IR 05000412/1985008
| ML20127A111 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/14/1985 |
| From: | Bettenhausen L, Van Kessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127A106 | List: |
| References | |
| 50-412-85-08, 50-412-85-8, NUDOCS 8508050417 | |
| Download: ML20127A111 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-412/85-08 Docket No.
50-412 License No.
CPPR-105 Priority Category B
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Licensee: Duquesne Light Company Robinson Plaza Building No. 2 Suite 210, PA Route 60 i
Pittsburgh, PA 15205 Facility Name: Beaver Valley Power Station - Unit No. 2 Inspection At:
Shippingport, Pennsylvania Inspection Conducted: April 14-19, 1985 b
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Inspector:
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H. F. Van Kessel, Reactor Engineer Date
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Approved by:
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L.'H.~Bettenhausen, Chief, V
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Operations Branch, DRS Inspection Summary:
Inspection on April 14-19, 1985 (Inspection Report No. 50-412/85-08)
Areas Inspected:
Routine, unannounced inspection of the pre-operational test L
program including test program requirements and implementation, test procedure i
reviews, reactor coolant system hydrostatic test, licensee action on previous l
inspection findings, quality assurance and quality control for the test
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program, and tours of the facility.
The inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> on site by one NRC Region based inspector.
l Results: No violations were identified.
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DETAILS 1.0 Persons Contacted Duquesne Light Company (DLC)
F.A. Arnold, Staff Engineer, Startup Group (SUG)
C.R. Davis, Director QA
D.W. Denning, Assistant Director QA
R.
Flodstrom, Assistant Director QC System Release and Startup D.C. Hunkele, Director QA, Operations
T.P. Noonan, Beaver Valley 2, Station Superintendent
M.
Pavlick, Director Milestone Management
R.J. Swiderski, Startup Manager
D.H. Williams, Startup Engineer
R.G. Williams, Supervisor Testing and Plant Performance
U.S. Nuclear Regulatory Commission D.M. Johnson, Resident Inspector, Beaver Valley 1
L.J. Prividy, Resident Inspector, Beaver Valley 2
W.
Troskoski, Senior Resident Inspector, Beaver Valley 1 G.A. Walton, Senior Resident Inspector, Beaver Valley 2
Denotes those present at exit interview on April 19, 1985.
- 2.0 Licensee Action on Previous Inspection Findings 2.1 (Closed) Unresolved Item (412/85-01-01).
Start-up Manual not avail-
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able for review by NRC.
The Start-up Manual (SUM) has been completed and was available for review.
It was approved in accordance with requirements.
For further details on the review of the SUM see Section 3.1.
This unresolved item is closed.
2.2 (Closed) Unresolved Item (412/85-01-02).
Procedure for inverter testing not available for review by NRC. The procedure for inverter testing has been reunited with the procedure for battery testing and is now available for review by the NRC without the many corrections shown previously. This unresolved item is closed.
3.0 Preoperational Test Program 3.1 References (1) Beaver Valley 2 FSAR, Chapter 14. " Initial Test Program".
(2) Beaver Valley 2 FSAR, Chapter 17, " Quality Assurance".
(3) Beaver Valley 2, " Start-up Manual (SUM)", Effective date, March 29, 198 (
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(4) ANSI N45.2.6-1978, " Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants".
(5) Field Construction Procedure FCP-80, Change 0, " Conduct of Phase-1 Test Program", issued by Stone and Webster Engineering
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Corporation (SWEC).
(6) " Quality Assurance Program Manual", Beaver Valley Power Station.
(7) Regulatory Guide 1.58, Rev. 1, " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel", September 1980.
(8) Regulatory Guide 1.68, " Initial Test Programs for Water Cooled Nuclear Power Plants".
(9) ANSI N18.7-1976 (Revision of N18.7-1972), " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants".
(10) ANSI N45.2 - 1971, " Quality Assurance Program Requirements for Nuclear Power Plarts".
(11) 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants".
(12) Field Construction Procedure FCP-51, Change No. 3, " System /Sub-System Turnover to DLC-CSUG", SWEC, July 30, 1984.
(13) Field Construction Procedure FCP-29, Change No. 8, " Exception Work Tracking", SWEC, August 6, 1984.
3.2 Test Program Requirements The NRC Inspector met with key personnel of the Start-up Group (SUG)
to discuss various aspects of the Unit 2 preoperational test program.
Areas addressed included the definition of the test program, the test organization and test program administration.
Discussion Since the Start-up Manual (SUM) was available during this inspection for NRC review (see paragraph 2.1 above) it was reviewed, partly, for the implementation of regulatory requirements in the Unit 2 preoper-ational test program.
