IR 05000334/1986008
| ML20203H258 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/16/1986 |
| From: | Eapen P, Harris D, Hunter J, Meils E, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203H238 | List: |
| References | |
| 50-334-86-08, 50-334-86-8, GL-83-28, NUDOCS 8608040346 | |
| Download: ML20203H258 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-334/86-08 Docket No.
50-334 License No.
DPR-66 Licensee: Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Station, Unit 1 Inspection At:
Shippingport, Pennsylvania Inspection Conducted:
June 2-6, 1986
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Inspectors:
o G. Nghuda, Lead Reactor Engineer
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7l/6lVh 0.diarris, NRC Consultant-dite
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g/ G. Hunter III, Reactor Engineer
/ crate Q/f& L 7/lt{9G G. Meils, NRC Con #ultant
' date Approved by:
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Dr.P.K.Eapen, Chief,[QualityAssurance
/ da'te Section, OB, DRS Inspection Summary: Special announced inspection on June 2-6, 1986 (Report No. 50-334/86-08).
Areas Inspected:
Licensee's actions to address the concerns identified in NRC Generic Letter 83-28 in the areas of Equipment Classification, Vendor Inter-face, Post Maintenance Testing, Plant Surveillances, and QA/QC Overview.
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l Results: Two Violations (failure to maintain cable separation criteria, and i
failure to completely fill out required information on Maintenance Work Requests (Paragraphs 3.2a, and 3.2c(1), respectively)) and four unresolved items were identified.
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1.0 Persons Contacted Duquesne Light Company (DLCo)
- H. R. Caldwell, Director of Instrumentation and Controls (I&C)
D. Carothers, Electrical Maintenance Supervisor D. Croft, Shift Technical Advisor (STA)
- T. Dowhy, Engineer
- C. E. Ewing, Manager Quality Assurance (QA)
- S. C. Fenner, Director of Quality Control (QC)
- K. O. Grada, Manager - Nuclear Safety
- R. Hansen, Director of Site Maintenance
- D. C. Hunkele, Director of QA Operations
- T. D. Jones, General Manager - Nuclear Operating Unit
- F. Lipchick, Senior Licensing Supervisor
- K. B. Lowrie, Material Procurement Supervisor F. J. Mantine, Principle Engineer
- W. J. Mercer, Test Supervisor
- S. Nass, Supervisor Engineer
- M. A. Pergar, QC Supervisor
- R. D. Ruga, Manager of Technical Services
- D. Schmitt, Acting Director Nuclear Engineering Dept. (NED) - Electrical
- B. F. Sepelak, Licensing Engineer
- H. M. Seigel, Engineering Manager
- G. S. Sovick, Senior Licensing Supervisor U.S. Nuclear Regulatory Commission (USNRC)
- A. A. Asars, Resident Inspector
- L. E. Tripp, Chief, Reactor Projects Section 3A
- W. M. Troskoski, Senior Resident Inspector
- Attended exit meeting held June 6, 1986 The inspectors also contacted other administrative and technical licensee personnel during the course of the inspection.
2.0 Inspection Summary 2.1 Background The reactor trip system, as part of the reactor protection system, is fundamental to reactor safety for all nuclear power reactor designs. Transient and accident analyses are predicated on the assumption that the reactor trip system will automatically initiate reactivity control systems on demand to assure that fuel design limits are not exceeded. The design and regulatory philosophies for attaining the high reliability required of the reactor trip system have been primarily on the use of redundancy, periodic testing, and quality assurance.
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In February 1983 the Salem Nuclear Power Station experienced two fail-ures of the reactor trip system on demand.
Regulatory and industry task forces were formed to determine the safety significance and gen-eric implications of the events.
Based on these findings, certain actions were required of all licensees.
Thase actions, transmitted in Generic Letter 83-28, fell into four areas.
(1) post-trip review, (2) equipment classification and vendor interface, (3) post-maintenance testing, and (4) reactor trip system reliability improvements.
DLCo submitted their response to Generic Letter 83-28 in letters list-ed in Attachment A.
This inspection included the areas of equipment classification, vendor interface, post-maintenance testing, and QA/QC interface.
2.2 Inspection Results Two violations and four unresolved items were identified. These findings are discussed in paragraphs 3.2a, 3.2c(1), 3.2e and 5.2c.
Except for the violations and unresolved items, the licensee's actions were found to be adequate to address the concerns of Generic Letter 83-28 and consistent with the statement in the licensee letters listed in Attach-ment A.
3.0 Equipment Classification 3.1 Program Review The inspectors reviewed the applicable documents, listed in Attach-ment A, and determined that the Equipment Classification Program addressed the following:
Safety related components identified as such in written
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procedures for procurement, maintenance, and modification.
