IR 05000334/1992028

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Insp Repts 50-334/92-28 & 50-412/92-27 on 921215-18.No Violations Noted.Major Areas Inspected:Design Changes,Mods, TER Process,Lers & Status of Previously Identified Open Items
ML20138D626
Person / Time
Site: Beaver Valley
Issue date: 02/02/1993
From: Bhatia R, Paolino R, Ruland W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138D624 List:
References
50-334-92-28, 50-412-92-27, NUDOCS 9302230023
Download: ML20138D626 (3)
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F U.S. NUCLEAR REGULATORY COMMISSION REGION 1 DOCKET / REPORT NOS. 50-334/92-28 50-412/92-27 LICENSE NOS. DPR-66 NPF-73 LICENSEE: Duquesne Light Company P.O. Box 4 Shippingport, Pennsylvania 15077 FACILITY NAME: Beaver Valley Power Statio- ( aits 1&2 INSPECTION AT: Shippingport, Pennsylvania INSPECTION DATES: December 15-18, 1992 INSPECTORS: ht _

R. Bhatfa, Rdactor Engineer //

2-[93 Date Electrical Section, EB, DRS

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R. Paolino, Sr. Reactor Eng(p6er, bate Electrical Section, EB, DRS APPROVED BY: .

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W. Ruland, Chief, Electrical Section, ' D' ate Engineering Branch, DRS Areas Inspected: Routine announced inspection of the engineering and technical support (E&TS) program activities in support of plant operations, including design changes, modifications, technical evaluation report (TER) process, licensing events reports (LERs),

and status of previously identified open items.

Results: NRC inspection and review of a select sample of design changes / modifications, technical evaluation reports (TERs) and licensing events reports (LERs) form the basis for determining that the documents reviewed and the data contained therein was of good quality and technically accurate. The inspector reviewed three previously identified open items.

Licensee documented evaluation and corrective actions taken provides justification for closure of two items.

9302230023 930210 PDR ADOCK 05000334 Q PDR

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1.0 PURPOSE The purpose of this inspection was to assess the quality and adequacy of the licensee's -

engineering organization in support of plant operations. Areas examined included:

major / minor design changes and plant modification, technical evaluation report process and-their resoltaons, licensing event reports, and status of previously identified open items.

2.0 ORGANIZATION q During this inspection, the inspectors noted that licensee management and staff personnel for -

all aspects of operation of the Beaver Valley Nuclear Powu Station were located on the R

Beaver Valley Site. The current organization chart indicates that the Nuclear Engineering:

Department (NED) reports through its manager to the Corporate Nuclear Services Unit General Manager. NED was organized into six functional engineering sections: clectrical ~

and controls, general and plant, nuclear services, computer, engineering and design services, materials and standards.

The inspector noted significant organizational changes from previous inspections in NED.

The functional electrical engineering and I&C group have been increased from two_ to four sections. Several engineers were reassigned within the various functional groups to better .

serve and strengthen the NED overall design organization functions.

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The inspector concluded that with the above positive changes, which included two additional.

supervisors, the licensee was in a better position to provide technical support to the plant. .;

3.0 ADN11NISTRATIVE CONTROLS FOR ENGINEERING ACTIVITIES The inspector reviewed selected administrative and engineering procedures to determine whether the engineering activities were specified and controlled by approved procedures- . j which provide for meeting the licensee.'s objectives and commitments. Procedures reviewed by the inspector included those for initiating engineering work, station modification requests, design control work, safety evaluations, technical evaluation reviuvs and engineering modification prioritization work. The inspector found that the licensee's initiating and performance procedures for engineering activities provide adequate guidelines, controls and specific requirements to ensure that design,' design changes and modifications are performed in accordance with current approved procedures that comply with accepted industry standards. These procedures provide appropriate requirements and guidelines for thel 10 CFR 50.59 screening and safety evaluations, verifications of design input, calculations, and final design and proper approvals.

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The inspector also reviewed the licensee's program for prioritizing the engineering design modifications. The licensee's recently developed a new workload priority system (NGAP 2.17) which provides a unified system to identify the most important task at BVPS through the use of a common set of criteria. A unified common criteria prioritization system was considered to be a positive factor toward improvement of the engineering scheduling system. A sample review of the priof ty list developed by this system indicates that a number of higi. priority items cannot be done in the upcoming refueling outage because of the large number of items maintained in this s):: tem. Typically, in each unit outage, only twenty to thirty modifications can be completed. The licensee agreed to review the prioritization process and take appropriate corrective action to refine this process. The inspector had no further questions.

4.0 DESIGN CIIANGE AND MODIFICATION PROGRAM IMPLEMENTATION Procedure No. NEAP 2.2, Revision 5, " Design Change Control," dated September 18,-1992, was established to control the major plant modification packages. Minor modification controls are addressed in Procedure No. NEAP 2.19, Revision 1, " Minor Design Change Control." These procedures provide guidelines for the evaluation of approved station modification requests (SMR), preparation of conceptual designs, review and approval of modification packages, procurement, installation and post-modification testing of the hardware. The procedures also outline the requirements for other specialty groups (such as fire protection, environmental or seismic etc.) when required.

