IR 05000334/1993005
| ML20036A372 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/23/1993 |
| From: | Blumberg N, Fred Bower, Caruso J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20036A368 | List: |
| References | |
| 50-334-93-05, 50-334-93-5, 50-412-93-05, 50-412-93-5, NUDOCS 9305110141 | |
| Download: ML20036A372 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
93-05 l'
Docket Nos.
50-334
I 50412 i
License Nos.
DPR-66 NPF-73
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Licensee:
Duquesne Light Company l
Post Office Box 4 Shippingport, Pennsylvania 15077 l
Facility Name:
Beaver Valley _ Units 1 and 2
Inspection at:
Shippingport, Pennsylvania
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Inspection Conducted:
March 29 - April 2,1993
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3 73 Inspectors:
_F. L. Bbv(Er, Reactor Engineer Date Performance Programs Section j
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Operations Branch, DRS Y$-
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Johri'G. Caruso, Reactor Engineer Da(e -
Performance Programs Section Operations Branch, DRS i
[M J3 fl Approved by:
Norman J.41umberg, Chief Ddte /
Performance Programs Section Operations Branch, DRS 9305110141 930504 gDR ADOCK 05000334 PDR a
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i Inspection Summary: Inspection from March 29 - April 2,1993, (Inspection Report Nos.
50-334/92-05 and 50-412/93-05)
Areas Inspected: An inspection was performed to review areas important to the health and safety of the public and to determine if the licensee had adequately implemented their maintenance program in accordance with regulatory requirements in the areas of control and j
implementation of troubleshooting activities; work planning; quality control of maintenance activities; procurement of materials for maintenance; and receipt inspection.
Results: The inspectors found adequate administrative controls were in place for the development and performance of Maintenance Work Requests (MWRs). From a review of completed work packages, the inspectors concluded that, in general, the licensee had adequately implemented their administrative controls for MWRs (Section 2.2).
The inspectors noted that good administrative controls have been established for troubleshooting activities performed by Maintenance. These administrative controls were satisfactorily implemented, but isolated instances were noted where implementation could be
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improved. The inspectors also noted that administrative controls have been established for
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l tmubleshooting activities performed by Operations; however, it was concluded troubleshooting performed by Operations could be improved by logging and documenting the procedures used to perform the troubleshooting, documenting equipment lineup changes, and l
l logging each Tech. Spec. action statement that is entered and exited (Section 2.3).
I The inspectors determined that the licensee was in conformance with administrative controls for receipt inspection activities. Staffing was adequate to support the daily receipt inspection
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workload; there was no receipt inspection backlog; and, no safety concerns were identified in the area of receipt inspection (Section 2.5).
The inspectors' review of the Quality Control interface with maintenance identified concerns regarding: (1) unilateral waiving of QC holdpoints that may be required by engineering guidelines and standards without initiating a procedure change per technical specifications; (2) the guidelines for including QC holdpoints into maintenance work documents may not be adequate; (3) the guidance and controls provided to allow maintenance supervisors to delete, i.e., mark not applicable (N/A), steps in approved maintenance procedures are limited; and (4) Maintenance Work Requests that do not specifically reference which sections of the attached maintenance procedure are necessary to complete the work activity. These concerns were identified as an unresolved item (Section 2.6).
An unresolved item concerning a licensee commitment to perform an assessment of the effectiveness of the entire Fire Protection Program was closed (Section 3.0).
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DETAILS
1.0 PERSONS CONTACTED
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Attachment 1 provides a listing of persons contacted during the inspection.
2.0 MAINTENANCE IMPLEMENTATION (62700)'
2.1 Scope An inspection was performed to review areas important to the health and safety of the public and to determine if the licensee had adequately implemented their maintenance program in accordance with regulatory requirements in the areas of work planning; quality control of maintenance activities; procurement of materials for maintenance; and receipt inspection.
Additionally, this inspection performed a review of the control and implementation of troubleshooting activities conducted at Beaver Valley. This included reviewing j
troubleshooting activities performed by the Maintenance Department including mechanical,
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electrical, and instrumentation and controls (I&C) troubleshooting, as well as troubleshooting activities performed by Operations and other plant organizations.
I 2.2 Maintenance Work Controls t
2.2.1 Maintenance Work Request Administrative Controls Procedures have been developed by the licensee to provide administrative controls for
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maintenance activities. The inspectors reviewed three procedures that relate directly to the control of maintenance work planning and work performance, NGAP 7.5, MM 4.5 and MM i
4.16. The review identified an appropriate system of administrative controls established for the planning, performance and documentation of maintenance work performed.
Maintenance Work Request (MWR) packages are developed using a computerized MWR system. The following is a list of some of the attributes that must be considered when using the computerized MWR system:
Repair Priority
Plant mode (s) during which repairs should be made and lowest mode during which
testing can be performed Whether the repair involves special controls, such as for an IST pump or valve, a
containment isolation (type C) boundary valve, or equipment qualification This identifies the inspection procedure number used during the conduct of this
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Applicable Technical Specification Limiting Conditions for Operations and required
completion times
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Identification of reference documents such as procedures, drawings and technical
manuals, etc.
Identification of required supporting forms such as lifted lead and jumper logsheets;
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post-maintenance preoperational and operational testing forms; hot work, confined space, and fire barrier permits; and requests for clearance (blocking and tagging),
radiation work permits, security permits, etc.
