IR 05000412/1985098
| ML20236X186 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/15/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236X181 | List: |
| References | |
| 50-334-85-98, NUDOCS 8712090040 | |
| Download: ML20236X186 (55) | |
Text
{{#Wiki_filter:, _, _ _ _ _ _ - _ _ _ _ > . t ENCLOSURE 2 , I f U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT 50-334/85-98 (AMENDED REPORT) (R) i DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION, UNIT 1 ASSESSMENT PERIOD: OCTOBER '1, 1985 - MARCH 15, 1987 BOARD MEETING DATES: APRIL 23-24, 1987 i l i l l
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-_ i (- h: r m l ., SUMMARY- ! Annual'ized.
Area Hours Hourse % of Time tj Operations 1029.
o706 29.7 Rad Protection 384 263-11.1 Maintenance 400 274 11.5 Surveillance 610 418 17,6 ~ Fire Protection-HK 231 158 6.7 < Emergency Prep.
154 106 4.4 , Sec/Safeguar's 147-101 4.1 d Outages
- 262 180 7.6-
' Licensing
0 0.0 Training
0-0.0 Engineering Support 208 143 6.0 Assurance _of Quality
32 1.3 ~ TOTALS: 3471 '2381 100.0 ,. T2-1 I _ A___ _ _ -
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. . Beaver. Valley. Unit.1.
.; ' ' ' , .,. . , w I TABLE 3-E ENFORCEMENT. ACTIVITY ~A.
-Violations Versus' Functional Area by Severity Level an < ' ' Functional No. of Violations in Each Severity Level: , - A~rea V 'IV 'III- 'II I.
Total , h, , 1.
, Plant Operations
2 , , 2.
' Radiological Controls .2
'4 3.
Maintenance-1
2' , ' 4,~ - ' Surveillance ~ 2: 2-5; Fire Protection / Housekeeping
4 y 6. u. Emergency Preparedness ..7.
Security & Safeguards! 1-1- '8.
Refueling-& Dutage Management a
- 9.
Licensing 10-Training and. Qualification Ef.fectiven'e s s , , 11. : Engineering Support
12J ' Assurance of' Quality' __ __ __ __ __ 1._ T . . TOTALS
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Summary f ,g, , .! . .. .Seve ri ty - .! y
. Inspection . Level Area Subject-
Number Requirements.
' 85-22-10 CFR 20.408 V Radcon Fail'ure-to issue. radworker ?. ,, , terminati_on; exposure reports.
o m Repetitive.
~ i $" App..B ~ IV Radeon Unplanned & unauthorized.
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10 CFR 50, ' ' release from Unit'l to Unit- "' 2 due to inadequate shared.
'> ' ' system boundary' isolation.
. , 85-25 10 CFR 50, IV Fire Protec-Lack of emergency lighting . App. R, . tion * units for' safe shutdown
-~Sec. III-J access routes.
85-26 Security Plan IV Security Protected area access with-out proper photo-identif,1-cation. badge.
B6-05 10 CFR 71.5 IV Radcon LSA drum's shipped with holes.
(Transporta-No QC' check of= container tion) integrity.
TS 6.8 V 'Radcon Pro'cedure not reviewed on.
(Trans 2 year frequency, tion) porta-86-06 TS 4.3.3.5 IV.
Surveillance-Shutdown Panel channel check failed to properly identify. RHR temperatures as in-y
- 1 operable.
%. TS 4.3.3.6.1 IV Fire Protec-EDG smoke detector surveil-tion lance test failed to iden-
- tify inoperable channel &
" control room alarm function.
FSAR DEV N/A EDG day fuel oil tanks not Table B.1-1 constructed to seismic re-quirements.
g-86-08 10 CFR 50.55a IV Fire Protec-RTB control wiring not ' IEEE-279 tion * separated by a. fire retard-ant barrier of 6" min, air space.
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- - Beaver ValleyLUnit-.1
Inspection . Requirements' Level Area Subject' LNumber' . / Severity 86-08-TS 6'.8.1 FIV Maintenance ' Failure to adhere to ad- '(cont.)
ministrative controls re-garding completion.of MWR documentation.
' 86-11-10 CFR 50,.- .IV Fire Protec-Failure to perform a com-
'Appi B and R tion * plete sensor.to indicator " functional ~ test of RCS cold ' leg temp. & failure to assure BIP. transfer keys functioned.
86-18-TS 6.12.2 IV Operations Failure to control access.
to NSS key cabinet contain-ing high rad area keys.
, 86-23.
10LCFR 50, .V Maintenance.
Failure.to follow industrial App.-B ! safety practices during battery MSP.
87-02 TS 4.3.1.1.1 'IV Surveillance Missed Power. Range. Monitor.
nuclear instrument channel check during startup.
~ 87/05-10 CFR 50,. . I V'. Operations ' Violation of plantLconfig-App. B .uration. control procedures, resulting in minor ~ gas-release to Primary Auxiliary-Building.
- It is' recognized that these could also be included in an Appendix R, Engineering or Assurance of Quality section.
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.s l TABLE 4 v? 'l T ' TABULAR LISTING OF LERs BY, FUNCTIONAL AREA- - ' ,e-Area' Numbe'r/Cause Code Tot:31 , l.
f A g.
.C D E f > , Plant Operations
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4 0' 7: Radiological' Controls:
'l Maintenance
> LL Surveillance: 4* 3*'
1
Fire Protection / Housekeeping.
I
2 4-E L mergency Preparedness 0-Security and Safeguards
Refueling and_ Outage Control _
-Licensing q.
Train'ing-and Qualification Effectiveness Engineering' Support ' Assurance of Quality _ _ _ _ _ _ Total
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5
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- 0ne'LER contained two events that occurred during one trip - startup evolution..
Cause-Codes: A'- Personnel Error B'- Design,' Manufacturing, Construction or Installation Error C - External Cause j 0 - Defective Procedures E - Component Failure X - Other T4-1 i a _ _ - - _ _ _ _ -
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.BeaverNalleyjdnitL1- .s y
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a LLR SYNOPSIS.
'LER' . , Number Summary Description .. , 85-17 Inoperable Rod. Position Indication System due.to computer failure.
85-18 ! Vital Bus III inverter input fuse failure ~ causing reactor trip.
85-19 . Reactor trip due to RCS loop flow instrumentation spikes.
g; 85-20 Out-of. specification PRM nuclear instrumentation rate trip setting.
86-01 Vital Bus III : inverter input fuse failure causing reactor trip.
i 86-02s MSSV left settings outside allowable limits.
.86-03L Partia11y inoperable fire detection system in diesel generator area.
86-04 Inadequate fire 'prote'ction system surveillance test (CO2 flow through nozzles).
86-05-Inoperable filter. bank -sprinkler nozzles.
86-06' Mis plugged steam generator U-tubes.
86-07-Inoperable fire suppression system smoke detectors.
' 286-08 ' Steam generator tube plugging.
. .86-09 Failure.to perform. fuel pool pump surveillance test within ASME required frequency.
86-10' Train B ESF actuation in Mode 5 due to operator error.
'86-11.
Manual reactor trip when four control rods dropped.
86-12 Reactor Trip during RTB shunt trip test due to personnel error.
i i .86-13: Operation prohibited by technical specifications when emergency bus ! undervoltage relay testing exceeded I hour.
87.-01 Reactor trip during turbine pedestal surveillance test due to operator i error.
Failure to perform PRM low trip setpoint surveillance during subsequent startup.
l~ 87-02 Reactor trip due to EHC' malfunction.
87-03 Inadvertent start of motor-driven auxiliary feedwater pump.
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- , Beaver' Valley Unit 1 .s ! ATTACHMENT 1 TOTAL NUMBER 0F SHUTDOWNS AND TRIPS PER YEAR SINCE STARTUP No. of.at Power No. of Unplanned-Year Reactor Trips Shutdowns '1976= '43
1 1977
18 I .1978 25-
' 1979
5 1980*
1 1981~
1 . l, 1982
4 ' 1983
3 1984
5 1985
7 ., 1986 3-
1987**
0
- The plant was shutdown for mo>t of 1980 for major modifications.
- As of 3/15/87.
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q ENCLOSURE 3 i U. S. NUCLEAR REGULATORY COMMISSION .
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i REPORT 50-412/86-99 u DUQUESNE. LIGHT COMPANY q
BEAVER VALLEY POWER STATION,. UNIT.2 ' ' , , .(Pre-Operational Testing Phase) ~ ASSESSMENT PERIOD: APRIL 1,.1986 - FEBRUARY 28, 1987 BOARD MEETING DATE: APRIL 22, 1987 .I ! I i ) !? h W"P Yr i ,
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LTABLE OF CONTENTS i'! PAGE.
2 I.
INTRODUCTION..................................................<....... 'l l e A.' Purpose and 0verviek............................................. li i ' < B.
SALP Board a'nd Attendees.......................................
! l II.
CRITERIA............................................................. u3-LIII.. SUMMARY OF RESULTS..................................................... 4-A.
.0vera11 Summary..................................................
l B.
-Background.
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LLicensing Activities.............. ....................,...
2.
I n s pecti on Ac ti vi t i e s..................................... -6 .l
C.
Facility Performance Analysis Summary........................... 7.
- IV; PERFORMANCE ANALYSIS............................................ .....
'f A.
construction.....................................................
.B.
LPreoperational' Testing.............. ...........................
1 < C.
Fire Protection land Housekeeping.................................
., ' -D.
Operational Read.iness............ ............................. IS H . E.
. Licensing...............~.......... ............................. 21 i F.
-Assurance of. Quality..........................
' ................ V.
. SUPPORTING DATA AND SUMMARIES........... ............................
- a
A.
' Construction Deficiency Reports (CDRs)..........................
B.
. Investigation Activities........................................ 26- . C.
Escalated Enforcement Actions.........., .......................
D.
Management Conferences..............................
" ......... E.
Licensing Activities.......................................... .
' TABLES ! l a . Table.1 - Inspection Report Activities J-Table 1? - Inspection. Hours Summary i Table 3-Enforcement Activity j ~ Table 4 - Construction Deficiency Reports ATTACHMENT
Attachment 1 - Enforcement Data-l
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~ INTRODUCTION ~ - A.
P_urpose'and 0verview The' Systematic Assessment of Licensee Performance (SALP) is an. integrated 'NRC' effort-to collect the available observations.and~ data'on a' periodic.
basis and to evaluate. licensee performance based on this information.
SALP is. supplemental to' normal regulatory processes used to ensure com-- pliance. with NRC rules' and regulations.
SALP is' intended to be suffi- ~ciently diagnostic.to provide a. rational basis for~al. locating-NRC re-sources and to provide meaningful: guidance to theLlicensee's management to promote quality and safe plant ' operation.
. An NRC SALP Board, composed of the staff members listed below,. met on . April ~22, 1987 to review the collection of performance observations and data to. assess the licensee's performance in accordance'with the guidance-in,NRC Manual Chapter 051o, " Systematic Assessment'of Licensee Perform-ance." A summary of the guidance and performance criteria-is provided in Section I.I of this report.
This' report is the~SALP Board's assessment of the licensee's safety' per-formance at the Beaver Valley. Power Station, Unit 2 for the eleven month period April1,'1986' through February. 28,1987. -It dif fers significantly
- from' previous Beaver Valley 2 assessments.
Construction related activi-l ties have~ been, combined into one functional area with emphasis not so much on the individual disciplines,'but more upon construction completion and' readiness for operatica.
