IR 05000334/1993014
| ML20046C268 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/30/1993 |
| From: | Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20046C263 | List: |
| References | |
| 50-334-93-14, 50-412-93-15, NUDOCS 9308100067 | |
| Download: ML20046C268 (2) | |
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U.S. NUCLEAR REGULATORY COMMISSION REPORT NOS:
50-334/93-14 50-412/93-15 DOCKET NOS:
50-334; 50-412 LICENSE NOS:
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LICENSEE:
Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 FACILITY NAME:
Beaver Valley Power Station, Units 1 and 2 JNSFECTION CONDUCTED:
July 19 - 23,1993 INSPECTOR:
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A. Finkel, Senior Reactor Engineer hag
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Performance Programs Section Operations Branch, DRS APPROVED BY:
78[k 3 Norman J. B16mberg, Chief Dite Performance Programs Section Operations Branch, DRS i
9308100067 930802
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DR ADDCK 05000334 PD *
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Insoection Summarv: Inspection from July 19 - 23,1993 (Inspection Report Nos.
50-334/93-14 and 50-412/93-15)
Areas Inspected: Announced safety inspection of the licensee's corrective actions taken to address the following NRC inspection findings: (1) Unresolved items 50-334/92-16-01 and 50-412/92-11-02, Fire loading calculations were performed by engineering on groups of approved plant changes after the work was started or completed and 50-334/92-16-02 and 50-412/92-11-02, Fire doors were not automatically closing and latching and repair of fire doors were made without using fire qualified hardware; (2) Violation 50-334/92-02-01, The Supplementary Ixak Collection and Release (SLCR) system test program did not perform a complete test of the SLCR system; (3) Four weaknesses were identified in 50-334/412/91-201, (A) Using Cernficates of Compliance vendor data without validating data, (B) Lack of verification of data when downgrading items, (C) Lack of data to support commercial-grade warehouse stock in safety-related applications for material purchased before September 1,1989, and (D) Not all plant design changes are translated into design documents such as drawings, specifications and procedures; and (4) Inspection of Quality Control method of selecting hold points 50-334/412/93-05-01, Quality control changing inspection hold points without peer review.
Results: No safety issues were identified during this inspection. The licensee's corrective actions taken to resolve the NRC inspection report findings, described above, have been implemented and plant documentation changes have been completed. The inspector's review of the revised procedures and interviews with engineering, maintenance, and quality control personnel indicated that they were aware of the NRC inspection report items and that they have received training on the revised procedures associated with the NRC report items. An evaluation of the method used by the quality control organization to establish and change quality hold points was verified by the inspector to be performed in accordance with their program documentation. The inspector also determined that program controls'are in place to review and evaluate quality control hold point changes. Training on the NRC inspection report findings, described above, and the corrective actions implemented by the licensee to correct these report findings, has been given by training department personnel to engineering, maintenance, operation, and quality personnel. The training classes attendance records and schedule dates are documented in the training school records.
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DETAILS 1.0 PERSONS CONTACTED Attachment 1 provides a listing of persons contacted during the inspection.
2.0 INTRODUCTION An inspection was performed to evaluate the adequacy of the corrective actions taken by the licensee to address the NRC inspection findings described in the following inspection reports:
(1) 50-344/92-16-01,02, 50-412/92-11-01, 02; (2) 50-334/91-201, 50-412/91-201; (3)
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50-334/92-02-01; and (4) 50-344/93-05-01, 50-412/93-05-01. A tour of the vital and nonvital areas of the plant was performed by the inspector to verify that the changes described in the licensee's corrective actions have been implemented as described.
Attachment 2 contains a list of the documents used by the inspector during this inspection.
3.0 INSPECTION RESULTS OF LICENSEE CORRECTIVE ACTIONS (Closed) Unresolved Item 50-344/92-16-01. 02 and 50-412/92-11-OL 02 (64704)'
An NRC fire inspection (July 13 - 17,1992) of the Beaver Valley Power Station Units 1 and 2 identified two unresolved items dealing with the following areas: (1) fire loading calculations were not performed on each approved plant change, but were performed after a series of approved changes were completed; and (2) fire doors did not automatically close and latch and unqualified fire door hardware was used to repair fire doors.
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(1)
Unresolved Item Nos. 50-334/92-16-01 and 50-412/92-11-01 Fire loading calculations were performed by engineering on groups of approved plant changes after the work was started or completed.