The inspectors concluded that the administrative procedures reviewed establish appropriate controls for providing work instructions. Attachment 2 of procedure MM 4.5 establishes guidelines for the level of detail required for work instructions for common work activities.
The administrative procedures also establish controls that identify the review and approval required to issue the MWR and authorize work to be performed in accordance with the MWR. The inspectors also noted that these procedures identify the requirements and methods for modifying the work instructions, documenting the completed work, and identifying the root cause of any related failure. In general, the inspectors found satisfactory l
i administrative controls for the development and performance of MWRs.
2.2.2 Review of Completed Corrective Maintenance Work Packages The inspectors reviewed approximately forty completed Maintenance Work Packages to verify that the following attributes had been adequately identified and implemented:
i The procedures specified in the maintenance package were adequate for the scope of j
l the maintenance performed; Required administrative approvals were obtained before initiating the work, and there
l are provisions for obtaining approval from operations as well as notifying operations when affected systems are removed from service and ready to be restored to normal service are present; Functional testing and calibrations,' as necessary, were completed before returning the
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equipment to service, and the measuring and test equipment used was identified and in calibration; Qualified parts and material used were identified and recorded;
The inspection and hold points are identified in the procedure and are based on a set
of established guidelines, and inspections were performed in accordance with procedure requirements; and l'
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The provisions for control of equipment, including lifted leads, jumpers, bypasses,
and mechanical blocks were identified in the work control procedures.
The inspectors concluded that the licensee had adequately implemented the above listed attributes in the sample evaluated and no specific deficiencies were identified. However, the inspectors noted several concerns in completing this review: (1) the Maintenance Work Requests did not specifically reference which sections of the attached maintenance procedure were necessary to complete the work activity; and (2) the extensive marking of nonapplicable (N/A) procedural steps gave the inspectors some concern especially when this was done within applicable sections of the maintenance procedure. These concerns are discussed further in Section 2.6 of this report.
2.3 Control of Troubleshooting 2.3.1 Administrative Control of Troubleshooting by Maintenance Paragraph 2.2.1 identified that the licensee has developed procedures to provide administrative controls for maintenance activities. A review was conducted to determine what administrative controls are in place to conduct activities to identify and correct equipment malfunctions, i.e., troubleshooting. In general, the inspectors found that troubleshooting performed by the Maintenance Department, including ihe mechanical, electrical, and instrumentation and controls (I&C) groups, is controlled by MWRs process and the related administrative controls. Maintenance Manual Section (MM) 4.5 provides guidelines for developing MWR work instructions for maintenance activities that require troubleshooting for unknown conditions on energized, pressurized, or operating equipment.
The inspectors reviewed these guidelines to determine their adequacy.
The inspectors noted that the troubleshooting guidelines in MM 4.5 are additional guidelines provided to the maintenance planner for the development of detailed work instructions for the
" Instructions" section of MWRs. Maintenance personnel indicated that these guidelines were added to MM 4.5 in March of 1991. A summary of the guidance provided by MM 4.5, Attachment 1, " Troubleshooting Guidelines," is as follows:
Prior to developing the troubleshooting methodology, the planner or maintenance
supervisor should consult Systems Engineers, Operations, Technical Specifications, the FSAR, Vendor Manuals, applicable procedures and drawings, etc., to understand the equipment and system interactions As applicable, inclub the following in work instructions to craft personnel:
Notes, cautions and prerequisites for the specific task
Steps to record as-found and as-left o.,ditions
Steps to record abnormalities observed during equipment operation
Steps to take if abnormal or unexpected conditions are observed
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Steps concerning the logging and control of lifted leads and jumpers
Steps for controlling measuring and test equipment
Steps to retain removed equipment for further analysis
Steps to take if a protective device activates during troubleshooting l
I When troubleshooting equipment important to safe and reliable operation, an impact
l statement should be included that identifies the scope of the troubleshooting, the l
required equipment status, the work boundaries, and any potential plant upsets i
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Provide precautions that follow-up corrective maintenance outside the scope of the j
original MWR should be perfonned under a separate MWR The inspectors found no specific procedural requirement that all troubleshooting performed by maintenance must be done using a MWR, but discussions with Maintenance Department managers indicated that in general it was policy to have all Maintenance Department controlled troubleshooting performed using MWRs. The use of the MWR process for (
troubleshooting controlled by Maintenance ensures that all the administrative controls applied l
to the development, review, approval, performance and documentation of work performed by MWRs are applied to troubleshooting. These administrative controls were described in paragraph 2.2.1 above. The inspectors concluded that appropriate programmatic controls are in place for the use of Maintenance Work Requests and good guidelines have been j
established for maintenance to develop detailed troubleshooting instructions to be performed
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using MWR controls. It appears that proper implementation of these administrative controls would provide good control of troubleshooting activities and an appropriately documented historical record of the troubleshooting activities performed.
2.3.2 Review of Significant Troubleshooting Events Conducted by Maintenance The inspectors performed a search of Licensee Event Reports (LERs) and licensee Incident Reports (irs) to identify any recent (i.e., post-1988) significant Maintenance Department troubleshooting events that resulted in a plant trip, engineered safety feature (ESF) actuation, significant safety system degradation, or other significant plant event. These searches identified two significant maintenance related troubleshooting events that resulted in LERs j
being submitted. These LERs were reviewed to assess the adequacy of the controls and their implementation for troubleshooting activities performed by maintenance.