New functional areas were added to address other plant operations and readiness aspects of licensee performance.
l The' SALP' Board was comprised of. the following members: -{ ! -B.
SALP~ Board and Attendees W. Kane, Director, Division of Reactor Projects (DRP) and.SALP Board Chairman W. Johnston, Director, Division of Reactor Safety (DRS) L. Bettenhausen, Deputy Director, DRS (Part Time) R. Bellamy, Acting Director, Division of Radiation Safety and Safeguards , (DRSS) (Part Time) J. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS (Part Time) J. Stolz., Director, Directorate I-4, NRR E. Wenzinger, Chief, Projects Branch No. 3, DRP , L. Tripp, Chief, Reactor Projects Section 3A, DRP J P. Tam, ' Licensing Project Manager, NRR
J. Beall, Senior Resident Inspector, Beaver Valley Unit 2
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.! .) % Other Attendees
W. ' Troskoski', Senior' Resident: Inspector, Beaver Valley Unit 'l .. l 'M. - Shanbaky, Chief, Facilities Radiation: Protection Section,.DRSS (Part Tirne) ' ' . . 'J; McFadden, Senior. Radiation Specialist,- DRSS ~(Part Time).
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II. CRITERIA ' Licensee performance is assessed in selected functional areas,- depending on whether the facility.is in a construction, preoperational'or operating phase.
Each functional area normally represents are&s significant to nuclear safety .and.the' environment, and are normal programmatic areas.
Special. areas may ~ be added to highlight significant observations'. One or' more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality.
l 2.
Approach to resolution of technical issues from a safety standpoint.
3.- Responsiveness to NRC initiatives.
4.
Enforcement history.
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Operational and Construction events (including response to, analyses of, and corrective actions for).
' i 6.
Staffing (including management).. Based upon the SALP. Board assessment, each functional area ~ evaluated is clas- -sified into one of three performance categories.
The definitions of these . performance' categories are: Category.1., Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of ' performance with respect to operational safety { is being achieved.. Reduced NRC attention may be appropriate, d Category 2.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and reason- - ably effective so that satisfactory performance with respect to operational safety is being achieved, NRC attention should be maintained at normal levels.
Category 3.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources ap-- ] pear to be strained or not effectively used so that minimally satisfactory l performance with respect to operational safety is being achieved.
Both NRC
and licensee attention should be increased.
The SALP Board may determine to include an appraisal of the performance trend of a functional area.
Normally, this performance trend is only used where l both a definite trend of performance is discernible to the Board and the Board l believes that continuation of the trend may result in a change of performance ' level.
Improving (declining) trend is defined as: Licensee performance was determined to be improving (declining) near the close of the assessment period.
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J ,,. J III. SUMMARI'AND RESULTS~ .A; Overall Summary Continued. improvement in-the overall level of performance.was demonstrated- !during this assessment period.
Severalflicensee' initiatives have been.
. generally effective in addressing or anticipating. problems.
These in- ~itiatives included the Design Endorsement Program for design verification, the Operational Readiness Review Team for assu' ring necessary p'rocedures and programs' are in place for license receipt, and the Quality Concerns Program.for aggressively soliciting' potential employee concerns.
High levels of, management involvement.in day to day activities was: evident.
Weekly onsite meetings were attended by the Chairmar. of the Board thereby demonstrating the' active involvement'of senior corporate management.
Overall. construction activities were found to be well managed with evi-dence of good construction quality levels in installed hardware. However, > the'QA program appeared to.be somewhat-limited as'a management tool'due to.the : scope and priority of its activities. ' The preoperational test program was considered to be a notable strength. Housekeeping was' generally-good with the mainten'ance and preservation of turned over: . hardware also a strength. The licensee'made good progress in the area of. operational +eadiness although,some added involvement by.NRC was . necessary 'to.obtain timely security program development'. In summary, during this assessment' period, the licensee demonstrated good-ability.to coordinate and manage'the many related, complex activities that occur at this stage in project life.
B.
. Background Duquesne Light Company was issued a Construction Permit (CPPR-105) to build Beaver' Valley, Unit 2, (Docket No. 50-412) on May 3, 1974.
During this SALP period, the licensee was granted an extension of CPPR-105 until . December 31, 1987.
The Nuclear Steam Supply System (NSSS)-is a 2660 MWt Westinghouse PWR with three loops; the -Architect / Engineer (A/E) is Stone and Webster. At the end of this assessment period, fuel load was sched-uled for May, 1987.
Construction was estimated by the licensee to be more than.98 percent complete as of February 28, 1987, as compared to 93.6 percent complete at the end of the last assessment period (March 31,1986).
' 1.
Licensee Activities In general, the work force increased during the assessment period.
On-February 28, 1987, there were about 4,900 construction workers,
compared to about 2,800 on March 31, 1986; an increase of approxi-l mately 70%. Total second and third shift activity more than doubled ' from 600 to 1300 during this period. Weekend activity increased as site activities shifted to a seven day work week.
The licensee !. .. l
__ . Beaver' Valley' Unit 2.
5- ) A I integrated the Quality Assurance and Quality Control organizations j together with'an.overall staffing increase from 450 to almost 500,. j an increase of about 10 percent.
Stone and Webster ' supervisory, y engineering and administrative personnel assigned on site alsotin-j creased, from about 680 to 730 people.
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During this assessment period, site activities. shifted-from con-- j struction oriented to the support of preoperational testing and the
completion'of major' milestone activities.
In this regard, major j testing-progressed through the period with the completion of the
reactor coolant system hydrostatic test in April, 1986; Hot Func-
tional Testing in December,1986; the Structural Integrity Test.
(SIT) and the Containment Integrated Leak Rate Test (CIRLT) in 'y February,1987; and Engineered Safety Features testing throughout the current period. Additionally, 9 of the 16 plant buildings were completed and turned over to the control of the plant staff.
The remaining buildings are the largest and involve.the bulk of the i . safety-related equipment: reactor containment, auxiliary building,
main steam and cable vault, safeguards building,-service building, control building, and turbine building.
As of February 28, 1987, 466 of the 476 subsystems had been turned over and accepted by the Duquesne Light Company Startup Group for proof testing. The remaining construction work not yet.substanti-i . ally complete includes insulation, safety-related cable fire wrap, cable tray. covers,~ activities supporting the remaining preopera-tional testing, building turnover, and design modification rework.
Preservice inspection, ASME Code stamping, and security system com- .ponent work were also continuing.
i i Other licensee activities during this SALP period included operator t licensing, emergency preparedness,' and operational readiness plan- ! ning and program reviews.
New fuel was received on site in Septem- ) ber, 1986.
The Unit 2 core was placed in the Unit 2 spent fuel pool ! with controlled access security provided by the Unit 1 security force via an amendment to the Unit 1 security plan.
Preparations were being made at the end of the assessment period to conduct the loss of offsite power test (planned for April 2,1987) and to im-piement security for the Unit 2 site (planned for April 15,1987).
On March 16, 1987, shortly after the close of the SALP period, the licensee elected to replace the ball type Main Steam Isolation i Valves (MSIVs) with a more standard valve type.
The licensee moved back the scheduled fuel load date at that time from April 30 to May 21,.1987.
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- C LBeaverLValley;UnitJ2.
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Inspection. Activities.
OneLNRC resident inspector was' assigned to Unit 2 for the entire assessment period. A new' senior' resident inspector was assigned to Unit 2 in August, 1986; to fill.the vacancy created by.the trans - fer of the previous senior resident inspector at the end of the previous period. 'Also, the NRC senior resident inspector assigned to Unit 1; devoted part.of his inspection effort;to the test program-activities at' Unit 2.
A total'of 53. inspections were performed in >- volving 5115 hours (or 5580 hours on'an' annualized basis) of.in - spection..as listed in Table 1.
NRC specialist' inspections conducted during 'this assessment'phriod .are categorized below by the functional areas of.this report.
Resident and specfalist inspections are listed separately.
. A distribution of inspection hours, by functional area, is shown in Table 2.
Enforcement data, resulting from these inspection activities,-are summarizedLin. Table 3.
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C.
Facility Performance Analysis Summary ,, CATEGORY CATEGORY LAST .THIS' PERIOD PERIOD 4/1/85 4/1/86.
RECENT ' FUNCTIONAL AREA 3/31/86' 2/28/87 TREND * Construction '1 ' ~ ~ Containment'and Other Safety Related --- Structures
-- Piping System and Supports 2.
Safety Related Components
-- Support Systems
--- Electrical Fower. Supply and. -- . Distribution '
. Instrumentation.and Control Systems-
-- Preoperational Testing
1 . Fire Protection & Housekeeping N/A
Operational Readiness N/A
Improving ' Licensing - .1
Assurance of. Quality **
2
- Trend during the last quarter of the current assessment period.
- This report also discusses " Assurance of Quality" as a separate functional area.
~ Although thi.s topic is assessed in the other functional areas as one of the evaluation criteria, discussion of this area separate'ly provides a synopsis.
For example,-quality assurance effectiveness has been assessed on-a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections.
Although quality work is the responsibility of every employee, one of the man-agement tools to measure this effectiveness is reliance on quality assurance { , inspections and audits.
These and other major factors that influence quality, y such as' involvement of first-line supervision, safety committees and worker L attitudes, are discussed in each area.
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e,- m O,. y gi u( ~ L Beave'r Val 1'eyLunit 2-8 ' g T l' ' ilV'. PERFORMANCE ANALYSES A.
. Construction (1455' hours,L28.5%) 1.
. Analysis- .During!the: previous SALP assessment period, the following' functional areas.were evaluated and assessed separately:. Containment'and Other-Safety'-Related Structures (Category 1); Piping Systems and Supports ' ' -(CategoryL 2); Safety-Related Components (Category 1); Support Sys-tems (Category.2); Electrical Power Supply'and Distribution (Cate ' - -gory 2);.and Instrumentation and ControlLSystems (Category'1). ~The summary for these functional areas noted major improvements inLthe areas of piping and. supports, instrumentation and control. systems, but continuing problems were noted in the area of support systems.
More attention to detail and the. conduct'of independent overviews and mo.re' aggressive self-identification of problems were solicited.
It-was also noted that positive steps had been taken in the way ofL l licensee initiatives, organizational realignment and tracking pro-
.,' grams which were successful..in addressing certain-previous program-matic.NRC concerns. The licensee completed review of electrical-separation: issues and established an electrical plan to achieve ?- ~ . identified corrective actions, but plan implementation had just begun.
During this assessment period,"all construction' disciplines have been combined under this one functional area.
The bulk 'of the re- -maining construction activities during this assessment period was .in' the areas of electrical distribution, instrumentation and con-trols, and re-work; Licensee management, including. technical, administrative' and-QA/QC, was highly involved in the implementation of the project electrical plan to correct electrical cable separation deficiencies. Work-related programs and procedures were well planned'and executed, . -{ Long term concerns with electrical cable separation and unsupported.
j cables were being addressed by special programs. These programs were technically adequate and generally timely, although some slip-pages did occur.
The management's weekly. update meeting showed , active participation. The management's Design Endorsement Program ' has proven ef fective in achieving verification of design.
The pro-gram has uncovered weaknesses early and obtained effective correc-tive actions. Management support to. resolve construction deficien- ^ cies and unresolved items was also evident.