The preoperational test program for Beaver Valley 2 is described in chapter 14 of the FSAR.
The SUM is composed
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of independent procedures which identify and control how the testing is to be conducted. A chapter has been added to identify who controls the testing (test organization) but the manual does not describe what the test program. The ins,pector observed that the program descrip-tion or a reference thereto, is highly desirable to make a manual out of the assembly of independent procedures.
The inspector verified, through discussions with key test personnel and review of the SUM, that the following areas of testing are covered in the SUM:
(1) Flushing and cleaning of systems (2) Hydrostatic tests (3)
Instrument Calibration (4) System Turnover (5) Functional Equipment Demonstration (6) EE/ME/I&C testing The inspector verified that the test program meets FSAR commitments in the following areas:
(1) Tests are identified and sequenced (2) Test procedure contains test objectives, prerequisites, test summary, and acceptance criteria.
The individual tests to be performed under the preoperational test program are not identified in the SUM. They are listed in a separate index which is not a part of the SUM.
The inspector noted during in-spection 50-412/85-01, and also during this inspection, that a perfect match between the preoperational tests, as listed by the Licensee, and the regulatory requirements was not achieved.
In addition there are some test classification problems which require correction.
For in-stance, the Steam Generator Hydrostatic Test (secondary side) and the Reactor Vessel Internals Vibration Test are not listed as preopera-tional tests.
Initial Core Loading, however, is listed as a preoper-ational test.
The inspector verified that format and content require-
ments of the test procedures met regulatory requirements (SUM 3.5.1).
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i Review of the SUM sections addressed showed that formal methods have been established for the test organization to receive jurisdiction from construction of systems, components, and instrumentation prior to
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testing. The methods are described under Section 7.1 of the SUM in the form of turnover procedures.
Control of system status prior to testing is achieved through tagging procedures as provided under Sec-tion 7.2.5 of the SUM. The inspector observed that there was no check off list, with sign off requirements, for the placement of jurisdictional tags.
For " danger tags", however, there is a check off list with sign-off requirements. The inspector will pursue this item in future inspections.
Return of systems and components to construction for modification or repair is controlled by procedures defined under Section 7.2 of the SUM. The control of system status subsequent to testing is control-led by procedures defined under Section 3.5 of the SUM.
Section 3.4 (paragraph 14) of the SUM deals with temporary installations of piping (bypasses) and other items.
The inspector observed the absence of a separate system restoration section in several procedures reviewed during this inspection as well as during inspection 50-412/85-01.
The licensee explained that they prefer to restore the system immediately after the need for a given system status item expires during the test.
In some cases such restoration may not take place until the end of the test but, in many cases, it is possible to do it before the end of the test.
Where restoration steps occur in the procedure, there is a sign off requirement for each step. The inspector concurred with this method of system restoration but will check on this item in future reviews of test procedures.
Formal administrative measures have been established to govern the conduct of testing including:
the use of current test procedures (SUM 3.5.3), test personnel's knowledge of the test procedure (SUM 3.5.3), changes to test procedures during testing (SUM 3.5.1),
criteria for test interruption and continuation (SUM 3.5.3), test coordination (SUM 3.5.2), documenting significant events, unusual conditions, or interruptions experienced during testing (SUM 2.6 under " Conduct of Critique") and identification of test deficiencies (SUM 3.5.3).
Scheduling and sequencing of test activities is being accomplished via a CPM network. Milestones for the start-up schedule have been established (see Section 3.4).
Test results evaluation is control-led by procedures defined in Section 3.5.3 of the SUM including data l
redaction requirements (Paragraph VI B.14), acceptance criteria
(Paragraph VI B.14.b), identification of test deficiencies (Paragraph l
VI B.8.b(1)&(2)), retest requirements defined (Paragraph VI B.12),
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l and review and approval requirements.
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l The inspector verified that the required qualifications of key l
personnel in the test program are included in the SUM (Section l
6.2.1).
The inspector, also, reviewed the training and qualification l
records of key test personnel.
Except for one record, the records j
were incomplete and did not contain the required qualification cer-l-
tificates and experience background information. Through discussions l
with the same test personnel, the inspector ascertained that their l
experience and educational background should be adequate to qualify them for the assigned positions in accordance with ANSI N18.7 and
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N45.2.6.
It will be necessary, however, to update the records to l
positively verify the qualifications of these key test personnel.
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The inspector will follow up on this item in a future inspection (s).
The inspector verified that:
responsibilities of key test personnel were specified (SUM Section 1); the responsibility for appointing key test personnel was defined (SUM 1, Paragraph IV.B.1); the authority and responsibilit'es of test personnel were defined (SUM Section 1);
the interfaces between organizations involved in the test program were established (Chapter 17 of FSAR for QA/QC interface; SUM Chapter 7 for Contractors; Chapter 1 of SUM for organizations SWEC, Westinghouse, Duquesne Light Company).