LER 91-016-00 The first LER, 91-016-00, dated June 3,1991, reported that some "B" train temperature switches in the High Energy Line Break (HELB) Detection System failed to trip closed as expected during surveillance testing. The failure resulted from jumpers that were left in the circuitry. These jumpers were left in the circuitry by ongoing troubleshooting efforts that had been postponed to obtain repair parts prior to continuing the tuubleshooting. This
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troubleshooting had been focused on one temperature switch that was causing spurious "B" train operations.
The inspectors reviewed the troubleshooting MWR (910535) to determine if the troubleshooting instructions were appropriate and in conformance with the troubleshooting work instruction development guidance in MM 4.5. The inspectors found the MWR instructions inadequate in that the instructions did not provide steps to record as-found and as-left conditions nor steps conceming the logging and control of lifted leads and jumpers.
These types of steps are required by the guidelines for troubleshooting instructions in MM 4.5. It was also noted that the LER provided more detail concerning the work performed during the troubleshooting and repair activities than the documentation of completed work found on the completed MWR record. Therefore, the inspectors concluded that the level of detail contained in the "Cause of Failure" and " Corrective Action" sections of the MWR could be improved.
The LER identified corrective actions to improve the administrative control of jumpers during troubleshooting and maintenance. The inspectors noted that the procedure for the control of temporary modifications has been revised to provide adequate instructions for conting, logging, and tagging jumpers installed by troubleshooting and maintenance activit es.
LER 91-024-00 The second LER, 91-024-00, September 4,1991, reported that while troubleshooting the "B" loop Bypass Feedwater Regulating Valve, the valve opened resulting in an overfeeding of the steam generator. This event occurred during troubleshooting activities when leads were relanded to restore the control loop to service and an open demand signal to the valve was present. The licensee concluded that the event occurred because the procedure used as guidance was not written for the plant conditions established during the troubleshooting efforts and it was not written to be performed while the valve was in service.
The inspectors reviewed the MWR (914298) to determine if the troubleshooting instructions were appropriate and in conformance with the guidance in MM 4.5. The inspectors determined that the MWR instructions were inadequate in the following areas: (1) the only instructions provided on the MWR were to check the controller / auto-manual station and repair as necessary; (2) the instructions did not provide notes, cautions and prerequisites for the specific task; and (3) the MWR did not include an impact statement, for troubleshooting equipment important to safe and reliable operation that identifies the scope of the troubleshooting, the required equipment status, the work boundaries, and any potential plant upsets. The troubleshooting guidelines in procedure MM 4.5 require providing this information in troubleshooting MWRs. The inspectors also noted that the level of detail recorded in the "Cause of Failure" and " Corrective Action" sections could be improved since this information can provide an important historical recor i.
The inspectors further noted that the MWR was originated, developed and approved by the l
same maintenance supervisor. Although this is allowed by the licensee's administrative procedures, the inspector considers this to be a poor work practice. From discussions with l
licensee maintenance personnel and a review of other MWRs, this does not appear to be a normal work practice, and it appears to have been done as a result of the emergent nature of this troubleshooting.
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Additional information concerning this event, the licensee's corrective actions and the resident inspection staff's review of this LER were documented in Region 1 Inspection Report Nos. 50-334/91-17 and 19.
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2.3.3 Review of Maintenance Work Request Packages for Troubleshooting Activities The inspectors reviewed a selected sample of MWRs to determine the effectiveness of the Maintenance Department's implementation of troubleshooting guidelines, contained in procedure MM 4.5.
In general, it appears that since the issue of the troubleshooting guidelines in March of 1991, the Maintenance department's implementation of these guidelines has been and is continuing to improve. The inspectors found a number of instances where the work instructions provided a good level of detail and met the guidelines provided in procedure MM 4.5.
However, the inspectors found isolated instances where the licensee did not implement their
guidelines adequately. These areas included: (1) providing an adequate level of detail in the l
work instructions provided prior to starting work; (2) providing or documenting additional work instructions, as required by procedure MM 4.16, when work progresses beyond the initial instructions provided in the work instructions section of the MWR; and (3) providing better documentation of the work accomplished to ensure an appropriately detailed history of the work done.
2.3.4 Administrative Control of Troubleshooting by Operations Department A review of Operating Manual Chapter (OM) 1/2.48.1D was conducted to determine what administrative controls are in place for troubleshooting performed by Operations.
The inspectors review of OM 1/2.48.lD identified the following summary of controls provided for troubleshooting conducted on safety-related equipment under the cognizance of the Nuclear Shift Supervisor:
The Nuclear Shift Supervisor (NSS) shall authorize the extent of troubleshooting to be
performed prior to its start and the NSS shall inform affected shift personnel of possible effects that the troubleshooting may have on normal plant status prior to its start; Troubleshooting shall be performed by persons who possess adequate qualifications
and does not require detailed step-by-step procedures;
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Normal precautions from the affected operating procedure apply; l
Documentation of component lineup changes is required to assure proper system
restoration; The temporary installation of jumpers or components shall be controlled by logging
and tagging in accordance with NGAP 7.4; and If troubleshooting is interrupted, the system or component is to be retumed to normal
j status or left in a safe condition and properly blocked and tagged.