Personnel involved in electrical construction activities were knowl-q edgeable of regulatory requirements and technical requirements such ! as that for Raychem heat shrinkable tubing installation which was j found to be a problem at several'other sites.
The training records of craf t personnel documented the details of the indoctrination and
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. - - , . Beaver. Valley. Unit 2 '9-A; l: Iperiodic retraining received by the: personnel. -Evidence of good.
. training.was. notable in the quality of work performed by personnel 'in'the electrical area.
y , With' respect to-instrumentation and controls, the prompt and. effec-tive' disposition of: instrumentation. deficiencies indicated licensee attention to proper resolution ~of technical issues.
In addition, the receipt inspection of instruments was thorough a'nd instrument storage areas were clean and well organized.
Staffing of the' NDE contractor for the preservice examination of piping was very good.
During the early part' of this assessment 'l period, the' licensee did not have an American Society for Non-L destructive Testing certified. Level III NDE. specialist on their- ' PSI /ISI staff...As a result, the utility did not have the ability . to independently verify the NDE contractor's data evaluation.
The licensee recognized this weakness and expanded the PSI /ISI staff-to include a certified licensee individual. A nigh level of-PSI-activity took place'during this period and the technical evaluation of the potential flaws that were identified was'signific'antly im-proved by the increased expertise of the. PSI /ISI: staff.
L One inspection during the. SALP period used the NRC Mobile Nonde-structive Examination (NDE) Laboratory to conduct an independent measurements inspection.
Selected structural-supports, fuel racks and preservice' inspection weldments were inspected, which duplicated' examinations required of. the licensee by regulations and codes, and' the results were evaluated.
Other confirmatory examinations, in-cluding those of structural concrete, were designed to. verify con-formance with material specifications and the 'results were compared to quality assurance records, Some deficiencies were. identified but the overall assessment was that the licensee's quality of con-struction was good and that the licensee's inspection program ade-quately verified the conformance of installed-hardware with NRC regulations anc nuired industry codes and standards.
The licensee conducted the containment Structural Integrity Test (SIT).
Specifically, NRC soserved that management planning, proce-dure development, prerequisite' identification, test performance, data gathering, QA surveillance and record keeping for the SIT was e.xcellent.
The conduct of the test was observed to be well managed.
Coordinated and well planned teams of competent engineering person- .I nel performed the 48 hour test and the test itself provided a direct verification of the quality of containment construction.
No defi-ciencies were identified in the performance of the structure itself.
The performance of the licensee's QA organization in supporting l construction related activities was uneven. Aggressive QC ( involvement was evident in inspecting work in progress such as I wrapping cables, instrument receipt inspections, and preservice ' I l _ _ - - - - -.
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p. : + , .. . . . l: inspection. ' Discussions with QC inspectors revealed high dedi- ' cation and. interest in assuring a quality product. However, NRC identified examples of three different types of hardware defic-iencies in the field which were found to have been accepted by QC.inspectorsduetoQCinspectionprocedureswithinadequate' guidance.
Rigid sway strut installation, safety related cable storage and.HVAC seismic'. support bolting were'found that did not meet requirements.
These hardware deficiencies indicated an apparent weekness in'the' process which. produces inspection plans l' for. accepting ' safety related hardware.
In summary,;overall. construction completion activities were well managed.
Numerous NRC field observations, including; independent examinations and preoperational test results to date, all demon-strate that-the construction / inspection process has generally worked as designed and has produced a well. constructed plant.
Thus, de-- spite some problem: with lack of sufficient detail concerning ac-ceptance. criteria in QC' inspection plans, there continues to be much: l "- evidence of good construction quality-levels in installed: hardware.
2.
Conclusion Category 1.
'3.
Board Recommendation-None.
_ _ ______
y= ,... s (, .l .. ., Beave'r Valley. Unit 2.
4. :
B.
Preoperational Testig (1841 hours,.35.9%) 1.
Analysis During the previous _ assessment period, this functional-area was as-- signed a. Category '2 rating.
The licensee was in the process of re-organizing from the' construction phase to the.preoperational' phase., Minor weaknesses:were' identified in the finalization of organiza-- tions, division of responsibilities, development'of' support group.
interfaces, absence of program description,. and management oversight .[ of program development.
Improvements _were made such that.by the.
.. ' end of the previous assessment period,-the.overall preoperational . testing program was considered. capable of assuring that all. required testing and: performance requirements were met.
-There were 17' specialist inspections and routine resident' coverage of this area during this assessment period. Much of.this inspection - effort was devoted to reviewing test procedures, witnessing test
' performance and reviewing' test results. ' Procedure review was directed at management. review, test centrols, acceptance criteria, system restoration,- test data gathering' methodology and' test ob-jective clarity. Major test' milestones received' extensive inspec- - tion coverage as did certain key -Engin'eered Safety Features (ESFs) such as the Reactor Protection System,.:the ESF actuation system, l the Auxiliary Feedwater (AFW) system, ECCS and the emergency diesel-generators._ : The progress of these' selected ESFs was close'ly-moni-- tored as they were construction proof tested.
, The licensee achieved considerable success in completing several
major testing milestones including the Reactor Coolant system (RCS)
hydro, Hot Functional Testing (HFT), the containment' structural in- ! tegrity test and the containment integrated leak rate test.
These tests were started'and completed on or ahead of schedule.
Equipment problems were resolved and test sequences were adjusted such that all major tests were accomplished successfully. The achievements of the preoperational test program are attributed to a strong man-agement commitment to the professional conduct of the test program.
This commitment was demonstrated by the high degree of. management
involvement in test problems as evidenced by twice daily meetings i for testing activities coordination and problems resolution; the marshalling of resources to resolve each problem; and the staffing i of the Startup Group with highly competent engineers with signifi- ! I cant experience in conducting preoperational testing at other sites.
Problem solving was aggressive, technically thorough, and oriented toward root cause determination.
Some problems were identified in drawing control and procedure, but these were few in number compared with the large number of documents reviewed. No programmatic weaknesses were identified.
Systems and components generally performed as designed and test deficiencies . ' ~ ._
c.
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' - W@ . ; , lif r ~. ~' g,y 9 ~ ,. . _, & iwere~ carefully tracked and aggressive 19l attacked via rework ire-. ' - . , n analysistand; retest'.1 Test data were found"toibe.of..high; qual,ity with.a conservative threshold for' identifying potentialstest'defi-- e.
a m ' ' . ciencies; ; Testi results were reviewed by the licenseeTin a; thorough,. J ' <; , , well organized manner.
C , Of? par'tibularLnote was 'the licensee'sLapproach 'to ' cold. startitestingS @ f J > of,the AFWisystem. Other units have experienced water' hammer probH } ; ," ' ilems'during theLstartup of turb'ine-driven'AFW pumps. LBeaver Valley.. ,i I .
- Unit.2 has
- long piping runs associated:with:AFW~but includedisevenz
!" drip' pots Lin' the. steam supply line tto' prevent water hammer. or waterL ' - t.
slugs;in that111ne.
NRC' questioned ifJthereiwasfadequate' assurance; ' [3 ' that the drip pot's wo'uld function; as-designed. The licenseetre :
. , > v.iewed the piping layout as represented in the? detailed scale'model-on site and stationed test observers at appropriatellocations!to i , ,,,, , p
monitor piping response for--water hammer during theitests. -The M ' , turbine / cold: start tests:were~ performed.-during HFT.and no. water; q hammer events were' observed.
The results.-give good confirmation ' !: ' , Lof'AFW system performance and-demonstrated the:. licensee's.respon-n Q'
- siveness to NRC: concerns.
. ' , , ,' ,1The licensee's QA Surveillance Group was actively;and.ef.fectively: [, involved'..in the'overvie'w and-1nspection:of testsi..This involvement- ' ' ' enabled-the.? licensee to: detect 'a. weaknessLin theLknowledge'of some
, ,7 test personnel:in.the area ofstest program administrative controls
'and take; appropriate corrective-actions.: g 'L.
m.
,. m., Ihh .0verallithAlicensee'spreoperational..testingprogram:wasanotable1 ' L - ~ strength,, with well controlled tests and highly professional problem! ) solving., '.
^2.
Conclusion
g ?u ' ' ' 0; - Category 12 .i ,. s
W 3.
Board Recommendation 'j - None.
- .
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i ,K ' M < Beaver Valley' Unit 2i
4., .C.
Fire Protection and' Housekeeping (162 hours, 3.2%) 1.
Analysis-This area was.not evaluated separately-during previous SALP periods, although_some housekeeping concerns were raised as they-impacted the acceptability'of safety related components (Storage of Safety.- Related Components).
NRC inspections assessed the adequacy of the-hardware installation ~ and the readiness of the Fire Protection Program, particularly as it related to: fuel receipt onsi.te. Additior: ally, routine resident in'spections have examined fireproof' coating material applications, fire sealant installation, and. cable-separation 'and routing activi-ties. Housekeeping,.as appropriate to the status of the Unit 2 plant conditions during construction, testing and building turnover to-the plant staff, were observed during routine plant' inspection ) tours.
.) The licensee: Fire Protection LProgram was found to be adequate for the onsite receipt of the initial.. core and its storage in the Unit 2, spent fuel pool.
Licensee. personnel were generally knowledgeable i.
in fire protection requirements and the' licensee's fire hazard an-l alysis and implementing' procedures were good.
Deficiencies were identified. in the initial fire brigade training, triennial QA audit ' plans, and the location of certain hose stations.
The licensee was responsive to the. identified concerns and-implemented effective corrective actions.
There were no significant fires-onsite during ~ the assessment period.
With respect to Appendix R, licensee management generally pursued fire protection issues to their' proper resolution.
The licensee has made several modifications to achieve compliance with Appendix
R separation requirements.
The licensee' also demonstrated redundant J means of achieving a plant safe shutdown in the event of a fire, including use of the Alternate Shutdown Panel.
During HFT, the , L licensee exercised both remote panels by physically controlling plant systems and hardware and achieving plant cooldown. Wal kdowns have further demonstrated that the licensee's procedures were well planned and that adequate procedural training had been given to the 'l operators.
With respect to housekeeping at Beaver Valley, Unit 2, acceptable levels of site cleanliness wree noted throughout the period.
The i ,
l acceptability of site housekeeping appears to be dependent upon the I status of plant activities; construction areas require continual licensee attention but generally exhibited good controls, buildings
turned over to the plant staff appear to be maintained in good order, i and other plant areas appeared to improve as the preoperational testing and turnover process progressed.
- - - - - _ -
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- BeaverValleyUnitf2
'14 'M' _ g.
'
- }
. k Early in the pe'riod, metal' shavings'were. introduced into'the RCS
after a sceam generator: nozzle' dam.was. inadvertently'left in the
- '
.
- RCS and was-shredded by one reactor coolant pump..The licensee'.s.
ll ^ ' - recovery efforts were exceptionally thorough and inciu'ded re-flush-h inglthe'RCS, the~RHR system and_the CVCS seal injection lines,. con. ' i ' ducting nitrogen blows'of the steam generator' tubes, and performing l H aihand wipe-down of the inside. walls'of affected piping.
Licensee- , corrective actions were' effective'in preventing any recurrence of; RCS cleanliness degradation.
,o .. ( EThe preservation of-plant systems and. equipment was enhanced by.the I-licensee's practice of placing turned'over equipment under.the.s'ame , , M ' surveillance.and maintenance programs as will be used during plant-- d i operation.