To ensure that fire calculations are performed on each approved plant change before the work is started, Nuclear Engineering Department Procedure (NEAP) 2.15, " Fire Protection Reviews," has been revised so that as part of the work package a fire protection review is required. If the plant modification is of the nature that a fire calculation is not required, the work package documentation will so state. The inspector reviewed five work packages and determined that the requirements of NEAP 2.15 were applied. Also, in discussions with engineering personnel, the inspector determined that training on the fire loading calculation requirements in NEAP 2.15 have been discussed with them by their supervisors.
(2)
Unresolved item Nos. 50-334/92-16-02 an
=Id 12/92-11-02 Fire doors were not automatically closing and latching whs > sed by personnel. Also, repairs made to fire doors were performed without using qualified fire door hardware.
The closing problem associated with the ten fire doors and the installation of unqualified
'The parenthetical notation following the paragraph title denotes the NRC inspection procedure that was used by the inspector in conducting this inspectio.
hardware installed on two fire doors have been corrected. To ensure that these conditions are not repeated, the licensee has revised, " Plant Installation Procedure (PIP) S17.3." This procedure identifies the technical, procurement, installation, maintenance and inspection
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requirements for Beaver Valley Units 1 and 2 fire doors and fire door hardware. In discussions with operating personnel, maintenance, and quality control personnel the inspector verified that these personnel have been trained on the revised requirements of procedure PIP S17.3. During a walkdown of the plant, the inspector verified that the fire door closing / latching and use of unqualified fire door hardware described in the NRC combined inspection report 92-16 and 92-11 have bxn corrected. The inspector also verified, during the plant walkdown, that other fire doors within the plant were in working order.
The NRC inspector concluded that System Engineering had performed an adequate assessment of both the NEAP 2.15, " Fire Protection Reviews," procedure and the PIP S17.3 procedure in revising these documents to address the NRC unresolved items described above.
Also, the fire doors have been repaired to comply with the fire system procedure requirements. These unresolved items are closed.
(Closed) NRC Procurement Assessment Findings 50-334/91-201 and 50-412/91-201 (92701)
An NRC procurement assessment inspection (March 4 - 8,1991) was performed to review Duquesne Light Company's (DLC's) program for procurement and dedication of commercial-grade items used in safety-related applications at the Beaver Valley Power Station (BVPS) Units 1 and 2, in accordance with 10 CFR Part 50, Appendix B, and to
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determine the extent of the implementation of the Nuclear Management and Resources Council (NUMARC) initiatives in this area.
The NRC assessment inspection identified four weaknesses in the following areas: (1)
DLC's reliance on information such as (Certificates of Compliance) provided by vendors without having implemented a program for commercial-grade supplier surveys or a source verification program to validate the suppliers data; (2) The blanket downgrading (with restrictions) of certain commodity items on the BVPS Generic Limits (such as 0-rings,
gaskets, filter elements and packing 11aterials) from safety-related to nonsafety-related
classification without verifying justifmon; (3) Lack of a basis for the use of commercial-
grade warehouse stock in safety-relateo applications that was purchased before l
September 1,1989; and (4) Nuclear Enguaring Department philosophy used in technical evaluation reports that a plant design change occurs only if the change affects the design bases of the plant. Therefore, not all plant designs changes are adequately translated into design output uocuments such as drawings, specifications and procedures.
The NRC inspector reviewed the following actions taken by the licensee to address the NRC
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weaknesses identified in inspection report 50-334/91-201 and 50-412/91-201:
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(1)
The licensee has issued a procurement engineering guideline No.104, " Procurement Engineering Commercial Grade Dedication Group Policy." This document defines the Procurement Engineering Policy to be used when performing and evaluating their commercial grade dedication activities.
(2)
Procedure QSP 18.4, " Commercial Grade items Survey, Evaluations and Commercial Suppliers List," describes the program for the Quality Services Unit (QSU) to implement when scheduling, preparing, performing, reporting, evaluating and following/ closing activities associated with surveys of commercial grade suppliers.
This procedure also delineates the requirements for listing acceptable suppliers on the Duquesne Light Company Commercial Suppliers List (CSL).
(3)
The method for determining the acceptability of DLCs' stock commercial grade items is described in the project outline document, " Evaluation Process for Stored Commercial Grade Material."
(4)
The DLC's method for categorizing and implementing station modifications are described in the following documents:
Nuclear Group Administrative Manual (NGAP) 7.8, " Station Modification
Control" Nuclear Power Division Administrative Manual (NPDAP) 7.2, " Design
Change Control," and NPDAP 10.1, " Definitions;" and, Nuclear Engineering Administrative Procedure (NEAP) 2.1, " Station
Modification Requests;" NEAP 2.2, " Design Change Control;" NEAP 2.19,
" Minor Design Change Control;" NEAP 2.13, " Technical Evaluation Reports;" and NEAP 1.2, " Standard Terms and Definitions."