The inspectors noted that administrative controls for troubleshooting by Operations provide significantly less guidance than the administrative controls provided to Maintenance. It was also noted that these administrative controls lacked guidance concerning the limitations for l
performing plant operations required for troubleshooting activities without detailed l
procedures.
l The inspectors interviewed the Unit 2 Operations Manager and several senior licensed operators concerning the practices for performing troubleshooting activities. These Operations personnel indicated that troubleshooting is typically performed to identify the scope of work required for a MWR. From these discussions it appeared that Operations l
Department policy is that, when possible, troubleshooting is performed by using and adhering to existing operating procedures. When noncomplex troubleshooting is performed that requires operations that are not covered by an existing procedure, these operations will be performed by licensed operators.
The Operations personnel interviewed indicated that if troubleshooting efforts became more complex and considered actions were not covered by existing procedures, then based on the l
individual situation, actions would be taken to: (1) make a temporary change to an existing procedure; (2) develop a reviewed and approved temporary operating procedure; or
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(3) submit an MWR to maintenance for them to troubleshoot the problem. The inspectors l
concluded that this appears to be an acceptable approach for conducting troubleshooting activities; however, the inspectors noted that this approach is not a policy or administrative control that is specifically documented like the administrative controls for troubleshooting, OM 1/2.48.1D. This lack of formal administrative controls for conducting troubleshooting in the Operations Department is further evaluated below (section 2.3.5) in the review of Incident Report No. 2-93-014.
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2.3.5 Review of Significant Troubleshooting Events Conducted by Operations l
Department l
l To determine if the Operations Department was complying with their administrative controls for troubleshooting, the inspectors and reviewed post-1988 significant troubleshooting events performed by Operations. One event, that occurred on March 2,1993, was identified for i
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review. This event involved the isolation of the steam generator blow down valves during
the troubleshooting of a 130 volt ground on DC bus 2-1. This troubleshooting event was i
docuuented by the licensee in their Unit 2 Incident Report (IR) No. 2-93-014. The licensee l
made the required 10 CFR 50.72 report and was drafting a LER as required by 10 CFR 50.73 during this inspection. The IR did not indicate what procedure was being used to
conduct this troubleshooting and did not indicate what other troubleshooting actions or
methodology had been used prior to the steam generator blowdown isolation.
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Based on the plant records available for the inspectors to review, it was not evident if an approved procedure was.used to provide the guidance for performing the troubleshooting for i
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this DC bus ground. Although OM chapter 1/2.48.1D requires documentation of switch,-
valve and component lineup changes made during troubleshooting, the inspectors could not determine all of the lineup changes that were made. Discussions with Operations personnel indicated that procedures 20M-39.4.F, G & H provide guidance for clearing DC grounds y
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and would have been used as guidance for this troubleshooting. These personnel also noted that during this type of troubleshooting, drawings and load lists are marked up and used by-the Control Room to keep track of troubleshooting activities, but this documentation is i
typically not maintained as a permanent plant record.
The Nuclear Shift Supervisor's (NSS), Assistant Nuclear Shift Supervisor's (ANSS), and the
l Nuclear Control Operator's (NCO) Operating Reports (logs) for March 1 -'3,1993, were -
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troubleshooting event. The inspectors had the following observations concerning the r
documentation of troubleshooting:
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No plant record was found that documented all the actions taken to troubleshoot and
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locate the ground. From a review of the logs, the inspectors could not determine what procedure (s) were being used to search for the ground, nor could it be r
determined which breakers were being manipulated, and only some of the power
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panels that were being 'scarched for the ground could be identified. As reported in
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Section 2.3.4 above, OM 1/2.48,1D indicates that switch lineup changes are required
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to be documented.
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The logs indicated some of the major equipment manipulations taken to search for the l
l ground, but not all of the logs indicated that these actions were taken as part of the search for the DC bus ground. The inspectors had to review all three logs (NSS, ANSS, and NCO) to get an understanding of the actions that were being taken to search for the ground. The inspectors also noted that the level of detail in a particular log did not remain consistent from shift to shift.
t Both the NSS log and the NCO logs reported that the trip throttle valve for the AFW
pump was closed. The inspectors noted that the logs did not report why the valve was closed. These log entries did not report that a Tech Spec action statement L
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(3.7.1.2) had been entered. The inspectors found that the administrative controls for operating logs, OM chapter 1/2.48.5, require the NSS to log the entry and exit from all Tech. Spec. action statements.
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Based on the piant records available for the inspectors to review, including the Operating Logs described above, the inspectors concluded that the documentation of Operation Department controlled troubleshooting and the Operating reports was weak in the following (1) all the procedures used to perform the troubleshooting were not referenced in the areas:
operating logs; (2) logging all the valve, switch, and component lineup changes; (3) logging i
cach Tech. Spec. action statement that is entered and exited as required by OM 1/2.48.5A, and (4) providing a consistent level of detail in each Operating Report that meets the administrative requirements for that log as identified in OM 1/2.48.5A.
From the review of the operating logs, the inspectors had the following additional observations concerning Maintenance Department participation in Operations Department controlled troubleshooting activities:
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The ANSS log reported that the Relay Crew supported the Operations Department
troubleshooting efforts by removing and reinstalling the ground detection relay from its circuit. It was concluded that this was not the source of the ground. The inspectors found that the work performed by the relay crew, removing and reinstalling the relay, was done at the direction of the Operations department and was not done with a MWR. The inspectors reviewed the ground isolation procedures in OM l
chapter 39.4 and found that removing this relay is not a step in these procedures.