Management oversight of source documentation for the
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designation of safety related systems and components.
Corporate level procedures for safety related component
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procurement, maintenance, and modification.
Periodic Quality Assurance audits of activities impacting
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safety related equipment.
Corrective action program for safety related equipment.
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3.2 Program Implementation The licensee, in response to Generic Letter 83-28, committed to imple-ment the Master Equipment List (MEL) by January 1,1984 as the primary index used to identify safety related equipment. The MEL is a compa-ter listing by equipment number which provides such information as safety classification, vendor manual references and manufacturers data. The BVPS Unit 1 Quality Assurance Program, Appendix B also identifies those structures, systems and major components that are covered by the Operations Quality Assurance Program.
The inspectors reviewed applicable MEL listings for the components specified in the following paragraphs.
A field comparison of system mechanical drawings and electrical ele-mentary diagrams versus installed equipment was performed to assure completeness and accuracy of MEL.
From this comparison, components were selected to verify the effectiveness of the licensee's Equipment Classification Program.
For each system, the selected components and the review of the adequacy of their procurement, receipt, storage, handling and modification are discussed below.
The plant was in refueling outage during this inspection.
a.
Reactor Trip System (RTS)
Maintenance Engineering provided a print-out of the MEL for Reac-tor Trip Breaker A (RTA). The MEL showed the breaker as CAT I, Safety Related; also a spare parts list was generated showing warehouse stock numbers, purchase order specification number, and quantity on-hand in the warehouse.
During the walkdown on the RTS, the control wiring cubicle was examined. The inspector noted that safety-related circuits of different trains were in conflict with the UFSAR, section 8.5, page 8.5-3.
The UFSAR states that separation between redundant safe-guards wiring is either maintained by a fire barrier or an air space of six inches minimum. The circuits in violation are:
B Train (Purple)
A Train (orange)
IRD1BPC601 and IRDSN0C008 IRDSNPC501 and IRDSN0C017 IRDSNPC007 and IRDIAOC601 IRDSNPC003 and IRDSN00500 The method for supporting these cables was a small square piece of plastic with double back foam tape and a tie-wrap. The in-spector informed the licensee that the adhesive on one support had deteriorated and the support was hanging from the cable.
The failure to adhere to the electrical separation criteria is a violation (50-334/86-08-01).
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During a walkdown the inspector observed Train A and Train B associated circuits routed in a common nonsafety related cable tray.
UFSAR section 8.5 page 8.5-3 states; "A nonsafety related cable may run in a raceway with a safety related cable, but once associated with one train or channel, it cannot run in a raceway assigned to another train or channel".
The following cables in question were determined to be associated circuits:
IRDIANX900 and IRDSA0K600 IRDIBNC905 and 1FWSNPC041 IFWSN0C040 and 1RDSNOC001 ITMANOC605 and 1RDIANC905; The above associated circuits are routed in a common non-safety related cable tray.
Further evaluation by the licensee is re-quired to demonstrate compliance of these circuits with the UFSAR criterion listed above concerning the control of circuit routing.
This is an unresolved item (50-334/86-08-02).
The inspector noted that the bypass breaker 'B' was missing a shield plate inside the cubicle that covers the trip and close switches and that screws and nuts were loose in the door.
The inspector brought this to the attention of the licensee who took action to locate the plate and tighten the screws.
Maintenance Work Request (MWR) #856268 to replace the undervol-tage trip attachment was reviewed. This work was being done on June 3, 1986. The MWR did not contain an installation pro-cedure or set of work instructions to verify correct and consis-tent installation and adjustment of the relay. The installation was to be conducted in accordance with the vendor (Westinghouse)
guidance. However, no such written vendor guidance was avail-able at the Work Station. A Westinghouse representative was present while this work was being performed and was giving ver-bal instruction to the plant electrician on the installation and adjustment.
This vendor representative also did not have the applicable written vendor instructions with him.
Further investigation by the inspector identified that the re-quired guidance was available in the appropriate vendor manual.
The vendor representative informed the inspector that he was preparing a procedure to provide formal guidance for this work in the future. The MWR required post maintenance test (1-RP-BK-RTB-IE) to assure proper operation prior to return to oper-ation.
The inspector stated to the licensee representatives that not having applicable written vendor guidance at the Work Station and depending strictly on the vendor representative's verbal instruction for installation indicate:
(1) a lack of awareness of the licensee Quality Assurance Program, on the
part of the vendor representative and (2) a lack of control of the vendor activities by the licensee. A similar lack of vendor control was also reported in Inspection Report No. 50-334/86-06 as a violation.
This item will be tracked under the existing violation (50-334/86-06-02).
A listing of the MEL for Motor Generator Set breakers (MG-set),
showed the breaker to be Category I, non-safety related. MWR 837416 removed a part from an MG-set breaker for use on a re-actor trip switchgear breaker.