Extensive ~use of cleanliness enclosures, equipment covers, and gauge-shields was observed and is indicative of a high-
. ~3-level of attention to the, preservation and protection of installed i components.. ~ Substantial efforts were evident to clean up areas ~ '
, where construction was essentially complete, to complete painting l activities, and to give turned over building a. finished appearance.
f-3 In summary, the licensee was aggressively: pursuing fire-protection" i issues,c related systems and 1,ardware were being properly tested to.
w demonstrate. effectiveness, and the overall program status, including; j ~ L procedures and. training,.was good.
Housekeeping'was found to-be~
, generally very~ good-with the maintenance and preservation of turned.
' , over hardware-a notable strength.
'2.
Conclusion-Category l2.
3.
. Board' Recommendation.
None.
l I ! ! -. . - - _ - _-_____--___O
_- , ._ -_ __ - - - _ - . _ - _ _ ... _ _ _ _ _ _ - _. _ a . . Beaver Valley Unit 2
L *, D' Operational Readiness (764' hours,14.9%)- , 1.
' Analy'si s j This' functional area, not assessed previously,'is used to evaluate-l licensees at the Near Term Operating. License-(NTOL) and. low-power stages on the facility's readiness to:recei a a fuel load license, conduct low power testing, and receive a. f ull power license. -This functional area includes the consideration of Procedures and Staff- ! ing, Training and Qualification, Security, Radiological Controls and Chemistry, and Emergency Preparedness. Assessment of each of .i these areas.is discussed separately below.
J 'I a.
-Procedures and' Staffing Excellent management oversight'was evident in the procedure development process as evidenced by the overall quality of the construction proof and preoperational tests as'well as the.
development-of' maintenance surveillance procedures,for instru-ment channel functional and calibration. tests that are used by the station during operation.
The latest NSSS vendor test: experience at recently licensed stations was. factored into the procedure development process.
The Joint Test Group provided j-an effective multi-discipline review of' test procedures for l-scope and acceptance criteria to ensure regulatory commitments were-met.. No significant~ deficiencies indicative of program-matic problems were identified.
Adherence to administrative controls for procedure use was evident during testing...All major preoperational tests con-tained mandatory QA hold points, and significant portions of most tests were witnessed by the QA Surveillance Group. Their presence and findings early in the test program resulted in a rigorous enforcement of'the Startup Manual administrative controls for test conduct.
Early in this assessment period,
an NRC concern was identified relating to operations use of Temporary Operating Procedures (TCPs).
These concerns related tc completion of TOP documentation and adequacy of system alignment control.
The station was responsive in emphasizing procedure adherence and in using specifically marked up Operat-ing Manual (OM) valve lists as approved attachments to control system alignments. Consequently, there were few problems that occurred later during testing related to operations procedure adherence.
The development of Operational Surveillance Tests (OSTs) also ,, progressed well. Once a system was turned over to the station, i t was put on t.he routine surveillance schedule to maintain operability by performance of the OSTs that are to be used when the plant is licensed.
. _ _ _ _ _ _ _ _ _ - _ _ _ _ -
-- _ _ - _ - _ - - _ - _ _ - _ - - - - - - _ - _ -- -- .
. Beaver Valley Unit 2
<. The commitment tracking system was found effective with regard to updating plant procedures. As examples, as vendor manuals-were revised for the reactor trip breakers, applicable MSPs were also updated in a timely fashion and new commitments re-lated to'the low-temperature overpressure protection system were included in the next CM revision.
The staffing of the Unit 2 operating staff, 1&C technicians and maintenance groups with Unit 1 personnel is considered a notable strength and has facilitated the testing, modification and maintenance of Unit 2 systems, b.
Training and Qualification The first of two sets of scheduled initial licensing examina-tions was administered about one month before the end of the SALP period.
The Beaver Valley simulator was not used due to - the differences between the simulator and the Unit 2 Control Room. All candidates for this exam were previously licensed on Unit I and had approximately three years experience.- Of the 19 candidates, 16 were issued licenses (84%) which in'di-cates that the licensee's cross-training program has been effective.
Some weaknesses were noted among the candidates, but as a group, they performed well.
The training and experience level of the Unit 2 staff is very high.
Both the licensed and non-licensed operators were drawn from the Unit 1 operating staff with all of the initially licensed Unit 2 personnel hav'ng been previously licensed on Unit 1 and therefore, have signif.icant levels of experience, as well as the benefit of Unit 1 training and Unit 2 cross-training. The surveillance and maintenance activities were also conducted by personnel experiet ced with the very similar I equipment at Unit 1.
I c.
Security ) l During this assessment period, the licensee's performance was i evaluated during the development of a physical protection pro-gram for Beaver Valley Unit 2 and the preparation for inte-gration of the Unit 2 program intt a site (Units 1 and 2) security program. Also assessed, kas the licensee's perform-ance in developing and implementing a security program for the receipt and on site storage of special nuclear material (new fuel).
=-_ -_ - _ _ - _ - - - - - - _ -
- um, ' .*. , ' Beaver Va11ey' Unit.2~ 17.
. e.
, X- ' >k The licensee s program and procedures to control and account
for special nuclear' material at Unit 2 were;found to be.ade-quate as was _ the licensee's plan for. the protection of;the new ~ fuel. However, one violation of that' plan was identified when the licensee f.niled to assure the integrity of the' controlled' access area used for new fuel storage.
r
The licensee's overall security organization'n was severely stressed during the last half of.the SALP period. A new, sec'urity force contractor took over site security shortly after the Unit 1. security responsibilities had been expanded by the need to establish a controlled access area at Unit 2 for the.
protection of the new fuel. The site Director of Security . resigned during the period and the licensee promoted from.
within such that the.three member licensee security oversight staff suffered a sharp reduction lin cumulative nuclear plant-security experience. Additional challenges occurred in the last quarter of the SALp period as'the licensee needed to pre- > pare and submit Security Plan changes, install and test new systems, and train.and qualify many additional guard force members. The impact of these challenges was especially severe due to the manning level and changes to the licensee's secur-ity oversight staff. The increase in scope associated with adding a second unit to the security plan indicates that the oversight staff will continue to.be severely challenged, especially considering the problems.. inherent with the__startup of new systems and equipment.
The. initial.NRC preoperational program review found that in-sta11ation of.necessary security systems, equipment and hard-ware was not complete.
While some portions of most systems were installed, none were at a stage where preoperational testing could be accomplished.
The review.also disclosed that the licensee had not submitted to the NRC for approval'a security plan that integrated the Unit 2' security program.with the Unit 1 program. The complexity of combining both units under one security program apparently had not been fully under-stood by the licensee.
Deficiencies in hardware, communica-Hi tions and. planning contributed to the situation along with under-estimation by the licensee of the work and rework re-quired for installation of the security systems and equipment.
Subsequently, the allocation of substantial resources by the licensee to expedite secuMty system completion was evident including priority attention to security system installation, removal of entire buildings near security fer.cing and emplacing of macadam surfacing and camera towers.
, .
___im_.
._.__i__._..-. -
-_-__ _-
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- .;
~ Beaver.' Valley Unit 2
- .
The classroom portion of the guard force training and qualifi-4.
cation process was adequately defined, training modules'have.
s ' been developed and were being implemented for the additional-s guard force members needed.for. Unit.2. ' Practical training, however, was being' hampered due to the'new systems and equip-ment not yet installed.
Close management attention toLthis ' aspect of the training. program will be, reg'uired to ensure that
all members of the guardforce receive adequate training.
< 'In: summary, late in the assessment period, the licensee initi-ated actions'following NRC expressed concerns to provide high level. management attenticaLto, and escalated the priority of,_ the planning and,impler.entation of the Unit 2 security program.
Continued management attention will' be necessary in order to minimize the potential.for the security program to impact on the' licensee's readiness..to receive an ope' rating license, d.
Radiological Controls and' Chemistry During this' SALP period,. the licensee's' performance was evalu- - r ated during the development of preoperational. test procedures,.. organizational changes and dual unit programs.
There were four- , inspections conducted by. regionally-baud inspectors' in this t area; two in radiation protection *and:two1 1n, effluent controls and chemistry programs.
Resident inspectors performed routine reviews of the. program area throughout the assessment period.
' Generally,-the pro'gress, details, and quality of the licensee's r.
, ' radiological controls program were within the expected norms for the development and completion milestones during the. cur-rent preoperational phase of the project There is evidence 4' . of' prior planning, assignment' and tracking of self-identified , open items and priorities for operational readiness.
The ,
' Operatienti Readiness Review Team had a member of the radio-logical controls organization who assured proper attention to such matters. The licensee adequately completed developing t' the preoperational test procedures for the effluent monitors, .. process sample stations, and radioactive waste systems.
Liquid
and process sampling system pre-operational testing was in ' progres% and was adequate to date.
Y flotably, the licensee has order several. types of new high ' ' t quality equipment to facilitate dual-unit operation, such as . sensitive automated friskers and state-of-the-art whole-body-
' ' counters. Also, numerous physical barriers.for potential high I radiation areas, in addition to those already identified in i the original ALARA design review, are being installed. These ! i . items are considered indicative of the licensee's intent to build a high quality program based on a conservative radiation protection philosophy.
i l' , , i Il. , t, j/ '
_ _ - g ' Beaver Valley' Unit 2)
). '. The ' licensee has established an organizational structure to support combined Unit I and 2 operations; permanent staffing , of these organizations was almost complete'and site specific manuals for both chemistry and effluent controls were'close to completion.
Unit 2 staff-qualification will be completed after the manuals are issued. The' licensee's' efforts' in thi s area were indicative of advanced planning to ensure an ade-quately qualified staff is available.to support Unit 2, opera-tions.
In summary, an on-site organization to support combined opera-tion of Units 1 and 2.has been established. Advanced planning.
to identify and track items based on plant differences and on program areas to be upgraded was evident. Adequate progress was noted in the development of the radiological controls pro- . gram with respect to the overall completion of the project.
Licensee plans to make major capital' purchases of upgraded equipment, to improve the overall quality of procedures, and to improve exposure' controls by adding additional physical access control to various radiation areas were noted.
e.
Emergency Preparedness During this SALP period,-emergency preparedness assessment was . limited to those aspects needed to. support fuel load at Beaver Valley Unit 2.
Beaver Valley Unit I received its operating license in 1976 and has been in operation since that time.
The two units will have the same emergency response facilities.
the same low population zone and emergency planning zone, and similar procedures.
Unit I has maintained a SALP Category I rating in the last three SALPs due to DLC's commitment to excellence in the area of emergency planning. This commitment has been consistently demonstrated through the dedication of adequate resources, extensive training and drilling of personnel, and exceptionally effective interface with all local government agencies.' The same EPF group responsible for this good performance has re-sponsibilities for BV-2.
The operations staff at Unit 2 has at least one year operating experience with Unit'1, including participation in pest site drills. Site specific procedure development and training was progressing on schedule.
In summary, a strong management cos1+. ment to this functional area has been evident at Unit 1, and all indications point to a continued commitment as Unit 2 is integrated into the emer-gency plans.
, I k
_ _ - - - _ _ _ _ _. - -
__., ' j^. l 4.1 ' ' Beaver Valley Unit:2.
x 1,, f.
Overall Summary , , , The overall assessmentLis that the licensee:made good progress.
during.the period in finishing construction and testing 1acti-vities-and achieving aLgood level of. operational; readiness.
The: status of pr~ocedure'and.operatingLmanual development, ' s.taffing and. qualification,'and radiological controls and chemistry was consistent with.the licensee's announced schedule.