The inspectors found that these procedure only provides instructions for opening and closing breakers to identify the portion of the circuit that contains the ground.
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On March 3rd, the ANSS reported that I&C was troubleshooting the DC bus ground
and the alarm cleared with no problem identified. The NSS log was more descriptive. It reported that when an external test lamp was applied to the DC-C2 breaker that the ground went to zero volts. It reported that I&C subsequently verified that the ground voltmeter and alarm relay were functional. The inspectors discussed l
the scope of the I&C troubleshooting with personnel from the Maintenance department. It was stated that this troubleshooting included performing continuity i
checks and was performed under the direction of Operations and without a MWRs.
The inspectors again reviewed the ground isolation procedures from OM chapter 39.4 and found that performing continuity checks is not a step in the procedure. As
previously noted, this procedure only provides instructions for opening and closing breakers to identify the portion of the circuit that contains the ground.
The inspectors note that these are two examples where troubleshooting activities exceeded the
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instructions provided in plant procedures. Troubleshooting without detailed step-by-step procedures is allowed by the Operations Department administrative controls for troubleshooting in OM 1/2.48.lD. However, this appears to be contrary to the typical
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approach, described by Operations personnel, to use existing procedures, temporarily change existing procedures or write temporary procedures for troubleshooting activities. No administrative control was found that precludes Maintenance personnel from participating in troubleshooting activities under the direction of Operations without the use of a MWR.
However, the inspectors concluded: (1) that the documentation of Operation Department controlled troubleshooting was weak and did not meet the administrative requirements established in OM 1/2.48.5A; and (2) implementation of the MWR process and the associated administative controls for this troubleshooting activity would have provided
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detailed work instructions and more complete documentation of the troubleshooting work activities.
2.4 Receipt Inspection of Materials for Maintenance Activities The inspectors reviewed the implementation of the on site receipt inspection program and the material storage and receipt inspection facilities available at Warehouse No. 22 as part of an assessment of QC oversight of maintenance activities. In addition, the inspectors evaluated concerns identified by maintenance personnel during interviews regarding work delays due to unavailability of material and parts experienced during previous outages.
The inspectors interviewed the acting receipt inspection supervisor and several QC inspectors concerning general activities involving the handling and processing of materials. The monthly " Deficient Material / Documentation Report" dated March 2,1993, was reviewed.
t This report provides the status of identified receipt inspection deficiencies and the status of requests for support and/or resolution from various site disciplines. The report also trends
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open deficiencies and hold tags for the past twelve months. The inspectors verified that the
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licensee's conformance with the Quality Services procedures, QSP 15.1 and QSP 15.2, for
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tagging and controlling Nonconforming Materials was adequate through a review of records and a tour of the warehouse.
In reviewing this area, the inspectors had the following observations and conclusions. At the time of this inspection there was no inspection backlog in the receipt inspection area; however, a backlog had previously existed between December 1992 and March 15, 1993.
An additional QC inspector has recently been assigned to the receipt inspection area following the completion of a cross-qualification program. QC Inspector staffing was i
adequate to support the daily workload. In an effort to ensure there are adequate numbers of inspectors available to cover fluctuating workloads occurring in the receipt inspection area,
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management is continuing to take steps to cross-qualify plant QC inspectors to work in receipt inspection. Recent planning improvements, such as staging procurement packages in receipt inspection before ordered parts have been received, have improved efficiency.
Currently there is less emergent work, a better flow of work, and better allocation of QC resources. In conclusion, no safety concerns were identified in the area of receipt inspectio.
2.5 Quality Control and Maintenance Interface The inspectors performed a review to determine what quality controls were applied to maintenance implementation. This review was also conducted to verify that inspection points and holdpoints are identified in work documents and are based on a set of established guidelines. As part of this review the inspectors reviewed the applicable maintenance administrative controls and records of Quality Control (QC) surveillance of maintenance
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activities.
The inspector reviewed a selected sample of completed daily QC General Inspection Reports.
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The guidelines for conducting these inspections are discussed in Quality Services Procedure, QSP 10.1, Section 3.12. These reports document QC inspector observations and findings from oversight of maintenance activities and document completion of the required QC holdpoint verifications. It has been the QC Department's practice to perform inspection surveillance of the nonroutine maintenance work activities from start to finish when the availability of inspection resources permit. The results of daily QC General Inspection Reports are further reviewed and trended in management reports. These practices were viewed by the inspectors as a positive initiative to improve QC oversight of critical safety-related maintenance activities.
As part of this review, the inspectors questioned the intent of a guideline in Maintenance Manual Section 4.1, paragraph VI.D.5.a, stated, "QC Supervision shall notify Maintenance Supervision of any QC holdpoints to be inserted. QC will normally perform independent QC inspection. In those cases where this is impractical, a qualified supervisor who is not responsible for the work may perform the inspection...." This procedure as previously written appeared to contradict other existing procedural requirements regarding QC department oversight of maintenance activities. The licensee initiated a procedure change request to change the procedure to read, "... Work shall not progress beyond a holdpoint until a QC verification has been performed and a QC signature obtained or holdpoint has been properly waived by a QC representative." The inspectors noted this procedure change should clarify and ensure consistency with the licensee's other current procedural requirements on this subject.