The MG-set breakers are not in the same program of surveillance, and preventive and corrective maintenance testing as the safety related reactor trip system components.
The licensee is currently writing an Engineering Memorandum to address the safety classification of the MG-set breakers. The use of a non-safety related part on safety related equipment without a 10 CFR 50.59 Safety Evaluation is an unre-solved item pending the determination of the correct safety classification of the MG-set breakers.
(50-334/86-08-03)
The inspector reviewed Design Change Package 622, including the 10 CFR 50.59 Safety Evaluation, design scope and concept, equip-ment classification, and Duquesne Light Company Specification j
8700-DES-47, " Automatic Actuation of Reactor Trip Breaker". The applicable documents were reviewed for proper safety classifica-tion and found acceptable.
b.
Class 1E Electrical Systems The inspector reviewed the MEL for the undervoltage and degraded voltage relays on the 4.16kV 0F Switchgear (VF100 and VF2100) to verify proper classification.
The relays were inspected for correct labeling and component identification. The inspector found that all terminal blocks were labeled and numbered and the cables were properly tagged.
The MEL listing did not however classify the relays as Category I.
The licensee was notified of this apparent discrepancy for appropriate action, c.
Charging System 1.
Mechanical The inspector selected the B Charging Pump (CHP-B) and the suction valves from the RWST (MOV CH115B, M0V CH1150) for verification of proper classification. The MEL listing provided by the licensee designated the components as safety related Category I which agrees with the Quality Assurance Program, Appendix B classification.
The inspec-tor verified that the above components were correctly classified in the Maintenance Work Requests and Maintenance Procedures listed in Attachment.
The inspector held discussions with the Director of Site Maintenance concerning QA audits, personnel training and component failure trending. The Director informed the in-spector that the Maintenance area is audited by QA at least annually. Maintenance is also indirectly audited by QA because of the working interface that exists with Stores and Rad Con. QA audit findings are evaluated by mainten-ance supervisors and corrective action is initiated.
Per-sonnel are informed of QA requirements for Safety Related equipment through the Conduct of Maintenance Manual and General Maintenance training.
Personnel are also instruc-ted on the use of the MEL and QA Program for component and system classification.
The Maintenance engineers do not trend specific component failures, however they do trend LERs, recurrent failures, and incident reports.
While reviewing Maintenance Work Requests (MWRs) (listed in Attachment A) related to the Charging and Safety Injec-tion System the inspector noted that eleven out of twelve MWRs were not filled out in accordance with Site Administra-tive Procedure Chapter 3D
"The Maintenance Work Request".
QA had previously identified an excessive number of uncom-pleted " Post-Maintenance Test" blanks during an audit of completed MWRs from 1985. As part of the correptive ac-tion, Site Administration Procedure Chapter 3D Was rewritten with the Appendix 'C' section modified to more clearly de-lineate responsibilities and provide guidelines for deter-mining the need for Post Maintenance Testing.
The sections identified by the inspector as not filled out according to the procedure are listed below:
MWR Deficiencies (Missing Items)
860186 Maintenance Engineer signature, E.Q., ASME Section XI 856913 Post Maintenance Test, Material Requisition, Leadman date of signature 852192 Maintenance Engineer signature 856940 Post Maintenance Testing, Technical Speci-fication blanks 842700 Various blanks 850873 Adequate Post Maintenance Test request 841354 Shift Supervisor signature indicating satis-factory completion of work and testing but no test documentation available.
847867 Post Maintenance Test 865053 Maintenance Engineer signature 860272 Material Requisition, Maintenance Engineer signature 852586 Material Requisition, Maintenance Engineer signature, blanks
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The identified failures to adhere to Site Administration Procedure Chapter 3D is a violation.
(50-334/86-08-04)
(2) Electrical Systems Review of the MEL for charging Pump B breakers and switch-gear showed the system to be CAT I, safety related. A walkdown of the electrical portion of charging pump B was conducted. The elementaries reflected the plant as-built condition for those portions examined during this walkdown.
All components were identified with name plates at the switchgear cubicle, control room and the remote shutdown panel. All terminal blocks were labeled and terminal points numbered. All cable entering the switchgear was identified with a cable tag.
d.
Safety Injection System The inspector selected the Boron Injection Tank Inlet (MOV SI867A, MOVSI8678) and Outlet (M0VSI867C, MOVSI8670) isolation valves for verification of proper classification. The MEL listing pro-vided by the licensee designated the components as safety related Category I which agrees with the Quality Assurance Program, Ap-pendix B classification. The inspector verified that the above components were correctly classified in those Maintenance Work Requests and Maintenance procedures listed in Attachment A.