Strengths.noted in these areas include.the quality of-proce-
- dures, the experience of the staff,'and a conservative radi-
ation. protection philosophy.
Unit 2-is expected'to benefit from the same strong management commitment to excellence'in.
the' emergency preparedness that-Unit I has received.
Some ' , deficiencies were noted 1n the progress of security 1 program ~
? development and system. installation, but the high' level of.
management attention and resource allocationLobserved late'in the period:. indicates that this area. probably will not. impact overall readiness for operation.
l.
-2.
Conclusion: Category 2, Improving.
, 3-Board Recommendation . Licensee: Assess the current manning level of the security oversight staff in light of the increased scope.and responsibilities associated with a dual. unit site security program.
NRC: None.
l
a l i s l l l I
) J - . - _
_ -- _ _ - - _ - - - - - _ _ - - _ _ - -- - - - - - - - - - - -- .. . ~ Beaver. Valley Unit 2'
., E.
Licensing Activities 1.
Analysis This area was assigned a Category I rating, improving, in the last SALP assessment. An overall strong performance was noted with good performance in resolving several major issues, increased respon-siveness and cooperativeness with the NRC staff, and aggressive approach in resolving issues.
, Throughout the. review process during this assessment period, DLC's activities generally exhibited evidence of prior planning and as-signment of priorities.
This was shown by the licensee's approach to resolving numerous open and confirmatory items identified in the
staff's Safety Evaluation Report (SER). Generally, DLC management assigned the necessary technical people to develop complete, high = quality responses. OLC has performed an Engineering Assurance pro-gram (EAP) using outside contractors, in-house DLC engineering per-sonnel and Stone and Webster (SWEC) engineering personnel which was reviewed by the NRC. As a result'of the applicant's cooperation, the NRC was able to conclude that the EAP audit provided significant additional confidence that the design of Unit 2 is in accordance with design commitments and regulatory requirements.
DLC's management demonstrated awareness of the licensing issues by virtue of DLC's experience in the industry, technical expertise, and active participation in owners groups.
The licensee, in cases where generic questions arise, has made use of industry owners groups to develop acceptable resolution to licensing issues, e.g., resolution of Salem ATWS issues.
The licensee's management also consistently exercised firm control over its design contractor's activities and maintained good communication between the contractor, his own staff, and the NRC staff.
Strong licensee management involvement at the Senior Vice President level, who is stationed at the site and is responsible for managing the design, construction, startup, operation and maintenance of Unit 2, has produced positive results. Also, the DLC Regulatory Affairs r.rd Engineering staffs are both located at the site. As a result, in regard to licensing activities, there has been evidence of a close working relationship between the two staffs.
The licensee continued to use a tracking system for resolution of licensing issues.
The tracking system included all SER outstanding and confirmatory issues, proposed license conditions, and TMI NUREG-0737 issues.
In addition, any other major issues requiring resolu-tion (i.e., design and FSAR changes that require revisions to the staff's safety evaluations) are also included.
This tracking system has been very helpful in tracking and resolving the remaining lic-ensing issues.
- - _ - _ _ _ _ . _ _ _.
, . Beaver Valley Unit 2
i Beaver Valley Unit 2 is the lead plant in application of leak-before-break assumption to high energy' lines inside' containment.
The lic-ensee held frequent meetings with the staff on this issue and demon-strated good technical understanding and a cooperative attitude in these meetings. As a result, the staff was able to fully ccmplete this first of a kind review and provide the bases for authorizing (in SSER 4) a deletion of unnecessary pipe supports inside.the con-tainment building.
Open and effective communication exists between the NRC and DLC's licensing staffs.
Effective dialog between both staffs usually-promotes prompt and technically sound: responses to NRC initiatives.
The licensee has open dialogs with the' Project Manager on a daily basis.
Conference calls with the staff are promptly established
and included appropriate engineering, plant and/or contractor per-sonnel.
DLC staff demonstrated a good working knowledge of applicable regu-lations, guides, standards and generic issues pertaining to their plant. This was evidenced by their positive attitude and respon-siveness to the NRC staff in addressing unresolved SER issues.
DLC staff has always been prepared to meet with the NRC staff in a short time frame to obtain the necessary understanding of NRC information needs and has been successful, by preparedness and aggressiveness, in expediting SER issue resolution.in a timely manner.
During meetings, the licensee demonstrated a thorough understanding of the technical issues and effectively used the services of its architect-engineer, SWEC, and other contractors as needed.
DLC's promptness was especially demonstrated during its frequent meetings with the staff. The licensee kept the NRR project management generally in-formed regarding plant completeness status and major milestones.
However, some licensee delays in transmitting requested information had the potential to impact the staff's review schedule.
In summary, overall strong performance was observed in the func-tional area of Licensing Activities.
The licensee's steady per-formance during the current rating period, specifically, good per-formance in resolving several major issues, continued responsiveness and cooperativeness with the staff, and aggressive approach in re-solving issues are the main factors in this assessment.
2.
Conclusion Category 1.
3.
Board Recommendation None.
- [ ,
.
p.
.- l u,. , . - Beaver Valley Unit 2
1 I . . J F.
Assurance'of Quality (893 hours, 17.5%). ,, 1.
Analysis During the previous SALP period, this functional area was assigned._ .a Category 2 rating.. Management changes'and' programs were. initiated ' . which significantly strengthened the overall project by. establishing a strong' management team and by providing' program tools to ' control the resolution of' problems. 'A weakness was noted in the direction . of therlicensee's programs 'in that they tended to be reactive rather.
than aggressively identifying weaknesses in "frontend" activities . 'which would help reduce the' number of recurrent-deficiencies.
During this assessment period,- the earlier management changes' and program.'; were major. factors in enabling the licensee to successfully.
accom'lish major test milestones, such as HFT, SIT and ILRT, on p schedule.
Twice daily meetings of first and second level supervi- < sors ensured that-potential schedule problems were promptly 'identi-fied-and elevated to the. attention of management'. Weekly on-site.
meetings involving' senior corporate' management assured the' timely allocation of resources to address potential problems.
The weekly briefings, which were attended by the Chairman' of the Board, demon-strated the active involvement of senior corporate management in completing the project.
The result has been a smooth and integrated organizational response to complete construction,. conduct major tests and make necessary changes.
The licensee formed an Operational Readiness Review Team (ORRT), -headed by the Unit 1 Plant Manager on a-full' time basis. The ORRT was observed to be aggressively involved in examining all elements of operational readiness to assure that the programs and procedures required for an operating' license are in place. The startup acti-vities were being conducted in'accordance with the Station Startup Manual which is'similar to the Unit I station administrative proce-dures. This approach and the heading of the ORRT by the Unit 1 . plant manager, designated to be manager of both units after license issuance, helped achieve a smooth operational transition.
Early in the. proje_ct (before -1979), the licensee selected a new and essentially untried ball-type MSIV design which offered certain potential advantages (e.g, no valve slam).
Factory acceptance testing (1981-82) was fairly extensive, but was performed at ambient temperatures, not steam system operating temperatures.
During this assessment period,..the only other utility which had' also selected - the ball-type MISVs encountered severe problems with these valves.
The licensee created the MSIV Modification and Test Program which was a good initiative to ass'Jre quality even though it was reactive in that it was in response to problems identified at another site.
The program was also anticipatory in nature in that it included extensive contingency planning, including identifying the best
_ _ _ _ _ _
_ _ y[ 20e ' c .' %' , BeaverVAlleyUnit'2' 2'4 t' , available replacement valves, vehifying stress analysis compatibil k zity, and procuring' critical valve components.. Just-~after the close of.the SALP period, the other utility abandoned their' ball l type .MSIVs leaving Beaver Valley Unit 2 in a potentially untenable posi- ~ tion with. respect to the previously joint MSIV qualification-testing ,- (program.. Due to the excellent previous pre planning, the licensee ,was able to. elect to replace the Beaver Valley Unit 2 MSIVs with' minimal. schedular impact.
Another program, the Quality Concerns' Prog' am, aggressively. soli-r cited and pursued the questions and potential _ concerns of employees.
All outgoing employees were interviewed and al hotline number was.
' published site-wide with assurances of confidentiality.
Each con-. cern was assigned. a tracking number and program ' participants were provided with written letters documenting item resolution. -This-program is considered to be a major factor _in the very low incidence of allegations during this period.
A positive attitude was displayed by onsite workers. _ Effective first line supervision was evident during'NRC work observations.
The staffing level for QC personnel was high; they were aggressively involved in ongoing construction'and testing activities. Good.
records have allowed the licensee to resolve areas.of potential concern and provide documented evidence of quality.
. An overemphasis on paper by QA was identified during the: period as some audits concentrated heavily on documentation completeness rather than assessing the technical adequacy of the area audited.
Weaknesses were identified in the acceptance of rigid sway struts, the_ storage of cable, the installation of seismic supports, and the resolution of. professional differences internal to the QA organi-
zation.
The.QA overemphasis on paper was clearly demonstrated in l the licensee's' actions concerning PT indications on safety related
welds and piping.
The indications were identified in April,1986, by PSI personnel taking ASME XI baseline data who concluded that the indications were acceptable under ASME XI, but did not. meet the-more restrictive ASME III (N-stamp) construction acceptance criteria inspected against two to four years earlier.
No actions were taken until December 1986 because licensee representatives questioned the jurisdiction of ASME XI inspectors to make f_indings under ASME III i instead of addressing the tecnnical validity of the findings. The i NRC had to request that the licensee address the technical signifi- ! cance of the identified weld deficiencies. The velds were rein-l spected and repaired as necessary in January,19P The delay in ! resolution was the apparent result of the QA organization's over-i emphasis on " paper" and ineffectiveness in resolving internal dis- ) agreements.
' , , I Y-__--.__._--
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, , , z.
LBeaver Va11eyLunit: 2
- 25
., , % In summary, good engineering, auality construction ~, ~ aggressive QC, ' o and thorough preoperational testing programs _ have provided good assurance that a high. level of quality has been achieved ~ The ag-gressive' involvement of the site < staff and?a11l levels of management.~ have' been -exceptionally. effective. in anticipating, identifying,.and resolving potential problems and gives additional. confidence that a high' level of? qualityiis being achieved. :However, there was-little evidence ~of the'use.of.QA'as a management tool in that QA1 ' Lwas not used for assessment, to make~ improvement recommendations,- to identify problem Lroot causes, or to trend and identify ' developing potential ~ problems.
2.
Conclusion l L 'l i Catego ry. 2.
~3. 1 Board Recommendation None.
,
l' l ! 'l,
, .. I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - -
m_. (Z '
- 4 p
- Beaver 611ey Unit l2 ' 26-
V.
SUPPORTING DATA AND SUMMARIES A.
Investigation' Activities Three allegations we're received during the evaluation' period. One con-cerned alleged drug abuse, another involved alleged QC. inspector harass- . ment, and the third involved alleged conflict of interest.
Licensee and .NRC-investigation and followup. activities concluded that none of'the allegations were substantiated.
B.
Escalated Enforcement Action No escalated enforcement actions took place during the. evaluation period; however, Violation 86-29-01, concerning improper reporting under 10 CFR 50.55(e) was subsequently issued as Severity Level III with no Civil Penalty.
C.
Management Conferences ' July.9, -1986 - A special, announced management meeting at NRC's request to discuss the results of the Region i SALP board convened to assess licensee performance from April 1, 1985 to March 31, 1986.