Findings l
(1) Program tests were not, in all cases, found to be classified in accordance with regulatory requirements.
For example, the Steam Generator Hydrostatic Test (secondary side) and the Reactor Ves-sel Internals Vibration Test were not listed as preoperational tests. The inspector will follow the Licensee's corrective efforts under Unresolved Item 412/85-08-01.
(2) Five qualification and training records of key test personnel were found to be incomplete by the inspector.
The required qua-lification certificates and supporting experience and educational background information was absent from these records. While it is apparent from discussions with these key test personnel that they should qualify for the assigned supervisory positions, it will be necessary to completely update these records to verify that their qualifications are in accordance with ANSI N18.7 and N45.2.6.
The inspector will follow the Licensee's corrective efforts under Unresolved Item 412/85-08-02.
(3) The absence of records for the placement of jurisdictional tags after system turnover represents a potential lack of control l
over pre-test conditions.
The inspector will follow up on this l
Unresolved Item 412/85-08-03 in a future inspection.
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(4) The Startup Manual does not use or reference the existing pre-operational test program description in Chapter 14 of the FSAR. This causes the manual to be without a scope of work description. The inspector will follow up on this Unresolved Item 412/85-08-04 in a future inspectors.
3.3 Test Procedure Review and Verification The approved Preoperational Test (PO) and System Operability Verifica-tion (S0V) test procedures listed in Attachment A were reviewed for administrative and technical adequacy and for verification that ade-quate testing is planned to satisfy regulatory guidance and licensee commitments.
The procedures were examined for management review and approval, pro-cedure format, clearly stated test objectives, prerequisites, environ-mental conditions, acceptance criteria, source of acceptance criteria, references, initial conditions, achievement of test objectives, per-formance documentation and verification, detailed instructions for performance of test, restoration of system to normal conditions after testing, identification of personnel conducting the test, evaluation of test data, independent verification of critical steps or parameters, quality assurance and quality control interface and involvement.
Discussion The following test procedures, as listed in Attachment A of this report, were reviewed:
2.06.10; 2.06.13; 2.21A.02; 2.47.02; 2.47.03; 2.47.04.
S0Vs: 2.410.01; 2.34.02.
P0 2.47.02 was found not to have a system restoration section, while P0 2.47.03 and 04 had a very general system restoration remark at the end of the procedure. These, and similar observations made by the inspector during inspection 50-412/85-01 were discussed with SVG management.
Findings No violations were identified by the inspector.
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3.4 Test Program Status and Schedule Yew milestones have been determined for the test program as follows:
New Old Steam Generator Hyro.
11/85 5/85
(secondary side)
RCS " Cold Hydro" 3/86 7/85
Hot Functional Test 10/86 2/86
CILRT and SIT 2/87 5/86
Fuel Loading 4/87 6/86
Compared with the milestone dates received during the previous in-spection(50-412/85-01), the program has been delayed by 8 months.
With the additional 8 months, the Licensee will be in a good position to satisfy their commitment to Regulatory Guide 1.68, i.e., to supply approved test procedures for NRC review 60 days prior to performance of the corresponding test.
Of the 79 P0 and 81 SOV test procedures required, 58 P0s and 68 SOVs have been written in draft form, 14 P0s and 12 SOVs have been ap-proved for testing.
Zero pre-operational tests have been completed.
Of the 450 (64 complete systems) subsystems, 162 have been turned over to SVG by construction.
A newly revised 90 day plan, for the 2nd quarter of 1985, was re-ceived by the inspector as well as a (Level 2) CPM activity network which is based on the new milestone schedule.
4.0 Quality Assurance (QA) and Quality Control (QC) for the Preoperational Test Program The inspector met with key personnel of the QA and QC organizations, to determine their involvement with the program.
Particular attention was paid to the areas of surveillance plans, test witnessing, hold point assignments, turn-back of systems after turnover, and the coordination of turnover packages.
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Discussion A new Director for QA Operations has been appointed. He reports to the
QA - Unit Manager in carallel with the Director of Site Quality Control.
He is responsible for the quality assurance aspects of the preoperational
?S test program. He informed the inspector that his group will ?o eurveil-lances only. A surveillance plan, however, has not been developed to date.
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.The inspector will' closely follow the Licensee's action in this regard.
s The involvement of' Site Quality Control (SQC) with the test program was
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discussed with the Assistant Director "QC System Release and Startup". He informed the inspector that SQC will do surveillances on maintenance of the
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equipment. A surveillance plan exists.
Prior to turnover of the system, SQC will coordinate the turnover packages.