During the review of the MWRs the inspector noted that in two cases no documentation of Post Maintenance Testing was available.
This item is discussed in the Post Maintenance / Surveillance Test-ing section of this report.
e.
Instruments and Controls Reactor pressure protection channel I for pressurizer pressure was physically verified in the field by examining the following components:
PT-RC455 pressurizer pressure transmitter IRCPNRX002 pressurizer pressure transmitter cable to penetration IRCPNRX001 cable from penetration to reactor protection rack PQ-RC455 pressurizer pressure transmitter power supply PM-RC455/R I/V input module PM-RC455 signal isolator PI-RC455 pressure indicator PI-RC455A pressure indicator PC-RC455A/R I/V module PC-RC455E signal comparator PC-RC455C signal comparator
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BS-RC455C bistable switch (low PZR press Rx trip)
BS-RC455D bistable switch (low PZR press SI)
PM-RC455A lead lag comparator PM-RC455C/R I/V module RPR-3A K521 SI master relay RPR-3A K609 SI slave relay PA K604 SI slave relay The walk down identified one discrepancy between the latest re-vision and pending revisions of loop diagram 8700-RE22BF-1A2, and the field labeling of components. The following is a listing of the bistable associated with reactor protection Channel I for low pressure SI actuation designations showing the dis:repancy:
SOURCE DESIGNATIONS Field label BS-RC455E
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Loop diagram BS-RC455D Abnormal Operating Procedure (AOP) 13 BS-RC4550 Operating Manual Chapter I BS-RC455E Master Equipment List (MEL)
BS-RC4550 MSP 6.12 Pressurizer Pressure Protection Channel I Test BS-RC455E MSP 6.35 Pressurizer Pressure Protection Channel I Calibration BS-RC455E The maintenance history was examined for the bistable in question.
This examination revealed that the discrepancy in component iden-tification did not affect the work performed on the bistable and associated comparator. This was due to the proper correspondence between the field identification of the bistable and the related procedure identification.
To determine if the label discrepancy would have caused improper action by operations personnel performing AOP-13 the inspector requested the operations personnel to walk through a mock fail-ure of pressurizer pressure transmitter PT-RC455. During the walk through, the Nuclear Control Operator (NCO) identified the apparent discrepancy. The actions taken by the NCO and the Shift supervisor followed a path of proper analysis of the dis-crepancy and resulted in the appropriate bistable manual trip action intended by the A0P. The licensee has initiated appro-priate corrective action to eliminate the component identifica-tion discrepanc.
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While interviewing the I&C group personnel, the inspector was informed that the MEL had possible discrepancies and that it was not recommended for use in determining equipment classification.
The inspector noted that some station personnel were continuing to use the MEL. The licensee had identified possible problems in a letter NDIMNE: 3157 dated February 14, 1986 from N. R. Tonet, General Manager. The letter recommended the use of Appendix B of the Quality Assurance Program to determine safety related classifications of components until the MEL concerns are resolved.
A second letter NDINEM:0674 dated March 31, 1986 from H. M. Siegel stated that the Nuclear Engineering Department had developed a plan to validate the MEL with respect to QA Category I components which will begin April 15, 1986 and be completed by September 30, 1986. The letter also stated that until this program is complete, any information required for specific safety related components should be cleared with the designated engineer or the Director of Nuclear and Mechanical Section.
Since the licensee in response to Generic Letter 83-28 committed to using the MEL as of January 1,1984 as the primary index used to identify safe-ty related equipment, the timely completion of validating the
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safety related classifications of components is an unresolved item (50-334/86-08-05).
f.
Purchasing and Storage Purchase Orders (P0s) C013914, C00840, C002840, C002976, C014756, C015520, C015559, and C021151 were reviewed for the attributes listed below.
Proper safety classification
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Environmental requirements
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Seismic category
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National codes criteria (e.g. IEEE, ASME)
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10 CFR 21 applicability
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Shelf life provisions
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Documentation (e.g. Certificates of Conformance, Test Reports)
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Vendor technical information (e.g. manuals, storage conditions)
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These P0s were associated with replacement parts identified on tnose MWRs selected for review.
The offsite Warehouse and the onsite Storeroom were toured to deter-mine the adequacy of cleanliness, storage, environment, identification, traceability, access restrictions, shelf life control and other as-pects of storage conditions for items associated with the above pur-chase orders. The storage conditions for similar items were also examined.
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It was noted that shelf life control was accomplished by the use of a computerized program.
The expiration dates were also marked on the items' "QA Accept" tags. Other controls and functions such as item stock numbers, locations, purchase order histories and category /clas-sification information were also computerized.
No violations were identified.