December 15, 1986 - A special, announced management meeting at the lic-ensee's. initiative to discuss the modification and testing program in-tended to correct problems experienced with the ball type main steam isolation valves.
January 5, 1987 - A special, announced management meeting'at NRC's re-quest to discuss the status of the Operations Training Program, and the cross-training program for Unit 1/2 operators.
February 18, 1987 - A special, announced management meeting at NRC's re-quest to discuss the status of security program development, and the potential impact on. fuel load.
D.
Construction Deficiency Reports (CDRs) Seventeen CDRs were submitted by the licensee during the assessment period.
Nine of the deficiencies were the result of design or fabrica-tion errors.
Four CDRs were caused by personnel error.
Three of the deficiencies were associated with vendor supplied hardware. One CDR resulted onsite due to installation of insufficient bolts on a seismic support.
Construction deficiency reports are listed in Table 4.
E.
Licensing Activities During the SALP period, numerous meetings and site visits took place and many documents were issued by the NRC. The following major licensing i actions took place during the period:
1
J
_ ;- p ,w a.
O Bea'ver Valley Unit.2
'. May 28, 1986 SER Supplement 1 issued.
July 7, 1986 Engineering Assurance Program' determined to be acceptable substitute for IDVP or IDI.
August 25, 1986 SER Supplement 2 issued.
September 30, 1986 Seismic Qualification Review Team and Pump and Valve
' Operability Review Team onsite audits begin.
November 6, 1986' First. draft to Technical Specifications' transmitted.
November 18, 1986 Environmental Qualification Review Team onsite audit ~ ! ~ begins.
November 25, 1986 Construction Permit (CPPR-105) extended to December 31, 1987.
l December 1, 1986 SER Supplement 3 issued.
Detailed chronologies of licensing activities are documented in SER Supplements 2 - 4, Appendix A.
... . _ _ _
. _ _ _ _ _ _ , L ' e.
L.. Beaver Valley Unit 2- ' . TABLE 1 INSPECTION REPORT ACTIVITIES- { INSPECTION AREAS-REPORT NO.
HOURS INSPECTED' - 86-07.
Resident Licensee action'on previous inspection fin' dings, pre-- 214 Hours operational' test program implementation, RCS cold hydrostatic test, Emergency Diesel Generator and High Head Safety-Injection Pump proof testing, and QC ' program implementation.
86-08 Specialist RCS cold hydrostatic test; including review of the 76 Hours test procedure, prerequisites, preparation; test witnessing; and coordination between contractor and licensee QA personnel. Also, followup on previous inspection findings.
86-09 Specialist Engineering Assurance Program technical audit pre-240 Hours paration in the areas of mechanical systems, mechani-cal components, civil / structural, electric power, and instruments and. control.
86-10 Specialist Installation of electrical system'and components.
35 Hours 86-11' Specialist Review of preoperational test procedures and results, 35 Hours QA/QC interfaces, design of AFW turbine driven pump steam admission line design for water hammer poten-tial, "C" RCP problems and licensee action on pre-vious inspection findings.
86-12 Resident Licensee act1on on previous inspection findings, pre-158 Hours operational test program implementation, RCS cold hydrostatic test evaluation and system restoration, and Emergency Diesel Generator exhaust hood insula-tion failures.
86-13 Specialist Independent measurements inspection using the NRC 376 Hours Mobile Nondestructive Examination Laboratory on j selected structural supports, fuel racks, and pre-l service inspection weldments.
! 86-14 Specialist Nonradiological chemistry program including training,
58 Hours requalification,.and analytical procedures evaluation.
~ I I I T1-1 I l . %u_ - _ _ _ _ _
-
- s.
Beaver Valley Unit 2- ., INSPECTION . AREAS REPORT NO.- -HOURS INSPECTED 86-15: Resident Licensee action on previous inspection findings, pre-208 Hours operational. test program implementation, proof test-ing of AFW pumps, operational testing of station. bat-teries, progress of. electrical separation programs, and followup on: electrical support allegations.
' 86-16 Specialist Nuclear material control and accounting including: 81 Hours organization, operation, shipping, receiving, stor-age, internal. control, inventory, document control, and management.
86-17 ' Specialist Engineering Assurance Program technical audit.
240 Hours 86-18 Specialist' Preoperational test program implementation. procedures,. 31 Hours test results for cold hydrostatic test, QA/QC inter-face, proof-testing for manual and motor operated valves, and licensee actions on previous inspection findings.
i 86-19 Specialist Reactor vessel installation and associated procedures 42 Hours and QA records. Also, installation, modification and QC of safety related mechanical. equipment.
86-20 Specialist Preoperational test program implementation, proce-40 Hours dures, QA/QC interface, containment instrument air compressor testing, resolution and status of main ' control board changes, and licensee actions on pre-vious inspection findings.
86-21 Resident Licensee actions on previous inspection findings, 219 Hours preoperational tes'. program implementation, new fuel receipt, Physical Security Plan implementation for protection of the new fuel, licensee response to bomb threats, preoperational test procedure review, and solid state protection system proof testing.
86-22 Specialist Preoperational test program implementation, test l 71. Hours witnessing, QA/QC interface,. installation and re-moval of temporary strainers, and licensee action l on previous inspection findings.
y 86-23 Specialist Engineering Assurance Program technical audit.
[ 160 Hours j q 86-24 Specialist Operational readiness in the areas of operations, j 52 Hours maintenance, and QA.
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Be' aver Valiey: Unit:2.
! E j , , ') . INSPECTION-AREAS-REPORT: N0; ' HOURS- ! INSPECTED' j , '86-25-l Specialist- .Preoperational test program implementation, proce-33 Hours dures, results, QA/QC interface,.MSIVs,.new fuel receipt and licensee actions on: previous inspection findings.
' .86-26' . Specialist.
Preservice Inspection Program and: data.
a 36 Hours '86-27; Specialist Preoperational test program implementation,"proce- . 46 Hours.
dures, QA/.QC interface, MSIV' testing, test-witness-ing and licensee action on previous inspection-findings.
86-28.
Specialist Preoperational test program implementation,.proce- ~ 70 Hours 'dures, test witnessing, QA/QC. interface, MSIV testing, and licensee action on, previous inspection, findings; 86-29 Specialist Activities involving instrumentation,; control'and-39 Hours.
electrical ~ systems and components and: licensee ac- ' tion on previous inspection findings.
86-30 Specialist ' Instrument and instrument cable installation, work 39 Hours observation and document review.. 86-31 ' Resident Licensee action on previous inspection findings, new 287. Hours fuel receipt, security, potential.for High Energy Line Break.in'the Safeguards Building, rigid sway strut' functional interference, preoperational. test program implementation including testing of AFW, emergency-diesel generator (EDG), SSPS, and reactor trip breakers.
86-32 Specialist Preoperational test program implementation, proce-50 Hours dures, test witnessing,.QA/QC interface, AFW and MSIV proof testing, and licensee action on previous in- , spection findings.
86-33 Specialist MSIV ball valve operability and ring setting problems.
37 Hours 86-34 Specialist Radiation protection program, preoperational activi- , 52 Hours ties and new fuel receipt, handling and control i program.
.86-35 Cancelled 86-36 Specialist QA Program for preoperational testing and licensee 73 Hours response to Generic Letter 83-28, Salem ATWS Event.
TI-3 i __ 9
! I i 1 h ., ~ Beaver Valley Unit 2
- a, < , / INSPECTION " AREAS ' REPORT NO.
' HOURS.
INSPECTED !
- 86-37..
Special'i st: Preservice' inspection activities and procedures, and-32 Hours ~ nondestructive examination' activities and records.
'86-38 ' Specialist Preoperational-test program implementation'n, proce-50 Hours.
.dures, test witnessing, results, QA/QC interface, -MSIV test facility, EDG history, and licensee action on previous inspection findings.
86-39 Resident Licensee action on. previous. inspection findings, new ' 150 Hours-fuel. receipt, Hot Functional Testing, potential fail-ures of multiple ECCS pumps, TMI Action Plan Require-ments, AFW and MSIV testing.
86-40
- Specialist'
Preoperational Test program implementation, Hot 83 Hours.
Functional Testing,- QA/QC interface,.MSIV testing - 1 and licensee action'on previous inspection findings.
86-41-Specialist
- Installation and rework of electrical power cables 36 Hours and related documentation, calculations and verifi-cations of voltage levels during transients, and licensee action on previous ~ inspection. findings.
86-42 Specialist Operational readiness in -the areas of procedure pre-31' Hours.
parations and staffing for operations, maintenance and instrumentation and controls.
86-43 Specialist Preoperational test program implementation, test 186 Hours witnessing during HFT,lQA/QC interface, MSIV latch testing, and licensee action on previous inspection I findings.
'86-44 Resident Licensee actions on previous inspection findings, 372 Hours Hot Functional Testing, AFW and RPS system testing, regenerative heat exchanger weld indications, pre-service inspection activities, MSIVs,=firewrap of HVAC ductwork., radiation monitoring system reviews, TMI Action Plan Requirements, and preoperational test program implementation.
]
86-45 Specialist Process monitoring and radioactive waste system pre- ! 82 Hours operational testing and organization, staffing and procedure development with respect to chemistry and effluent controls.
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J Beaver Valley Unit 2 k.', INSPECTION AREAS q-REPORT NO.
HOURS: INSPECTED j 86-46 Specialist Electrical splices and~ terminations utilizing heat .. . 26 Hours shrink tubing to determine conformance to 10 CFR 50.49 and IE Notice 86-53,." Improper Installation of Heat ., Shrinkable Tubing," and licensee actions on previous inspection findings, p 86-47 . Specialist Licensee action on previous inspection findings,
' ' 61 Hours electrical separation. rework activities, 'and storage and protection of safety related electrical cables.
87-01 Specialist Operational readiness in the areas of procedure .74' Hours preparation,' staffing and implementation for opera- -tions, maintenance and instrumentation and' controls.
, , -S7-02 Resident . Licensee action on previous inspection findings, pre-461 Hours operational test program implementation, containment structural acceptance test and integrated leak-rate test, security, RPS testing, TMI Action Plan Require-ments, control room wall removal, CO actuation of
fire dampers, HVAC equipment seismic supports,-EDG testing, and charging pump test deficiency resolution.
87-03 Specialist QA Program, receiving inspection, storage and hand-158 Hours ling, design change and modification' program, OSC, and non-licensed training.
87-04' Specialist Preoperational test program implementation, procedure 67. Hours review, initial startup test program status, QA/QC.
interface and licensee actions on previous inspection findings, i ' .87-05 Specialist Preoperational testing of security systems and review 38 Hours of status for security implementation.
'87-06 Operator License Exams * 87-07 Cancelled 87-08 Specialist Management meeting in Region I Office to discuss 8 Hours Unit 1/2 operator cross-training.
{ l i !
- This report documented the NRC administration of exams and involved no NRC in-
-spection hours.
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, _ __ _ -- - _ _ _ _ _ - - - _ _ -. - - - - - _ - - ______ \\ J ). ' Beaver Valley Unit 2 ' INSPECTION-AREAS REPORT NO.
HOURS' ' INSPECTED 87-09 Specialist Operational radiation protection program; organiza- - 38 Hours tion and management. controls, external exposure and personnel dosimetry, internal exposure control and assessment and. control of radioactive materials.
l 87-10 Specialist Preoperational test program-implementation, QA/QC 62 Hours interface, operational. readiness and licensee actions on previous inspection findings.