The NRC inspector verified that the above DLC documents addressed the subject weaknesses described in the NRC Inspection Report 50-334/91-201 and 50412/91-201. The inspector discussed the weaknesses with engineering, procurement, and quality services personnel and found them to be aware of the NRC identified weaknesses. The inspector also determined that these personnel have had training on the above-referenced DLC's documents. The inspector closed these four items based on the quality of the above DLC documents addressing the weaknesses identified in the NRC inspection reports and the training given the licensee's personnel on these documents.
(Closed) Violation 50-334/92-02-01 (61725)
The licensee's Supplementary Ixak Collection and Release (SLCR) system test program only verified SLCR system flow rates required by Technical Specification (TS) Section 3.7.8.1, and did not verify room flow rates. Room flow rates verification was to be performed on an
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as-needed basis to support system flow balancing instead of being part of the TS test. In addition, station design documents did not provide adequate information to describe all design requirements of the SLCR system.
These design documents described the function of the SLCR system to collect leakage from the containment contiguous areas to maintain these areas under a negative pressure and to filter the exhaust from these areas through the " main Filter Banks" under accident conditions.
However, the secondary design requirements of providing post-accident cooling to maintain equipment qualification (EQ) in these areas was not added to station test documents after credit was taken for this function in EQ calculations. Therefore, the lack of taking ventilation flow readings in individual rooms such as the charging pump cubicles was a violation of an EQ requirement. The lack of verifying the charging pump cubicle flows, which existed at this unit for ten years (1980 - 1990), was identified by the licensee during a design change (DCP 201/202) that occurred in 1990.
The licensee has taken the following corrective actions to correct the SLCR system test deficiencies associated with the ' Unit 1 surveillance test program. Unit 2 is not affected since their design is different from that of Unit 1.
Calculation 8700-DMC-2500 has been performed, which established the minimum
SLCR system air flows in the charging pump cubicles to maintain the charging pumps temperature below their environmental qualification (EQ) temperature limits.
Beaver Valley test procedure (BVTP) 1 BVT 2.16.5 and 1 BVT 1.16.10 have been
revised to include the SLCR system design basis flow rates in the acceptance criteria.
The flow rate verification test has been scheduled as an 18 month verification
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requirement test on the licensee's master test schedule.
The SLCR system flow diagram 8700-RB-2B has been revised to indicate the e
minimum allowable flow rate values to meet both the EQ and exhaust flow rates.
The Design Basis Document (DBD) for the SLCR system has been revised to include e
area temperature limits and heat removal requirements that are within the EQ requirements.
The licensee has given their personnel training on this event and added this subject to e
the Training Personnel Continuing Training (TPCT) program as a lesson learned item for class review.
The inspector discussed the above actions taken by the licensee with operating personnel, test personnel and quality personnel. The personnel have received training on the SLCR system and understood the reason the problem occurred. Based on the revised engineering calculations, the test procedures and schedule changes and the training given to the licensee personnel, the inspector considered this item closed.
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(Open) Unresolved Item 50-334/93-05-01 and 50-412/93-05-01 (9270lP The licensee's quality services procedure QSP 5.6, " Instructions, Procedures and Drawings,"
allows established quality inspection hold points to be changed by quality inspection without peer review of these changes on Plant Installation Procedures (PIP's).
The method that Quality Services Inspection and Examination (QSIE) Department developed to establish inspection hold points in procedures is described in Quality Services Procedures (QSP's) 5.6, " Instructions, Procedures and Drawings," and QSP 10.6, "Prioritization of Quality Control Inspections." Procedure QSP 5.6 describes the methods the QSIE Department uses to assure that work documents contain the appropriate quality requirements, while QSP 10.6 describes how the QSIE Department establishes hold points and the method to change and document hold point changes. Inspection hold points that are established by code, seismic, fire and equipment qualification requirements cannot be waived by the Quality Control Supervisor using the guidance described in QSP 10.6. Paragraph 3.5.
The method for establishing hold points in plant procedures is described in QSP's 5.6 and 10.6 and are in accordance with the requirements of Nuclear Group Administrative Manual (NGAP) 8.10, "Onsite Safety Committee, Section H" and NGAP 8.21,, " Quality Services Audit, Surveillance, Inspection, Examination and Assessment Program, Section D.4.a."