2.6 Quality Control Holdpoints and Procedural Controls for Maintenance Activities l
This review was conducted to verify that inspection holdpoints are identified in work l
documents and are based on a set of established guidelines. The inspectors reviewed Quality Assurance administrative control procedures, OP-10, QSP-10.6, QSP 5.6, and QSP 10.1, concerning the use and implementation of QC holdpoints.
During this review, the inspectors identified that the methods and controls established in QSP 10.6, for the unilateral waiving of QC holdpoints, are in apparent conflict with Technical Specification requirements, and other upp;r tiered procedures and administrative controls established for making procedure changes. QSP 10.6 was issued as a new procedure, in l
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14 November 1992, to proceduralize guidelines and criteria for Quality Services Supervisors to waive unilaterally QC holdpoints from modification and maintenance procedures. The inspectors concluded that QSP 10.6 offers provisions that if exercised might result in violation (s) of the licensee's controls for making procedure changes. However, the inspectors found no instances where this provision for unilateral waiving of quality control holdpoints in procedures had been exercised by the licensee.
Provisions in QSP 10.6 allow unilateral waiving of QC holdpoint steps in Onsite Safety Committee (OSC) approved procedures without initiating a procedure change. These provisions are in apparent conflict with the following Technical Specifications (TS)
requirements: (1) written procedures are established, implemented, and maintained covering the procedures referenced in Regulatory Guide 1.33 that include maintenance procedures and modification work procedures; (2) the OSC reviews applicable procedures; (3) the OSC reviewed procedures reference PIPS and other engineering standards that require inclusion of applicable mandatory QC holdpoints; and (4) temporary changes to these procedures are initiated using established TS guidelines. The unilateral waiving of QC holdpoints as permitted in QSP 10.6 appears to constitute a procedure change but does not require the procedure change controls required by TS to be implemented. This is an apparent conflict between the controls established in QSP 10.6 and TS requirements.
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Operations Quality Assurance Procedure, OP-10, " Maintenance and Modification Planning,"
is an upper tiered administrative procedure for planning of safety-related maintenance and modification activities. OP-10 requires: (1) the use of approved written procedures; (2) the use of appropriate inspection and performance testing; (3) that work orders, procedures, and instructions receive an independent review; (4) that mandatory holdpoints be identified on appropriate documents for inspections, and these documents shall provide for inspection and witnessing of critical steps in the progression of work; (5) that procedure changes will be prepared, reviewed and approved in the same manner as the original; and (6) that revised work orders will be approved by authority equivalent to that which approved the original work order. In apparent conflict with these OP-10 requirements described above, QSP 10.6 allows unilateral waiving of QC holdpoints. This QSP 10.6 provision allowing the unilateral waiving of QC holdpoints appears to be a procedure change that is made without following
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the procedure change controls required by OP-10 and Technical Specifications. The waiving of QC holdpoints appears to be a procedure change that is not receiving the same required review, and approval as the original procedure. Fmther, it does not require approval by an authority equivalent to that which approved the original (i.e., review by the OSC and approval by the General Manager of Nuclear Operations). The inspectors noted that OP-10 is a higher tiered administrative procedure than QSP-10.6.
Additionally, QSP 10.6 allows unilateral waiving of QC holdpoints that may be considered mandatory by Engineering Design Documents such as; the Plant Installation Process Standards (PIPS). The PIPS provide generic engineering standards and guidelines for specific installation activities that are based on the original design specifications (see Attachment 1 for PIPS reviewed). Each of the individual PIPS has a section specifying
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mandatory inspection requirements that are developed into QC Inspection Plans for incorporation into modification and maintenance work packages. QSP 10.6 allows QC to make procedure changes to delete holdpoints that may be considered mandatory by engineering design documents. This is an extension of the concern discussed in the above paragraph.
QSP 10.6 places a priority on procedures by classifying them either a priority "A" or "B."
Both types of procedures may be waived by this procedure; however, priority "A" procedures will normally be subject to 100% inspection frequency. The inspectors asked QA management, what the technical basis was for classifying procedures in the "A" or "B" category. The inspectors were told that the priority was assigned based on the past history of problems experienced with that type of activity. The inspectors were concerned that this prioritization overlooks the requirements established for incorporation of mandatory holdpoints as discussed previously in the points presented above.
The concerns discussed above regarding unilateral waiving of QC holdpoints were brought to the attention of site management. During an interview the Manager of Quality Services, he indicated that QSP 10.6 was not initiated primarily for cost savings benefits but to improve safety by directing and allocating QC inspection resources to cover the most safety significant work activities. He stated that the authority to waive QC hold points dates back to at least the year 1978 in Quality Assurance Procedures such as OP-11, " Control of Maintenance and Modification." He also noted that before the issuance of QSP 10.6 specific guidance and controls did not exist for waiving of QC hold points. In interviews with several QC supervisors no specific use of this waiver authority was recalled. In addition, the inspector reviewed over forty completed maintenance work packages and no waivers of QC holdpoints were identified.
The inspectors concluded that the methods and controls established in QSP 10.6, for the unilateral waiving of QC holdpoints, are in apparent conflict with Technical Specification requirements, and upper tiered procedures. The inspector did not fm' d any indications that the provisions of QSP 10.6 have been actually used by the licensee. However, the inspectors are concerned that the use of these provisions might result in unwarranted waiving of mandatory QC holdpoints or a violation of licensee controls for making procedure changes.