The inspector reviewed selected design changes and modifications to ascertain that the changes / modifications were performed in conformance with the requirements of the Technical Specifications (TS), Code of Federal Regulation (10 CFR), the Safety Analysis Report, the licensee's quality assurance program and licensee Procedures. Modification packages selected for review from each facility included:

  • DCP No.1531, Revision 0, BVPS Unit-1 Replacement of Three Obsolete Inverters.

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  • DCP No.1575, (SMR No.-1997-2) BVPS Unit-1 D/G Fuel Oil Transfer Pump Gage Replacement.
  • DCP No.1887, (SMR No. 2458) BVPS Unit-1 Complete Isolation of Sensors to Solid State Protection System (SSPS).
  • DCP No.1890, (SMR No. 2395) BVPS Unit 1 Replacement of ASCO Valves.

The inspector concluded that the design changes and modifications were complete, technically accurate, and supported by plant operational tests. The programs for completing the design change and modifications were generally of good quality. The completed packages were reviewed by cognizant personnel and approved in accordance with established procedures and regulatory requirements.

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5.0 TECIINICAL EVALUATION REPORTS /RFSOLUTIONS  !

The inspector reviewed the licensee's Technical Evaluation Report (TERs) process to determine whether any safety concerns have resulted due to the implementation of this program, especially in reference to 10 CFR 50.59 safety evaluations for changes, tests or experiments, j

Nuclear Engineering Administrative Procedure (NEAP) No.2.13 was establisited to control the TERs at Beaver Valley Units 1 and 2. The TER process is utilized to evaluate the acceptability of discrepancies between a design document and as-feund condition, vendor technical information revision, design equivalent changes, and to evaluate existing se_ tpoints and vendor-approved part changes of replacement parts. The TER process is considered an integral part of the design control program and was used to control the above type of engineering evaluations that were not controlled by the design change package (DCP) control process.

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The inspector reviewed a representative sample of eight TERs. The sample reviewed was found to be of good quality with all documentation completed according to the established procedure. The 10 CFR 50.59 safety evaluations were completed as part of the TERs as required. The inspector's review of safety evaluations revealed no concerns.

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5 6.0 LICENSEE EVENT REPORTS (LERs)

The inspector reviewed the licensee's incident reporting program to assure that the Licensee Event Reports (L.ERs) were evaluated and controlled per established procedure and in accordance with 10 CFR 50 requirements.

Procedure No. NGAP 5.2, " Preparation of Incident Reports, Conduct of Critiques and Follow up Actions," provides guidance for the preparation, review, follow up actions to identify and initiate root cause analysis of incidents. -l LERs examined for this determination included:

  • LER No. 334/92-06, Unlocked Hi-Rad Area Door.
  • LER No. 334/92-08, Incomplete Containment Hydrogen Surveillance.
  • LER No. 412/92-09, Low Suction Pressure on Recirculation Valve Cycling and Main Feedpump Trip Due to Faulty Relay bitching.
  • LER No. 412/92-10, Containment Air Recirculation Fan Breaker Trip.
  • LER No. 412/92-11, Inadvertent Deactivation of CIA Signal.
  • LER No. 412/92-12, Missed RCS Dissolved Oxygen Sample.

The LERs were complete and technically accurate. A detailed, in-depth root cause analysis

! was performed where applicable and corrective actions taken were prompt and appropriate.

7.0 STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS (Open) Dcviation No. 50-334/89-25-01. pertaining to the Steam Generator Wide Range .

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Level Indicators (SGWRL). Regulatory Guide 1.97, Revision 3, Design and Qualification l Criteria, Table I, specifies independent and redundant instrument channels for category I

variables. It also specifies that the transmission of signals from these channels be through

! isolation devices that are part of the loop.

The .NRC inspection 50-334/89-25 determined that no isolation was provided between the instrument loops for transmitters FW-477, FW-487 and FW-497, and the common 3-pen strip chart recorder. In addition, separate indicators were not provided for each instrument loop.

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In a letter to the NRC, dated June 15,1992, the licensee has committed to a tentative schedule for implementing modifications that will ensure that the SGWRL instr mentation is in conformance with the separation, power supply, display, and single failure c Hon for 1504 Regulatory Guide 1.97, Category 1 instrumentation. A Design Change Request, No was issued to upgrade the SGWRL to include additional level recorders and isolation devices.

The licensee was proceeding with the upgrade and is planning to perform the channel modi 6 cation during the ninth refueling outage (9R) projected to begin in February,1993.