4.0 Vendor Interface 4.1 Program Review A licensee task force was established during 1983 to review existing Westinghouse {W), the Nuclear Steam System Supplier (NSSS), bulletins and to determine required actions and dispositions. The Testing and Plant Performance Section is now responsible for reviewing and dispo-sitioning W and other vendor technical information. These reviews are documented on Technical Evaluation Reports (TERs) that are distri-
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buted as appropriate.
The W Bulletins are entered into a computerized
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status tracking system. At the time of this inspection approximately twelve bulletins were open.
Six of these bulletins are dated pre-1986.
Vendor technical information received from other t.han W is also admin-istratively controlled and reviewed.
The solicitation of technical information from vendors who do not routinely provide such information has not yet been incorporated into the licensee's review program. The full implementation of a vendor interface program is dependent on NRC acceptance of the re-suits of the Nuclear Utility Task Force Action Committee (NUTAC)
proposals.
Procedures NEMP 2.18, SAP 24 and TAG 6 are the established written t
administrative controls. A new engineering manual for engineering activities is being developed and will include enhanced administra-tive procedures such as NECUM 6.4 and 2.13 for the control and review of all vendor technical information.
An example of action on and disposition of W information was the
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installation of undervoltage trip devices and counters on the
reactor trip breakers (Bulletin 83-02). Also, type of lubrication and maintenance cycle of breakers was incorporated into plant pro-cedures.
No violations were identified.
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1 4.2 Program Implementation
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The inspector reviewed the vendor interface program implementation with Cognizant Engineering and Maintenance personnel.
Vendor inform-ation received at the station either by mail or from vendor represen-
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tatives is transmitted to Engineering through an Engineering Memoran-
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dum (EM). Engineering evaluates the information and determines the
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applicability to the station. The Engineering Memorandum is returned to the station stating the disposition.
Engineering disposition memos include a recommendation to update the manual if the information is applicable. The vendor information which involves a spare parts change requires a Technical Evaluation by Engineering.
The inspector reviewed two Engineering Memoranda which Engineering had received from the station for evaluation.
The inspector had no further ques-tions.
a.
Reactor Trip Switchgear System The inspector reviewed the Reactor Trip Switchgear System Vendor Manual and verified incorporation of vendor technical bulletin information.
The inspector noted that vendor information was incorporated in The applicable maintenance procedures.
b.
Charging and Safety Injection Systems The inspector reviewed applicable Corrective Maintenance, Pre-ventive Maintenance, and Operating Surveillance Test Procedures listed in Attachment A for reference / incorporation of vendor technical bulletins, reports, manuals and instructions. The procedures reviewed were clearly written and adequately ref-erenced vendor information where applicable.
5.0 Post Maintenance and Surveillance Testing 5.1 Program Review Prccedures in Attachment A were reviewed.
From these, it was deter-mined that the following were addressed during the performance of maintenance:
Written procedures for initiating requests for post maintenance
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testing.
Criteria and responsibilities for review and approval of
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maintenance.
Criteria and responsibilities for the basis of safety related/
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non-safety related activity designate.
Criteria and responsibilities for inspection of post maintenance
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testing.
Methods for performing functional testing following maintenance.
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Administrative controls for documentation of maintenance
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activities.
5.2 Implementation Station Administrative Procedure Chapter 3D "The Maintenance Work Request" requires the operations personnel to review MWRs prior to work initiation and after the completion of the work to determine any post maintenance testing required and to verify satisfactory comple-tion of the testing prior to returning the equipment to service. The post maintenance testing is performed in accordance with written pro-cedures where applicable. All safety relatea work must be completed under an MWR to ensure post maintenance testing requirements are met.
The procedure requires the shift supervisor to ensure the appropriate post maintenance testing was performed to verify operability of the component prior to signing the MWR signifying acceptability for return to service, a.
Reactor Trip System The Reactor Trip Switchgear system was reviewed for compliance with technical specification response times listed in Technical Specification 4.3.1.1.3 Table 3.3-2.
The inspector reviewed BVT 1.3-1,1.8, Rev. O, Eighteen Month Surveillance, and determined that the response times were within the limits of the Technical Specifications.
Preventive Maintenance test 1-1RP-BK-RTA-1E was reviewed for proper acceptance criteria incorporation from vendor manuals and bulletins.
The procedure is also suitable for and used for the performance of post maintenance testing.
b.
Class IE Electrical System The inspector reviewed the undervoltage and degraded voltage relays on 4.16kV DF switchgear surveillance tests.
Surveillance tests MSP 36.48 and MSP 36.50 for December 13, 1984 were reviewed and all data was in compliance with the UFSAR and Technical Spe-cifications setpoints.
c.