The Manager of the Quality Services Unit has agreed to reevaluate the issues presented and take action as appropriate. This item is unresolved pending licensee action to address the concerns presented above (URI 334 and 412/93-05-01).
Procedure QSP 5.6, " Instructions, Procedures and Drawings," provides guidelines for insertion of QC holdpoints into maintenance work documents. QSP-5.6 states that mandatory QC holdpoints for the verification of factors affecting quality shall be identified in work documents. QSP 5.6 provides eight guidelines for the adding QC he,1dpoints to maintenance work documents. The inspectors determined that QSP 5.6 does not identify the need to use PIPS or other engineering standards to incorporate QC holdpoints in maintenance work documents. These engineering standards are used to incorporate mandatory QC holdpoints in l
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Modification work packages to ensure that the holdpoints verify conformance to requirements and to assure the quality obtained is at least equivalent to that specified at initial installation.
The inspectors were concerned, that the guidelines provided in QSP 5.6 for insertion of QC holdpoints into maintenance work documents were inadequate in that programmatic controls were not established similar to those found for incorporation of QC holdpoints into l
Modification Packages. This is especially a concern when performing extensive maintenance
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activities such as replacement of an equivalent safety related valve that involves established l
engineering standards containing mandatory holdpoints. The Director of Quality Services l
Inspection and Examination has agreed to reevaluate the programmatic controls established for insertion of QC holdpoints in maintenance procedures. This item is another example of the inspectors' concern relative to procedural control of QC holdpoints and is considered part of the previously identified unresolved item (URI 334 and 412/93-05-01).
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f Maintenance Manual Section 4.16 and procedure QSP 10.1 allow maintenance supervisors to designate the nonapplicable steps of a maintenance work procedure as N/A when only
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portions of a maintenance procedure needs to be implemented to complete a task. In reviewing completed Maintenance Work Packages, the inspectors were concerned with the limited guidance and controls provided to maintenance supervisors for applying this authority to mark approved procedure steps N/A. This is especially a concern when specific steps within applicable portions of a procedure are marked N/A. Additionally, from the review of forty completed Maintenance Work Packages (see report Section 2.2.2 for details) it was l
noted that the work instructions, in the MWRs reviewed, provided only a narrative description of the work to be accomplished by the referenced procedure. The work instructions did not denote the specific portions of the referenced procedure that were required to complete the work task. The inspectors did not identify any instances where necessary steps were incorrectly marked N/A in a completed procedure. The Manager of Maintenance Planning and Administration has agreed to reevaluate the adequacy of the programmatic controls established for maintenance supervisors in the use of their N/A authority when applied to maintenance procedures. This item is another example of the inspectors' concern relative to procedural controls and is considered part of the previously identified unresolved item (URI 334 and 412/93-05-01).
3.0 OPEN ITEM FOLLOWUP (92701)'
(Closed) Unresolved Item 50-334/92-16-03 and 50-412/92-11-03 This item dealt with the assessment of the Fire Protection Program (FPP). This item found that the assessments that had been performed were narrow in scope and did not address the entire Fire Protection Program. The report noted that the Supervisor of System Engineering This identifies the inspection procedure number used during the conduct of this
portion of the inspectio.
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is responsible for assessing the effectiveness of the program and noted that an assessment o the FPP and the staffing to support this assessment was scheduled to be performed within the i
last quarter of 1992.
l The inspectors found that an assessment of the FPP was performed by System Engineering.
j Maintenance Engineering and Assessment Department memo ND3 MEA:0019, dated j
February 10,1993, and the attached " Beaver Valley Power Station Fire Protection Program i
Assessment of Effectiveness for 1992" was reviewed by the inspectors. To assess the
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effectiveness of the entire FPP, System Engineering reviewed the following indicators:
(1) independent audits and inspections; (2) Incident Reports; (3) Equipment Availability; (4) Beaver Valley Power Station response to regulatory issues; (5) Training; (6) personnel responsibilities; and (7) Procedures. This assessment identified programmatic weaknesses and corrective actions. Schedular commitments for completing the corrective actions were identified for some of the corrective actions. The inspectors concluded that System Engineering had performed an adequate assessment of the Fire Protection Program; therefore, the concerns identified by this item were addressed and this item is closed.
4.0 EXIT MEETING The inspectors met with licensee representatives at the conclusion of the inspection, on April 2,1993, at Beaver Valley. The findings of the inspection were periodically discussed with licensee personnel during the course of the inspection. The inspection scope, findings and observations were summarized and discussed at that time. At that time the inspectors discussed the Unresolved Item concerning: (1) unilateral waiving of QC holdpoints that may be required by engineering guidelines and standards without initiating a procedure change per your technical specifications; (2) the guidelines for including QC holdpoints into maintenance work documents may not be adequate; and (3) the guidance and controls provided to allow maintenance supervisors to delete, i.e., mark not applicable (N/A), steps in approved maintenance procedures are limited. The personnel in attendance are listed in Attachment 1.
