
(Closed)' Deviation (79-18-08):
Failure to comply with commitments as stated in letter C.N. Dunn to B.H. Grier dated November 29, 1978.
Based on the results of this inspection described in Paragraphs 3 and 6 and IE Inspection Reports 334/80-08 and 14 this item is closed.
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(0 pen) Deficiency (79-18-10):
Failure of records storage to comply wisn ANSI N45.2.9.
As a result of NRC identified problems the manner in which modifications are controlled has been restructured.
During this inspection the inspector noted that current modification documents have yet to be processed into the records system. The licensee stated that the responsibility for various aspects of this activity have not yet been assigned.
Pending review of t!.e manner in which modification packages are incorporated into the records system, this item remains open.
3.
Desfon Changes / Modifications a.
References EMP 1.6, Personnel Training, Revision 4, November 1, 1979
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EMP 2.8, Handling of Design Change Packages, Revision 5,
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November 17, 1980 EMP 2.10, Design and Procurement Specifications, Revi:f on 3,
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July 8, 1980 EMP 2.12, Vendor Information, Processing and Control,
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Revision 1, February 14, 1979 EMP 2.23, Engineering Change Notice, Revision 3, June 12, 1980
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EMP 9.', Record Processing, Revision 2, February 14, 1979
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b.
Review The modifications Ifsted in c. belcw were reviewed on a sampling basis to verify that the following requirements have been implemented as applicable.
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10CFR50.59 reviews were performed and documented
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Design changes / modifications were accomplished and deemed
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satisfactory Procedures and drawings required to be changed or generated
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as a result of a design change / modification were updated or generated Design documents are controlled
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Channels of communications exist between the contracted design organization and the licensee Design change / modification packages are being converted
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into plant records I
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Document / Record Packaces The inspectors reviewed the following design change / modification packages (CCPs) with special emphasis on contracted engineering services.
OCP 130, Aux Feecpump Recirculation Line Piping Modifications
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CC? 166, EPRI Reactor Coolant System Crud, Study
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OCP 180, Modification to Otesel Generator Leading Sequence
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Control Circuitry OCP 204, Replace annunciator and ifne Voltage Regulator-
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l Uninterrupteole Power Supply
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DCP 276, Relocation of Four Narrow Range Steam Generator
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Level T anem#tters DCP 292, PJRV and SV Position Indication
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DCP 293, Subcooled Margin Meter
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OCP 278, Changeout SOVs in SIS per IES 79-01,01A
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CCP 319, Bergen Patterson Snubber Repair
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CCP 320, Post Accident Sampling System
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d.
Detail. 'Inde9th Examination of Certain Documents / Records The inspectors interviewed cognizant personnel and the following additional documents / records to verify the adequacy of the licensee's engineering overview and administrative controls with respect to procured engineering services, acceptable implementation of DCP requirements, and control of changes /
revisions to design channe/ modification documents.
Engineering Change Notices (ECNs) 204-1 through 15
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ECNs 130-1 through 122
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Purchase Requisitions ECs 64357 and 62159 and associated
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ECNs 62159-1 and 2 Appro :mately 82 Engineering Memoranda associated with
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various =cdifications including those listed in c. above Telephone logs and memoranda associated with modifications
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listed in c. above Orawings 8700-RK-1A-6-Al and 11700-RE :
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3; 3 GAD-5A-1; 36AL-48-1; and, 360-48-1 e.
Conclusions and Findings
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(1) The inspectors noted that the licensee corporate Nuclear Section began to conduct an additional safety analysis review of Mechanical Department Engireering modification packages, during October 1980, prior to their final release to the field for implementation.
Further, Memorandum Project Manager /BVT-00025 (a distribution list) dated February 25, 1981, directed that all modification packages now be forwarded to the Nuclear Section for this additional safety analysis review prior to their release to the field for implementation. The licensee also stated that Procedure EMP 2.8 is to be revised to include this additional design change /macification centrol requirement. This safety analysis is then to be used by the OSC for tFeir 50.59 evaluation.
(2) The inspectors stated that the control and overview of contracted engineering services appeared adequate for currently active modifications but expressed concern that this may not be the case should a nominal increase in work-load occur. (Refer to Paragraph 4.b) The licensee acknowledged the inspectors' statements.
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(3) The inspectors stated that they noted a significant improvement in the controls and implementation of design change / modification activities and attributed this to the readily apparent increased attention and control by licensee management.
The inspectors also cautioned licensee management not to reduce or relax this attention and control Just because such improvement has been made. The licensee acknowledged the inspectors' statements.
No unacceptable conditions were identified.
4.
Offsite Succort Staff a.
Review A review of the offsite engineering support staff was conducted by the inspectors including procedure reviews, reviews of personnel qualifications, personnel interviews, procidure implementation and audit report reviews (Reference Paragraph 6) to verify the following:
Developed acministrative controls which describe the re-
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sponsibilities, authorities and lines of communication are readily available
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The managers, group leaders and support staff are. aware
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of their responsibilities and authority as defined by applicable procedures The personnel which compromise the offsite sup,ncet staff
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are techr.ically competent and qualified to execute their responsibilities and authority as defined by applicable procedures Sufficient numbers of Itcensee staff are involYed in con-
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tractor oversight The procedures referenced in paragraphs 3.a in this report are
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in conformance with the requirements of 10 CFR 50, Appendix B, and the licensee's approved QA Program with respect to contracted engineering services Licensee has ability to direct, modify and control engineering
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services contractor /sub-contractor in a timely and efficient manner The offsite support staff activities are effective and
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any deficient conditions, including QA audit findings, are dispositioned in a timely and effective manner
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b.