Charging / Safety Injection Systems The inspector reviewed Maintenance Work Requests (listed in At-tachment A) for adequate post maintenance testing. Completed Operating Surveillance Tests (listed in Attachment A) which were performed as post maintenance tests to ensure operability were also reviewed for technical adequacy, completeness and supervi-
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sory review and approval. During the review of MWRs the inspec-tor noted two instances where there was no documentation support-ing the performance of required post maintenance tests.
MWR 850873 involved tightening the packing on Boron Injection Tank Inlet Isolation valve MOV-SI-867A.without requesting or perform-ing a valve stroke test prior to declaring the valve operable.
MWR 841354 involved tightening the packing on Boron Injection Tank Outlet Isolation valve MOV-SI-8670 and returning to operable status without performing the requested post maintenance test to stroke the valve.
Upon identification of this finding by the inspector, the licen-see representative provided the following information:
It has been the licensee's position to exempt these and
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similiar valves from post maintenance testing due to the potential for compromising reactor safety while performing the test at power.
The licensee has been granted an exemption from quarterly
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stroke testing for the valves in question.
The licensee concluded based on previous experience (e.g.
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stroke time histories) that the maintenance work was not significant enough to affect the functional capability of the valves.
The licensee takes exception to the ASME Section XI, Article
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IWV-3200 requirement to conduct post maintenance testing after adjustments to packing because:
The licensee has determined that required test is not
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possible at power (Note: The licensee procedure re-quires Modes five or six conditions prior to performing stroke tests of the valves in question.)
The test, if performed at power could compromise Tech-
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nical Specification requirements associated with the baron injection system.
The valves are difficult to reseat after testing.
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Other than stroke time history, the inspectors found no doc-umented bases for not performing the post maintenance test-ing, required by ASME Section XI, Article-3200, after making adjustments to valve packing.
This item remains unresolved (UNR 50-334/86-08-06) pending a detailed review of the
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appropriateness of the licensee practice by the NRC. The NRC review will investigate those valves for which the li-censee would not perform post maintenance tests because of the exemption from at power stroke testing. The review will also determine the appropriateness and applicability of extending the exemption from quarterly stroke tests to all Post-Maintenance testing, and the appropriateness of facility Technical Specifications regarding the Safety Injection (boron injection) System.
The inspector also reviewed certain Preventive Maintenance procedures listed in Attachment A for safety classifica-tion, Quality Control coverage, proper reviews and approv-als, acceptance criteria, and measuring and test equipment.
The procedures provide adequate guidance for correcting normally expected problems during performance of the proce-
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dure. A problem not addressed in the procedure requires issuance of an MWR to initiate corrective action. A sur-veillance critique sheet is included in the procedures to track problems and MWRs initiated.
d.
Trending The inspector reviewed the plant performance group " Testing and Plant Performance Trend Monitoring Report", April 30, 1986.
System parameters for programs addressing heat ex-
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change performance, vibration monitoring, flow and pressure trending for pumps, valve stroke timing, and the RTS re-sponse times were being trended. The STA is responsible for
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day to day monitoring of stroke time data to recognize any developing trends and alert the testing group when trends develop. The inspector also reviewed the valve book which is kept in the control room and determined that it was ade-quately used for its intended function.
6.
QA/QC Interface All Maintenance Work orders (MWRs) are reviewed by QC and include proper safety classification. Notification to QC prior to the commencement of a safety related MWR or Corrective Maintenance Procedure (CMP) is an admi-nistrative procedure requirement. A member of QC attends plan-of-the-day meetings during normal operation. During outages the daily work schedule is reviewed by QC. Additionally, Senior QC personnel maintain day-to-day contact with work foremen.
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l Procedures include details of work and acceptance parameters that are used by QC as inspection criteria. The MWR is signed by the QC inspector and an inspection report is generated.
One such report is usually issued for each CMP or MWR. The QC staff currently consists of 35 licensee employees.
Contracted personnel are used to supplement the staff during peak work periods. Approximately 45 contracted personnel are being used during the current outage.
The QC staff also conducts surveillance of onsite vendors who are authorized to work under their own licensee approved QA Program.
The QA group conducts audits and surveillances on a scheduled basis.
It was noted that surveillances were conducted on radwaste shipment, chemistry, modification, heat exchanger retubing and station battery changeout work activities.
Audit packages were reviewed to verify that checklists were developed and used, identified discrepancies were followed up and the audits were gener-ally conducted as scheduled. The following audits were reviewed.
BV-1-84-39, Nuclear Engineering and Construction
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BV-1-85-18, Material Control
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BV-2-85-23, Nuclear Engineering and Construction
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BV-1-85-36, Maintenance
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A number of checklists of other audits were also reviewed. Vendor informa-tion control, shelf life control, preventive maintenance and post mainten-ance testing were specific attributes of these check lists.
No violations were identified.