SQC also will provide QC cover-
age for post turnover deficiencies and test deficiencies for which a Start-l up Work Request (SWR) will be generated. The SWR form has a sign off re-quirement on inspection requirements.
If hold points are required they must be identified on the form.
The surveillance, performed by SQC, in-clude the calibration of test equipment. There are weekly meetings between SQC and SWEC to track progress on priority items of the exception work tracking list, Findings ss s
No violations or deviations were identified.
5.0 Plant Tours The inspectors made tours of~the facility including the* Control Room, the Auxiliary Building, the Fuel Building, the Reactor Building, and the Emer-gency Diesel Generator Building.
Specific attention was paid to the status of construction, housekeeping, fire protection, ongoing system modifications, and jurisdictional and safety tagging of systems.
During these tours, the inspector had discussions with start-up personnel on such items as con-struction status, system turnovers, integrated project schedules, and test sequencing.
No discrepancies were noted in these areas.
6.0 Unresolved Items Unresolved, items are matters about which more information is required to ascertain whether they' are acceptable items, items of non compliance or deviations. 2 Unresolved items, resulting from this inspection, are discus-sed in Sections'3 and 4 above (four, items).
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7.0 Exit Interview At the conclusion of the site inspection, on April 19, 1985, an exit meet-ing was conducted with the licensee's senior site representatives (denoted
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in paragraph 1).
The findings were identified and previous inspection items were discussed.
At no time during this inspection was written material provided to the licensee by the inspector.
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ATTACHMENT A
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PROCEDURE REVIEWS (1) P0-2.158.01 Revision 0, Approved April 30, 1984 Neutron Shield Tank Cooling Test (2) P0-2.1303 Revision 0, Approved August 24, 1984 Quench and Recirculation Spray Nozzle Air Flow Test (3) P0-2.13.02 Revision 0, Approved August 21, 1984 Quench Spray System Pumps and Controls Test (4) P0-2.13.04 Revision 0, Approved December 18, 1984 Refueling Water Storage Tank Test (5) P0-2.47.05 Revision 0, Approved November 29, 1984 Containment Type B Leak Rate Test for Fuel Transfer Tube Flange (6) P0-2.06-04 Revision 0, Approved November 14, 1984 Reactor Coolant Loop Isolation Valves Initial Checkout (7) P0-2,39.01 Revision 1, Approved September 26, 1984 2-1 and 2-2 Batteries, Inverters, and Chargers Test (8) PO-2.39.03 Revision 0, Approved September 20, 1984 2-3 and 2-4 Batteries, Inverters, and Changes Test (9) S0V-2.33C Revision 0, Approved July 17, 1984 Booster Fire Pump Test (10) S0V-2.33C.01 Revision 0, Approved March 3, 1984 Fire Hydrant Flow and Pressure Test (11) S0V-2.11A.01 Revision 0, Approved May 18, 1984 Hydrostatic Test Pump Test (12) S0V-2.39.01 Revision 0, Approved September 6, 1984 2-5 and 2-6 Batteries, Inverters and Chargers Test (13) S0V-2.32A.01 Revision 0, Approved June 26, 1984 Demineralized Water System Test (14) S0V-2.33D.01 Revision 0, Approved July 19, 1984 Fire Detection System Test (15) S0V-2.45E.01 Revision 0, Approved March 15, 1984 Electric Fault Recording Test
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Attachment A
(16) S0V-2.41C.01 Revision 0, Approved February 17, 1984 Domestic Water System Test (17) SOV-2.44C.01 Revision 0, Approved July 25, 1984 Control Rod Drive Mechanism Shroud Cooling System (18) 50V-2.39.02 Revision 0, Approved March 2, 1984 Instrumentation, Annuncitaor Circuitry, and Emergency I.ighting Systems Test (19) P0-2.06.10, Revision 0, Approved March 27, 1985 Pressuriser Continuous Spray Flow (20) P0-2.06.13, Revision 0, Approved March 27, 1985 Reactor Vessel Head Vent System Test (21) P0-2.21A.02, Revision 0, Approved March 13, 1985 Main Steam Safety Valve Test (22) P0-2.47.02, Revision 0, Approved February 8,1985 Containment Type C Leak Rate Test (23) PO-2.47.03, Revision 0, Approved January 15, 1985 Containment Type B Leak Rate Test for the Personnel Hatch (24) P0-2.47.04, Revision 0, Approved January 15, 1985 Containment Type B Leak Rate Test for the Equipment Hatch
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(25) SOV-2.410-01, Revision 1, Approved March 28, 1985 Domestic Water System Test (26) 50V-2.34.02, Revision 0, Approved June 14, 1984 Instrument Air System Test i
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