Findings The inspectors review included but was not limited to the following important elements.
(1) Training records and associated checklists were reviewed for each engineer responsible for the modification packages listed in Paragraph 3.c.
Additionally, the records for 25 other. engineers in the Mechanical and Electrical Engineering Departments were reviewed. These records indicated that all engineers had undergone required 1icensee training, were awarded college degrees and had at least several years of applicable experience.
(2) With respect to active Unit 1 CCPs within the Mechanical Engineering Department 26 modifications were assigned to six engineers in the Nuclear Section; 30 modifications were assigned to four engineers in the Station Section; and 30 modifications were assigned to four engineers in the General Section. The latter two sections' major portion of work is other than nuclear. The inspectors noted
' hat the major portion of design work associated with these
OCPs was actually being accomplished by engineering services contractors and that the assigned engineers were performing an overview function.
(3) The inspectors had requested a summary of engineering manhours expended during 1980 which the licensee obtained from their computerized system and provided to the Senior Resident Inspector subsequent to
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this inspection. The information appears below as submitted.
MANHOURS UNIT 1 UNIT 1 UNIT 2 OTHER TOTAL
% OF TOTAL B.V. Project Team 830 1065.5 2053.5 3949 21.0 12000 100.0 Onsite Engineering Group 12000
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Electrical Eng. Dept.
27321 5718 121904 154943 17.6 Structural Eng. Dept.
15334 4143 40629 60156 25.5 Mechanical Eng. Dept.
18566 8641 12464 39669 46.8 OLC Eng. Total 74051 270717 Notes:
(1) DLC OEG personnel manhours are included in respective Engineering Departments (2) Nonproductive hours, i.e. vacation, holidays, etc. are included in the "Otheri" (non-nuclear) manhours (3) OEG manhours are estimated and are non-DLC personnel O
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(4) The insp;ctors determined, based on the overall results of this inspection, that current assigned engineering manpower appears adeouate for current active workload.
However, the inspectors expressed concern that this manpower may not be sufficient should the workload increase (Reference (2) above).
The licensee acknowledged the inspectors' comments.
(5) The inspectors noted the close day to day contact that assigned engineering personnel had with engineering services contractors, specifically Stone and Webster.
These contacts were evidenced by voluminous telephone memos
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and logs and the engineer's knowledge 'about his assigned project (s). The inspectors stated that it appeared that any significant additional workload assignment to these engineers may prove detrimental to the qtality level of their work. The licensee acknowledged the inspectors' comments.
No unacceptable conditions were identified.
5.
LER Review LER 79-19/01T-1:
The inspector reviewed SVPS-CMP 1-75-165 which documented the work associated with the replacement of suspect wiring for the nine items listed in the attachment to this LER. With respect to Item 5, the inspector determined that the wiring was between TV-SI-101-1 and 2 (the item listed only TV-SI-101).
The documents / records in the subject work package indicated that all nine items have been rewired with
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environmentally qualified material (Reference Stone and Webster 10 CFR 21 Report to Director, Office of IE, dated November 24,1980).
No unacceptable conditions were identified.
6.
Audits A selected sample of audits of engineering activities were reviewed to determine that audit checklists or procedures were prepared and used; auditors were independent of responsibilities for audited activities; identified deficiencies were properly followed up by review of the audited organi:ations' written responses and verification of corrective actions; appropriate distribution of audit reports and responses were made; and, the audits addressed all elements of the audited activity.
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The following audits were reviewed.
BV-1-79-7, Design Change Packages
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BV-1-80-02, Design Control (OEG)
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BV-1-80-04, Stone and Webster Engineering
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BV-1-80-10, Modification Activities
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BV-1-80-28, Design Changes (Reaudit)
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No unacceptable conditions were identified.
7.
QA program Review A brief review of the Operations Quality Assurance Manual (CQAM),
Procedures OP-1 through OP-16, was done to determine that they addressed the Lasic areas specified in the Beaver Valley Power Station Final Safety Analysis Report (FSAR), A..tdment 6, (Decembir 7,1973), Table A.2.2-1, Matrix of Appendix B,10 CFR 50 vs. Operaticns Quality Assurance Program. The inspector noted that the procedure titles listed in the FSAR differed somewhat from those listed in the CQAM.
However, it appeared that the procedures did address the required subjects listed in the FSAR Table Matrix.
No unacceptable conditions were identified.
8.
Presentation of Preliminary Findings Licensee management was periodically informed of inspector findings as folicws:
Date Report Detail
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March 2, 1980 Entrance Interview March 4, 1980 2,
3, 4 March 5, 1980 3,4,5,6 March 6, 1980 Exit Interview A summary of inspector findings was provided to the senior licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection. The licensee acknowledged the inspectors' findings.
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