7.0 Unresolved Ite:ns Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations.
Unresolved items are discussed in Paragraph 3.2a, 3.2e, and 5.2c.
8.0 Management Meetings Licensee management was informed of the scope and purpose of the inspec-tion at an entrance meeting conducted June 2, 1986. The findings of the inspection were discussed with licensee representatives during the course of the inspection. An exit meeting was conducted June 6, 1986 at the conclusion of the inspection (see Paragraph 1 for attendees) at which time the findings were presented to licensee management.
At no time during this inspectioi, was written material provided to the licensee.
This inspection did not involve any proprietary informatio l
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ATTACHMENT A 1.0 References / Requirements (1) NRC Generic Letter 83-28, " Generic Implications of Salem ATWS Events" (2) 10 CFR 50, Appendix B (3) Beaver Valley I Technical Specifications (4) Beaver Valley I UFSAR (5) Beaver Valley Unit 1 Quality Assurance Program (6) ANSI N18.7-1972, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
(7) ANSI N45.2.2-1972, Packing, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants.
(8) ANSI N45.2.12-1974, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants.
(9) DLC0 Response to Generic Letter 83-28, November 1983 (10) OLCO Letter of November 4, 1983, Subject: Additional information regarding Generic Letter 83-28
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(11) DLC0 Letter of May 10, 1984, Subject: Additional.information regarding Generic Letter 83-28 (12) DLC0 Letter of October 30, 1984, Subject: Additional information regarding Generic Letter 83-29 (13) DLC0 Letter of January 14, 1985, Subject: Additional information regarding Generic Letter 83-28 (14) NRC Safety Evaluation For Beaver Valley Power Station Unit i regarding Generic Letter 83-28 (15) NRC Letter of June 29, 1982 to DLCO, Subject: Testing Requirement Relief and accompanying Safety and Technical Evaluation Reports.
(16) ASME Boiler and Pressure Vessel Code Section XI,1974 edition with addenda.
2.0 Documents Reviewed 2.1 Procedures / Tests OST 1.7.5, Centrifugal Charging Pump Test, Rev. 50 and results of January 14, 1986, March 13, 1986 OST 1.1.10, Boron Injection Flow Path Power Operated Flow Exercise, Rev. 66 OST 1.47.3A, Three Month Containment Isolations and ASME Section XI Test, Rev. 88 SAP 3D, The Maintenance Work Request, Revisions 0-2 CMP 1-75-330 SAP 24, Correspondence Control, Rev. O, October 24, 1984 MSP 6.12, Pressurizer Pressure Protection Channel I Test, Rev. 15, April 22, 1986 and results of November 3,1984, November 8,1984 MSP 36.48, Calibration of Undervoltage Relay 4160 Volt Emergency Bus IDF Loss of Voltage, Rev. 6, and results of December 13, 1984
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- MSP 36.50, Calibration of Undervoltage Relay 4160 Volt Emergency Bus IDF Degraded Voltage, Rev. 3, and results of December 14, 1984 BVT 1,4-11.1.2, Reactor Trip Breakers Monitoring Program, Rev. 1 BVT 1.3-1.1.8, Reactor Trip Time Response, Rev. O PMP 1-RP-BK-RTA-1E, RTA Reactor Trip Switchgear Inspection, Rev. 6, 1-7CH-P-1A-B-C-4M, Charging Pump Speed Increaser Lube Oil Pump Coupling Inspection, Rev. O, April 28, 1986 and results of March 13, 1986 (Pump B), March 19, 1986 (Pump C), April 15, 1985 (Pump C).
1-7CH-P-1A-B-C-3M, Charging /High Head Safety Injection Pump Lubrication Maintenance, Rev. O, July 23, 1982 and results of April 15, 1986 (Pump C), April 15, 1985 (Shaft Alignment), March 13,.1986(PumpB)
1-75-Motor-1E, Pump Motor Inspection, Lubrication and Linestarter Inspection, Rev. 7, May 16, 1986 ano results of June 3, 1986 (RSP-1B Pump Motor)
1-11SI-MOV-867C-1E, BIT Inlet Isolation Valve Motor Operator Inspection, Rev. 1, May 4, 1979 1-75-MOV-1E, Environmental Qualified MOV Motor Operator Inspection, Rev. 3, May 5, 1986 1-75-M0V-2E, EQ MOV Motor Operator Test and Inspection and results of May 30, 1986 (SI-84 2)
CMP-1-7CH-P-18-C-1M, Charging Pump Overhaul, Rev. O, December 4, 1985 and results of January 15, 1986 CMP-1-75-212, Heavy Loads Handling, Rev.13 and results of April 15, 1985, May 10, 1985 and March 13, 1986.