87.-11 Specialist Fire protection piping installation and program.im-31 Hours plementation.
' 87-12 Specialist Containment Integrated Leak Rate testing and'struc-' i 66 Hours tural acceptance test, 87-13-Specialist Activities associated with radiography ~of the Re-t 33 Hours generative Heat. Exchanger welds and reporting of. PSI . identified deficiencies.
87.-14-Inspection conducted during next SALP period.
, I l 87-15-Specialist QA Program effectiveness in areas of document centrol, l' 32 Hours _ records and preoperational readiness.
i - i > i i I T1-6
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_ - _ _ .'.Q' , Beaver Valley Unit 2 .. . TABLE 2 INSPECTION HOUR SUMMARY (4/1/86 - 2/28/87)' ACTUAL AREA HOURS ANNUALIZED % OF TIME 1.
Construction 1455 1587 28.5 2.
.Preoperational Testing 1841 2008 35.9 3.
Fire Protection and l Housekeeping 162 177 3.2 4.
Operational Readiness 764 '833 14.9 5.
Assur;ance of Quality 893 974 17.5 6.
Licensing
0 _ 0.0 TOTALS 5115 5579-100.0 l , i
! l h i L T2-1
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. L Beaver Valley Unit-2
< \\ TABLE 3~ ENFORCEMENT ACTIVITY A.
Violations Versus Functional Area By Severity Level ~ Functional No. of Violations in Each Severity Level Area Dev.
V IV III II I TOTAL 1.
Construction - -
- -- - 2-2.
Preoperational Testing
1
- - -
3.
Fire Protection & Housekeeping - - - - - - - . 4.
Operational Readiness -
- - - .
' 5.' Assurance of-Quality - -
- - -
6.
Licensing - - -
- -
TOTALS
2
1
0
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e -.... 86t13-01' 210.CFR 50.55A= IV.
5' NRCL-identified iridica,: w , -( ' ,4 j , . tion.on previously,. ' s , s '^ " ' g- - accepted ste.am, genera- , , , , , h4 tor. supports:that..had- ' ' ,
. , , not: been: di spositioned.. ' m.
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, . h 86-13f02L ildCFR'50, IV '5 . NRC-identified unac-- . ' iAppLB,- - ceptableilinearfindiT~
- F
, ~ J-Criterion.V.' cations;on~ spent l fuel' , . storage +acks;3- . s.. ! 86-21-01L Special4 Nuclear V-
K% l,
- Materials, License
. Degraded security,bar. - , , , rier providing. access? r ' e+ iSNM-1954 ' . to Fuel-. Building. y , 30ICkR:50,. ~IVI
Ch'angesmadeft'o"sNtem's! f, T86 2'8-01
J
. App L B.,... l _.
were ;not properlygre-
Criterion V~ - flected in preop tests.
, , f _. y-86L28-02', '10 CFR 50,.- V
- Test! personnel: failed.
Nm ' App. Bi.
to check prerequisites'
- 1 y.
- Criterion XI-prior to^resuminge - ' testing.
u' j86-29-01' .10.CFR 50.55(e) III .6 Late: reporting and- ' inadequate" corrective ~ ' action forTdefective - - ci rcuit: cards., T l86-31-d41 10 CFR 50, IV
Inadequate acceptance
' ' App. B! criteria to determine L Criterion V adequacy.of sway strut > paddle / bracket' clear- , ,, L . ances.
'! ' 86-32-02 BVpS-2'FSAR 'Dev.
- Preoperational test.
' p ' 14.2.12.15.1 did not determine lfk> available net-positive suction head for re-- ! circulation spray pumps.. '
,. T3-2 , ! ' ,;.
_ __ l*, " iBeaver. Valley Unit 2 t.' Inspection Severity Functional Brief Number Requirements Level.
Area Description 86-46-01-10 CFR 50, IV-1 Cable damage at a App. B, splice junction by the Criterion V-sharp edges.of a stainless steel motor.
housing base plate.
86-47-01 10.CFR 50, 'IV
Inadequate outside App. 8, .. storage of safety Criterion XIII related cable reels.
..
- 86-47-02 10 CFR 50, IV
Inadequate QC inspec-App. B, tion procedure for the-Criterion X equipment storage.
program.
87-02-02 10 CFR 50, IV
Inadequate QC inspec-- App. B, tion of HVAC equipment Criterion X supports.
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. .- . _ _ _ _ _ _ _ _ _ _ J
_,_ .. \\k\\ .. .., Beaver Valley Unit 2: ' , Lt- '9 ' 1, TABLE 4 CONSTRUCTION DEFICIENCY REPORTS ' (APRIL 1, 1986 - FEBRUARY 28, 1987)' . BEAVER VALLEY POWER STATION, UNIT 2 Cause CDR Number Deficiency . Code , I 86-00-05 Structural Failure of pipe insulation. on the Diesel. B ' Generator exhaust nozzles and insulation.
86-00-06 Failure of an ITE/Telemecanique molded case circuit E-breaker for a motor control center to reset after a trip.
'86-00-07 Diesel Generator fuel rack boost vent piping deficiency.
B.
86-00-08 '"C" reactor coolant pump damage by foreign material in A.
RCS during hydrostatic testing.
.; 86-00-09 Failure of NAMCO limit switches to activate.
E 86-00-10 - American. Warming fire dampers missing springs resulting B in a damper failure to close.
86-00-11 Priority raisa feature of steam generator steam dump B { valves.
,j 86-00-12 Commercial grade terrrinal blocks installed.instead of A
nuclear grade terminal blocks.
j ] 86-00-13 Failure of Westinghouse 7300' NLP, NSC, and NRA printed E circuit cards.
86-00-14 Corrections to Design basis flood calculations resulted A .j in identification of Class 1E components which could be j submerged.
] 86-00-15 Identification that Auxiliary Relay Racks were not B qualified to Class 1E requirements.
86-00-16 Main Steam Line Braks may produce environments greater A than E.Q. limits '86-00-17 Identification of Defective welds in the Regenerative B heat exchanger.
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L .. ' Beaver Valley' Unit 2- ' t..
Cause 'CDR Number Deficiency' Code 87-00-01: Potential accelerated thermal aging of cables-in-close .B proximity to hot piping.
87-00-02 HVAC control, circuit, logic errors.
B 87-00-03 . MSIV unlatching force deficiencies.
B-J.
87-00-04 Deficiencies in EDG HVAC fan: supports.
F , Cause Codes A - Personnel Error B - Design / Fabrication Error C - External'Cause ' D Defective Procedure E - Component-Failure F , Site Construction Error I ! 'l _ i l
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_ - ' [i>m ase ' UNITE) STATES ' .i NUCLEAR RE1ULATORY COMMISSION ENCLOSURE 4
- ~
.[ .n asGION 1 $ '! 031 PARK AVENUE MING OP PRUS$1 A. PSNNSYLVANI A 19406 ,, ....* o . Docket Nos. 50-334; 50-412 g 2 0 97 Duquesne Light Company ATTN: Mr.; J. J. Carey.
' Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen: ' Subject: Systematic Assessment of Licensee Performance (SALP) Report Nos.
50-334/65-98 and 50-412/86-99 On April 22-24, 1987, Region I SALP Boards reviewed and evaluated the activities associated with the Beaver valley Power Station, Units 1 and 2 for the period from October 1,1985 until March 15, 1987 for Unit I and for the period from April 1, 1986 until February 28, 1987 for Unit 2.
These assessments.are documented in the
enclosed SALP Board Reports.
Meetings have been scheduled for June 5, 1987,'at; ~! 10:00.a.m. and 1:00-p.m.' for Units l and 2, respectively, at NRC, Region.I, King of Prussia, Pennsylvania to discuss these assessments.
These meetings are intended .to provide forums for candid discussions relating to the performance evaluations.
Although we have' identified areas' for improvement, we find that your overall per-(' formance levels for both plants were satisfactory.
At the meetings, you should be prepared to discuss our assessments and your plans to ensure improved or con-tinued emphasis-upon those activities which would have a positive effect upon per-fomance. 'In particular, because of the NRC perception that quality assurance is not being effectively used as a management tool to enhance performance, we want to discuss with you the charter, goals and objectives, and impact of the Quality Assurance Department at Beaver Valley.
Any comments.you may have regarding the enclosed SALP Reports may be discussed.
Additionally, you may provide written comments within 30 days after the meetings.
Following our meeting; and your responses, the enclosed SALP Reports, your written responses (if deemed aecessary), and summaries of our findings and planned actions will be placed in the NRC Public Document Room.
Your cooperation is appreciated.
Sincerely, &,T.
==& William : Regional Administrator k
_.. _ _.- _ _._ _ _ _ -- -- .m -- U m 7.,. '.-, .l.\\ - i f ' d .,j @ %u %,. + ,Y , L1 "l> 4' b - - ' , - o..
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y, 7"g ~ ' ' Disquesne Light IComp'any - ' ' 1AY.:2 0 1987 " 2t 1" ,; o , , , a,. ,, , , -- I..I ' < ,, t M< M. ' Enclosures:,. . - $W L1, .NRCLRegionLI;SALP.ReportNo. 50-334/85-98; .- <2.
NRC.Regionil..SALP Report No. 50-412/86-99 ' ' .y <
' Ice;w/encisi... ' ' 1..._ , < ' jW '
- H. ' N.D Siegel,? Man' ger, ; Nuclear Engineering Department a
M > J.
LC.:E.LEwing,QA; Manager: , , .p' W.'S.
Lacey, P1 ant Manager 1 H '- ' R.":Druga; l Manager, Technical-. Servicesi.
- R.. Martin,1ManagerO Regulatory Affairs.-
- h' JJ.JCrockettgSenior Manager of Nuclear' Operafions_ ' N.'R. Tonet, Manager,, Nuclear Engineering &' Construction Unit' ,. , ~ -J.EDcSieber,-.Vice; President Nuclear; ' 0' o
- R. J.,;Swidersk1, Manager,iStartup Group m
J c P.gThomas, Hanager,- Engineering. " > ... ._ CfLO.; Richardson,L Stone' and. Webster Engineering. Corporation u Chairman:Zech- , ' ? Commissioner Roberts Commissioner Asselstine-M' ._ Commissioner;Bernthali W ' Commissioner;Carr' . 1Public Document' Room-(PDR). < Local:Public Document lRoomL(LPDR) > - . ;~ ., Nuclear Safety 1Information Center '(NSIC)' <. ' l' i NRC Resident-Inspector':
- Commonwealth of
- Pennsylvania"
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, _ _. - _ - - - - - - _ _ _ _ - _ - - - - - - - - - - - - 3- , , ENCLOSURE 5 Tf A
' M wennon,j412) 393-6000 ' YTeYl** Shippingport PA iS07N)004, June 1$, 1987 'U.
S. Nuclear Regulatory Commission Region 1 631 Park-Avenue-King of Prussia; PA 19406 ATTENTION: Mr. William Regional Administrator Reference: Beaver Valley Power: Station, Units No. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-66 Systematic Assessment of Licensee' Performance (SALP) Report Nos. 50-334/85-98 & 50-412/86-99
Dear Mr. Russell:
This letter provides Duquesne Light Company comments on the Systematic Assessment of' Licensee Performance for Beaver Valley Units
and 2 (Reports 50-334/85-98 and 50-412/86-99).