The modi 6 cation will:

  • Isolate each SGWRL instrument loop from its respective computer inputs with a QA Category 1, Class lE isolation device.
  • Ensure that the SGWRL recorders and their associated power supplies are QA Category 1, Class lE components.
  • isolate each SGWRL instrument loop from the common indicating meter in the auxiliary feedwater pump room or remove the common meter from the loops.

The above modi 6 cations will result in the following:

  • Display redundancy for the SGWRL loops in the control room.
  • Computer system isolation from the SGWRL loops.
  • Assurance that the SGWRL instrumentation channels are electrically isolated from associated non-1E or common components in the loops.

Existing compensatory measures, consisting of weekly checks between the control room indication, computer system and remote shutdown panel will remain in effect as applicable.

This item remains open pending completion of the modifications.

(Closed) ' Unresolved item No.50-334/89-25-02. pertaining to lack of isolation devices for redundant channels. Regulatory Guide 1.97 specines that redundant channels of instrumentation be electrically independent and physically separated from each other in accordance with Regulatory Guide 1.75, " physical Independence of Electrical Systems", up to and including any isolation device. The inspectors noted in reviewing licensee drawings that Unit I does not typically have isolation devices before instrument loops enter the control board.

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7 Based on the licensees review of its Regulatory Guide'l.97, Category I variables, the licensee indicated that isoir. tion was provided to the PVS/SPDS computers. In addition, to-maintain separation of redundant systems, the licensee applied qualified protective wrap to cables to the vertical boards, thus eliminating the nud for isolation devices.

This item is closed.

(Closed) Deviation No.50-412/89-23-03, pertaining to unqualified recorders. Regulatory Guide 1.97 specifies seismically qualified recorders for Category 1 variables. Records reviewed by the inspector indicate that the Steam Generator Level - Narrow Range Recorders ,

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2FWS-FR478,2FWS-FR488 and 2FWS-FR498 are not seismically qualified.

Licensee letter of March 9,1990, documents the justification for not having seismically qualified recorders for Unit 2 Steam Generator Ixvel - Narrow Range Indication. The licensee review and verification by the inspector of the Unit 2 Steam Generator - Narrow Range instrument channel show that the recorders were electrically isolated from the class lE powered instrument channels. The recorders were not powered from a class IE source. The -

indicating channels were qualified to the Regulatory Guide 1.97, Category I recommendations from the sensors to the display meters. The display consists of nine (9) i meters (3 per steam generator) thus providing three (3) redundant channels per Steam Generator - Narrow Range. A review of the Emergency Operating Procedures (EOPs) l indicate that the Steam Generators - Narrow Range Recorders were not required for immediate trending purposes by the operator. The inspector noted that in the event of failure of the recorders, the operator can retrieve the level information stored in the computer. The inspector determined this to be acceptable.

This item is closed.

8.0 CONCLUSION The cagineering and technical support provided for the operation of the Beaver Valley Power Station was adequate. The quality of design changes, technical evaluation resolutions and licensing event reports was found to be good. Numerous improvements were made during the past year to enhance support to plant operations. The inspectors review of documented reports indicate licensee adherence to procedures and timeliness of the corrective actions.

Three previously identified open items reviewed were closed.

9.0 EXIT MEETING At the conclusion of this inspection on December 12, 1992, the inspector met with licensee representatives denoted in Attachment 1. At that time, the inspector summarized the scope and findings of this inspection.

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l NITACllMENT 1 i

Persons Contacted Duauesne Licht Company R. F. Balcerck, Manager, Management Services

  • F. Cavalier, Director, Project Management
  • E. Coholick, Station Superviser, Licensing P. W.

Dearborn,

Supervisor, Engineering A. J. Fenwick, Director, Nuclear Records R. Ferrie, Senior Engineer, Engineering Management Services

  • K. E. Halliday, Nuclear Engineering Department
  • R. Hansen, Director, General Engineering
  • F. J. Kipchick, Senior Supervisor, Licensing D. G. McLain, Manager, Technical Services
  • S. Nass, Director, Nuclear Engineering Department
  • T. P. Noonan, General Manager, Nuclear Operations
  • M. Pavlick, Director, Quality Services
  • M. Perger, Director, QSI Inspection & Exam
  • D. Schmidt, Director, Electrical Engineering J. D. Sieber, Vice President, Nuclear Group
  • D. E. Spoerry, General Manager, Nuclear Operations Services
  • J. E. Starr, Supervisor, Engineering Management Services
  • D. Szucz, Senior Engineer, Licensing
  • G. S. Thomas, General Manager, Corporate Nuclear Services
  • N. Tonet, Manager, Nuclear Safety K. E. Woesser, Project Manager, SSFE

T 7.yra, Director, Plant Performance

  • J. Vassello, Director, Licensing G. Kammerdeiner, Director, Materials and Standards Engineering U.S. Nuclear Regulatory Commission L. Rossbach, Resident Inspector
  • P. Sena, Resident Inspector
  • Attended exit meeting.

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