2.2 Manuals / Programs (1) Beaver Valley Power Station Inservice Test Program for Pumps and Valves, Rev. 3, November 15, 1985 (2) Operating Manual Chapter 11, Safety Injection System, Issue 2 (3) G-676586, Westinghouse Switchgear Specifications for RTS.
(4) 8700-7.72-431, Westinghouse Model 764 Differential Pressure Electric i
(5) Transmitter Technical Manual - Installation and Operation
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(6) Limitorque Type SMB Installation and Maintenance Manual, l
Bulletin SMBI 82-8 l
(7) Limitorque Valve Controls Instruction Manual, SMBI-170 (8) Pacific Pump Instruction Book (9) Operating Manual Chapter 1.53C section 4, Abnormal Operating Procedure (AOP) 13 " Malfunction of Pressurizer Pressure l
Control", Rev. Chapter 1.1.5 section 5, Reactor Control and l
Protection, Rev. 4, October 8, 1985 l
(10) Operating Manual Chapter 1.1.5 section 5, Reactor Control and
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Protection, Rev. 4, October 8, 1985 (11) Operating Manual Chapter 6, section 1, Reactor Coolant System l
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2.3 Drawings 8700-RE-IF, 4160 One Line Diagram, Sheet 3 8700-RE22BF-1A2, RCS P2R Pressure Protection I & II Loop Diagram for PT-RC455 and 466.
8700-RE-21DL Elementary Diagram, Emergency System 90*.' Undervoltage Protection 8700-RE-21XT, Elementary Diagram, MOV-SI-867 A&B 8700-RE-21CT, Elementary Diagram, 4KV Electrical System, Sheet 21 of 21 8700-RE-21FN, Elementary Diagram, Charging and Volume Control, Sheet 1 of 7 8700-RE-21KM, Elementary Diagram, Safety Injection, Sheet 4 of 4 RM 155B-10, Reactor Coolant System RM 159A-10, Chemical and Volume Control System RM 167A-8, Safety Injection System, Sheet 1 RM 167B-9, Safety Injection System, Sheet 2 6848043, Westinghouse 260v Switchgear (RTS)
2.4 Maintenance Work Requests (MWR)
860186 B Charging Pump Low 011 Pressure in Speed Increaser 856913 8 Charging Pump Worn Copper River Water Cooling Line and Bad Heat Exchanger 852192 B Charging Pump Speed Increaser Low 011 Pressure 856940 B Charging Pump Floor Block Replacement 842700 Valve MOC CH115B Tripping on Thermal Overload 850873 BIT Inlet Valve 867A Boric Acid Buildup on Bonnet and Body 840562 RWST to Charging Pump Suction Valve MOC CH11510 Boric Acid on Stem 841354 BIT Outlet Valve 8670 Packing Leak 847867 BIT Inlet Valve 8678 Limited Switch Wiring Modification 865053 8 charging Pump Speed Increaser Gear Pump 860272 B Charging Pump Water Leaking from Speed Increaser 852586 8 Charging Pump Shaft Driven Oil Pump Losing Oil Pressure 826454 Replace RTB Contacts 826451 RTA Main Contacts Pitted 837717 Breaker Will Not Close 843136 RTA Breaker Will Not Stay Closed 826464 RYA Main Contacts Out of Adjustment 822039 RYA Control Power Fuses Blowing 837416 RYA Parts from MG-set Breaker 800687 RYB Closing Scienoid, Hung-up Breaker 826455 RTB Contacts Need Adjustment 821161 RYN Repair 822893 RYN Blown Fuse 831688 RYB Relay Replaced 832074 RYB Breaker Would Not Close 837573 RYB Replace Control Relay 856268 Replacement of UVTA 865609 Replace Shunt Trip Coil 865602 Add Operational Counter to RTA
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2.5 Miscellaneous (1) Master Equipment List (MEL)
(2) Valve Stroke Time Book (3) Engineering Memorandum 72229 (4) Engineering Memorandum 61820 (5) Design Change Package #622-Reactor Trip System (6) Testing and Plant Performance Trend Monitoring Report, 4/30/86 (7) Letter NDITAE: 0170 dated 4/15/86, Subject: Quarterly Pump Trend Review (8) Letter NDITAE: 0147 dated 1/10/86, Subject: Semi-Annual Valve Review (9) Letter NDINEM: 0674 dated 3/31/86, Subject: Validation of the MEL QA Category (10) Letter NDIMNE: 3157 dated 2/14/86, Subject: Determination of Safety Related Classification (11) Letter NDIMNS: 4492 dated 12/20/85, Subject: QA Audit BV-1-85-37 (12) Letter NDINCE: 0282 dated 12/11/84, Subject: Vendor Technical Bulletin / Data Letter Task Force Open Item Review and Close-out.
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