Procedures NGAP 8.10 and NGAP 8.21 describe the method and controls that quality control personnel are required to perform when changing inspection hold points previously established. As described above, hold points on code, seismic, fire and equipment qualification requirements cannot be changed by the quality organization without following the request for change requirements dermed in procedure NGAP 8.10. The NGAP documents that defme the requirements for the various program documents are controlled documents that are within the license requirements that comply with the Technical Specification of Section 6.8, " Procedures."
Based on the documents reviewed above, the inspector determined that the methods described in QSP's 5.6 and 10.6 for selecting and changing inspection hold points were in accordance with the requirements of the Updated Final Safety Analysis Report (UFSAR) and NGAP documents for the Beaver Valley Units 1 and 2 Nuclear site. This closes only the quality control hold point change subject of unresolved item 334/412/93-05-01. The remaining unresolved items of 334/412/93-05-01 remain open.
"The parenthetical nota on following the paragraph title denotes the NRC inspection procedure that was used bt the inspector in conducting this inspection.
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4.0 MANAGEMENT MEETINGS
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Licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted on July 19, 1993. The findings of the inspection were periodically discussed with licensee personnel during the course of the inspection. The inspector met with licensee representatives (denoted in Attachment 1) at the conclusion of the inspection on July 23,1993. The inspector summarized the scope of the inspection and the findings of the inspection as described in this report.
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Attachments:
1. Persons Contacted 2. Documents reviewed
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A'ITACHMENT 1
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Persons Contacted i
Duauesne Light Comoany
- L. Freeland, General Manager of Nuclear Operations
- K. Grada, Manager of Quality Services
- F. Lipchick, Senior Licensing Engineer j
- D. McLain, Manager of Maintenance Engineering and Assessment
- M. Mirchich, Acting Director of Procurement engie-Ng f
- T. Noonan, General Manager of Nuclear Engineer.
e4 2 Safety
- M. Pergar, Director of Quality Services
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- B. Spelak, Licensing Engineer
- H. Siegel, Manager of Nuclear Engineering Department
- D. Spoerry, Division Vice President of Nuclear Operadons
- G. Thomas, Division Vice President of Nuclear Services
- J. Vassello, Director of Licensing
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- R. Zabowski, Director of System Engineering
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United States Nuclear Regulatory Commissip_q
- L. Rossback, Senior Resident Inspector P. Sena, Resident Inspector
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- Denotes those present at the exit meeting on July 23,1993.
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The inspector also held discussions with managers, supervisors and other licensee employers during the course of this inspection, including operatione technical and administrative personnel.
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W A'ITACHMENT 2 l
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List of Documents Reviewed Nuclear Engineerine Denartment Procedure (NEAP)
NEAP 1.2, " Standard Terms and Definitions."
-l NEAP 2.1, " Station Modification Requests" l
NEAP 2.15, " Fire Protection Reviews" j
NEAP 2.13, " Technical Evaluation Reports" l
NEAP 2.19, " Minor Design Change Control"
.i NEAP 2.2, " Design Change Control" Nuclear Grouc Administrative Manual (NGAP)
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NGAP 8.10, "Onsite Safety Committee"
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NGAP 8.21, " Quality' Services Audit, Surveillance, Inspection, Examination and Assessment Program" NGAP 7.8, " Station Modification Control"
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- Nuclear Power Division Administrative Manual (NPDAP)
NPDAP 7.2, " Design Change Control" i
NPDAP 10.1, " Definitions" i
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Ouality Services Procedures (OSPs)
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t QSP 5.6, " Instructions, Procedures and Drawings
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QSP 10.6, "Prioritization of Quality Control Inspections" l
t General Licensee Documentation
I Calculation 8700-DMC-2500
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8700-RB-2B SLCRLsystem flow diagram j
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1 BVT 2.16.5 and 1 BVT 1.16.10, " Beaver Valley Test Procedure (BVTP)"
'l DCP 201/202 Design Change QSP 18.4, " Commercial Grade Items Survey, Evaluations and i
Commercial Suppliers List"
'j UFSAR, " Updated Final Safety Analysis Report" (l i
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i Attachment 2
PIP S17.3, " Plant Installation Procedure "
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NRC Inspection Reports 1. Unresolved items 50-334/92-16-01,02 and 50-412/92-11-01,02 2. Violation 50-334/92-02-01
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3. Procurement program weaknesses identified in 50-334/412/91-201 4. Inspection of Quality Control method of selecting hold points 50-334/412/93-05-01 i
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