Attachments:
1. Persons Contacted 2. Documentation Reviewed
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ATTACIIMENT 1 PERSONS CONTACTED Duquesne Licht Comoany J. Baumler, Quality Services Audit and Surveillance Director
- Cliff Custer, Director, Component Engineering
- S. C. Fenner, General Manager, Maintenance Unit
- Larry R. Freeland, General Manager, Nuclear Operations
- Ken Grada, Manager, QSU Mark Kilpatrick, Senior QA Specialist
- Frank J. Lipchick, Senior Licensing Supervisor T. McGee, Chairman, Onsite Safety Committee
- T. P. Noonan, General Manager, Nuclear Engineering and Safety Unit
- M. Pavlick, Manager, MP&AD E. Peace, Senior Component Engineer, Mechanical Maintenance
- Mike Pergar, Director, Quality Services Inspection & Examination
- Mark Pettigrew, Supervisor, System Engineer P. Santucci, Senior Quahty Control Inspector
- Fred Schuster, BV-2 Operations Manager
- Brian Sepelak, Licensing Engineer C. Shannon, Receiving and Procurement Program Auditor R. J. Snowden, Quality Control, Maintenance, Refueling & Operations, Supervisor
- Dale Spoerry, Vice President, Nuclear Operations
- James E. Starr, Supervisor, Engineering Management Nelson R. Tonet, Manager, Nuclear Safety
- Ron Zabowski, Director, System Engineer United States Nuclear Regulatory Commission
- P. Sena, Resident Inspector L. Rossbach, Senior Resident Inspector
- Denotes those at the exit meeting held on April 2,1993.
During the course of this inspection, the inspectors contacted other members of the licensee's Maintenance, Operations, Technical, and Quality Assurance department staffs.
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l ATTACIIMENT 2
DOCUMENTATION REVIEW
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Procedurm
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Maintenance Manual, Section 4.1, " Work Order Control," Rev.1, dated e
December 30,1992 Maintenance Manual (MM) Section 4.5, " Daily Maintenance Job Planning and e
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Scheduling," Issue 2, Revision 4, dated November 10,1992
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Maintenance Manual (MM) Section 4.16, " Performance of Maintenance Procedures,"
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Issue 1, Revision 0, dated November 6,1992
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Maintenance Manual, Section 4.17, " Control and Issuance of Maintenance l
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Procedures," Revision 2, dated 10/15/92 r
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Nuclear Engineering Administrative Procedure (NEAP) 4.1, " Preparation of Data l
Sheets and Modification Work Packages," Revision 1, dated February 25,1991 l
Nuclear Group Administrative Procedure (NGAP) 7.5, "The Maintenance Work e
l Request," Revision 3, dated December 14,1992
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Nuclear Group Administrative Manual, NGAP 7.7, " Plant Installation Process l
e Standards," Revision 1, March 26,1993
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Nuclear Group Administrative Procedure (NGAP) 8.21, " Quality Services Audit,
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e Surveillance, Inspection, Examination & Assessment Programs," Revision 1
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e Nuclear Power Division Administrative Manual (NPDAP) 2.3, " Procedure
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Preparation, Review, and Approval," Revision 4, March 19,1993 Operating Manual Chapter (OM) 1/2.48.1D, " Conduct of Operations, Organization e
and Responsibilities of the Operations Group, Operations Shift Rules of Practice,"
Revision 11 Operating Manual Chapter (OM) 1/2.48.2C, " Conduct of Operations, Operating e
Procedures, Adherence and Familiarization to Operating Procedures," Revision 11 Operating Manual Chapter (OM) 1/2.48.5A, " Conduct of Operations, Figures and
Tables, Imgs and Reports," Revision 11 Operations QA Procedure (OP) 4, " Design Control," Revision 5, dated May 13, 1991 e
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Operations QA Procedure, (OP) 6, " Material Control," Revision 4, dated
August 28,1992 Operations Quality Assurance Procedure (OP)-10, " Maintenance and Modification
Planning," Revision 2, dated January 4,1991 Operations Quality Assurance Procedure (OP)-11, " Control of Maintenance and
Modification," Revision 3, March 28,1991 Plant Installation Process Standards (PIPS) M06.1, " Category 1 Piping Installation,"
Revision 0.
Plant Installation Process Standards (PIPS) M03.3, " Pipe Support Installation,"
Revision 2,5/12/92 Plant Installation Process Standards (PIPS) M08.3, " Category 1, 2, 3 and F Pressure
Boundary Bolting," Revision 1.
Plant Installation Process Standards (PIPS) E02.3, " Cable Tray and Supports,"
Revision 1,6/5/92.
Quality Service Procedures (QSP) 2.2, " Qualification and Certification of QC
Inspection Personnel," dated December 23,1992 Quality Service Procedures (QSP) 5.6, " Instructions, Procedures, and Drawings,"
e Revision 2, dated December 23,1992 Quality Service Procedures (QSP) 10.1, "QC Inspection of Plant Maintenance,"
Rev. 2, dated December 23,1992
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Quality Services Procedures (QSP) 10.6, "Prioritization of QC Inspections,"
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Revision 0, November 4,1992
Quality Service Procedures (QSP) 15.1, " Control of Nonconforming Materials,
Components, and Parts," Revision 2, dated February 15, 1992 i
Quality Service Procedures (QSP) 15.2, " Hold and Reject Tagging Instructions,"
Revision 3, dated February 15, 1992 j
l Updated Final Safety Analysis Report (UFSAR), Section 17.2, " Quality Assurance
Program Description Operations," Revision 2 i