We have thoroughly reviewed both reports and carefully considered NRC comments discussed (; at the SALP meeting conducted on June 5, 1987.
In general, we _ find 'the facts presented in both reports to be accurate except for five areas-noted later in this response.
Further, we have considered the ratings and recommendations contained in the reports, and we plan to take appropriate remedial actions for those areas where further improvements are indicated.
We share the NRC's concern that our Quality Assurance Program should be more aggressive, and we plan to take additional measures to improve the usefulness of the Quality Assurance Unit as a management tool.
Notwithstanding deficiencies in the effectiveness of the Quality Assurance program, we believe that it is important to emphasize that the attitude of the workforce and supervision toward quality is good, that Unit 2 is a well constructed plant with high quality components and workmanship, and that Unit 1 is operated and maintained in such a way as to indicate our organization's dedication to quality.
Our specific comments on each of the reports are included as an attachment to this letter.
Very tru y yours, Carey . Senior Vice President Nuclear Group _ _ _ - _ _._.
- p
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- ATTACHMENT:I
... 2 ...,> > t ' g , f ?SALPxReport No. 150-334/85-98'and 50 412/86-99: , '
Beaver ^ Valley Units 1~andi2-4, , ,
- d3 e a
, L: j,i, ,< ' ,
. ,. -. . p . - f:. L The'ifollowingz'are Duquesne' Light ~. Company'sj comments. onL thei .above-captioned reports.. - , 'gy' ^ ~, i ' ' ~;c ' , ' iRadi$ logical-Controls;: Pace:l'2, firNt-paragrabh -LContrarylto;the, istatement i:in<the.; referenced paragraph,.there 3as.been;a full-time? g . ?
- person fassigned to -coordinateTand, perform activities'as'sociatedi g.
<with. thej ALARA ; program.., 5Aniadditionaleperson was assigned toy ^ALARAiduties'during!refuelingLoutages.: ' ' ' ~ , , g ,: ..., . . ' < ' .. l PWR hAving the? best) 'f
- In addition,;iBeaver- ~ Valley was.'. cited:asLthe K
M worker. : radiation Jexposuref record.'in;ithe.z countryV cin '1985.. < , 1, n , Additionally; ideclining.... exposure rates,-overall,1areLindicativel ,,, , L Hofil management,: involvement.
Aggressive. person-rem budgets werej'. ' established :fori 1985 rand.-1986. 5The budgets andEactualydose? data: are.;shown,be' low: . "BudoeE(rem) -Actu'alC(rem)j -
' > 1985 70J(non-outage)
- 60.5-13.6%
1986.
570.(outage) J627'0L +10%' ', . , .
'During;;the'.1986il outage, approximately.1000 rem'was expended 1on .[",.' . unplannedLtasks, i.e.,' l ' l - > L ' o ...
o.
100% Eddy? current"3 steam generators -'40 rem.
u t .o.
MOV-RC-591A' Valve repair -'.20 rem ^ , i . L o' Tube expansion."A" Steam Generator-- 20 rem c
o- -Increased Secondary Steam Generator.Inspecti'n'- 20-rem.
o-Extensive 'ALARA i. planning l reduced overall. total. dose 'for;the L-unplanned: tasks'. -Excluding the dose received from the unplanned ~ > . mD, tasks, the11986 actual. dose.would have been.527 rem or17.5% under budget'. a b.
' l ' j- . Radiological Controls, Page 13, first paragraph - The shipment of l. two-drums discussed'in this paragraph did not.contain radwaste as.
indicated, but. contained ' contaminated tools, 'which were being; shipped loff site.to a vendor's' facility for decontamination and return to the site for further'use.
> d 7- > Surveillance, Page 19, 4th paragraph, line 3 - The reference to " Quality Control" personnel should be changed to " Quality
Assurance" personnel.
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- . < r o ' ?Licensina, *Pages '33 and-34r We;haveLreviewedithe performancefof. a ' . . i N.
P our,zlicensing; effort during.this,SALPJreport period.-'While our j L ioverall igoals(lof?^ operating. Unit -1; safely and-reliably andlthe i completions and:3startup of< Unit'2' p' , l key &_licensingiipersonnel, we'beli. required the! reassignment;ofitwo . eve.'that our performance!intthis ? area:<was!Lconsistent with performance"during prior / SALP periods? ' tour ! records'jindicate ~ that: - there. : was : increased ? activityJin - the , licensing,rareaf ?as!' indicated *by.. the.increaseTin-the number of-J ~Technica1L: Specification: amendments prepared: and;. submitted.and- ' .' , " ' . ? substantial.6 progress.in ~the closeout-of.IL'and>E open11tems..,We[ ' ,
'furtherj :believe.. that work on. the : Unit f2I draft ~ technical' specifications *iand'tthe review : associated sith; theocoritro1L room; " L wall"" removal:Lrequired' the expenditure of: substantia 1Eadditional
Li -
- time',and; effort lon the part -of UnitLl1 licensing personnel, D
" Fo providing: antadditional. burden onsthe limited resources availableL <
. at that time.
'We 'believe;thAt the Technica1' Specification.' review' activities for D . Unit' 2 causedf:an' increase in : work load and-:a diversion of.
resources. :.which taxed our abilityfto resolve'the many unique'and: ~ ' complexf' issues-which arose. during~ this' period.L' We further g believe1 :that~the^ technical content.of'our submittals'have been:of high quality;.even though a few submittals have been moreTtimelyn
We further believe that as Unit 2 receives its full power. license L. ; (_~ and"Flicensing,' activities' for.both units are. consolidated.under _ ' one.slicensing Organization,. that-sufficient resources will be' ~ n? available. Lto; ; conduct' licensing activities?Lproperly in' the ..' future.
.Therefore, it'is'our opinion.that.the " Declining"' rating is. not,. warranted.- We will, however. monitor this program to >
r , assureLthat: performance improvesFin this area.
3, , Trainino and Qualification Effectiveness, Pace 36, Recommendation Duquesne Light Company will review the content-and quality of - . ourt operator; candidate screening' process,'our pre-license audit examinations?'and NRC licensing and'requalification examinations-to 'determinef if appropriate -and consistent standards are applied'- throughout the operator training program.
Assurance of Quality - References to quality assurance are made in several sections of both SALP reports; however, the comments are-. summarized in the cover letter ~ by 'the statement that, .... quality assurance is not being effectively used as a " - management. tool to enhance performance.
As discussed at the " .. SALPc meeting, Quality Assurance is actively involved in many < areas Lof. toth Beaver Valley units.
Some of the areas in which Quality Assurance has been involved are listed on Attachment II
- to this letter.
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NO ATTACHMENT I .Page 3 3j- , Assurance of Quality (continued) 'Irt order-to more effectively utilize'Quslity Assurance, Duquesne ~" Light is proposing three. additional action _ plans which will be implemented to improve this area:' e 1.
'JO full-time QA surveillance. program has been developed;and implemented.(effective 5/1/87) for BV-1.
The present QA >. surveillance. program for BV-2 will be continued into the operating phase.
,f.' 2.
'A reviewi of programs, in addition to the 10CFR50' Appendix B -
quality assurance program,.has been initiated to determine where' improvements can be made and what additional programs can be implemented to improve, plant reliability.
The results-of this' review will be submitted to management for their review and-approval by August 31, 1987, 3.
A. Management. Quality Review Program,. similar to'the BV-2 ' Quality Improvement Management program will be initiated, which will review. quality performance-indicators,' assess .causes .for adverse performance trends and institute appropriate' corrective action.for performance improvement.
'This program will be implemented by November 30, 1987.
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, .. ATTACHMENT II Special Projects, Audits or Investigations
.E L 1 - 1.
PerformedL independent; Devaluation'of. reactor trips on Beaver Valley Unit No. l' , L2.
Study of accessibility of' plant' areas duriny emergencies.
3.
Conducted ' investigation into "C". Reactor Coolant. Pump cover problem for Beaver Valley Unit No.12.
, 4.
Provided. independent' observers for EPP drills.
5.
Provided member for Appendix R Task Force.. 6.
Conducted. 100% surveillance-of Beaver Valley ~ Unit No. 1 split pin replacement.
7.
Presently. performing; a review of Beaver Valley Unit;No. 2.
l- . Technical. Specification-surveillance.
L 8.
Coordinated Beaver Valley. Unit No.1 2 investigation of Joseph Oats Regenerative HX problem.
9.
Evaluated records storage facility compliance to N45.2.9 . requirements.
L ( 10.
Participated in Radwaste Packaging and Shipping Task' Force.. 11.
Coordination of Cooperative Management Audit Program.
12.
Review inspection, surveillance and audit. aspects of IE Notice 85-19.
13.
Investigate:cause of damage to MSIV.
14.
Records Task Force.
15.
Audit of ECORAM activities BV-2 SG Eddy Current Test of rerolled tubes and sample of shot peened tubes.
16.
Audit of Detroit Edison for procurement of electrical cable.
17.
Audit of personnel background checks at solid Waste Management Services.
- 18. Audit Power Piping (Donora) for weld filler metal control (S&W did not have a TL available).
19.
' Quality Concern (hotline) DCP documentation review.
I 20.
Audit of QCR Program, i k 21.
ORRT - DSB co-member.
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, fATTACHMENT II' , , 4( @ ;26 t L- ' .g 7,3.: Page.2L .* ,
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' 2 2. '. A tid i ti o f L D C P $ 7 6 6 s :- Control Room' Wall'. Removal.
A+ . .23.
- Q A '. M a n u a l ~'.' r e v i e w c-' o f 4 ' Buffalo Forge- -for: NERU..toijustify: ' ' ,, waiving' requirement for' approval'ofi:the manual as specified-in: procurement? document.. ( Copy ' of;. S&W Spec. ).- N 24.; Quality" Concern Response'- Uniti#1' Battery' Room.
. ! 2 5.- . Chlorine 1 Detector --documentation problem.
, j 26.
Develop-QA '"NRC ' Assessment of Quality - BV-2":forlthe'NRC-, ' - ,
- Operating License.
O ' /27..' control'.' Room: Design review audits -' 1984, 1985
- 28.-- Review and assessment of RIs and' their usei-E1983..
. < 29.,' Assessment of'Victoreen Instrument Company - 1983.: - 4' ) - - 30. : Random Sampling Program MonitoringLand' Auditing.
C - 31.. Audit-of.. Security Prior'to BV-2 Lockdown.
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- - - --- m, - , , , r , 'l &4 . ' 'f y ] ,.. o , .< - jj ' -ENCLOSURE 6' < < , , Beaver Valley Unit 1 ' L .SALP Board Report Errata: Sheet ., .. i , H PAGE' 'LINE NOW READS SHOULD READ-6' .. '33 Declining-(Deleted)- ' and' .
'31
. Basis: -No definite trend'of' performance discernable ~to the Board which would - indicate a change in performance' level (category).
.11' Unforeseen...be performed.
See'following- , Should. Read: Unanticipated'.high exposure workbeyond;.the -ini,tial work scope "' resulting. from. problems identified during in-service! inspection was. performed.
This Lovera11. performance was close.to the . ~" industry average.
Concerns in this area included a perceived 1 y- , need. for more. aggressive oversight and coordination of and emphasis on ALARA activities.
For. example,-low, attendance was ' ' noted ' at. ' the NuclearL Group' ALARA Review Committee meeti.ng s. : ... (Thi.s ' committee has the responsibility to review th.e status of '
program implementation.)
Basis: Board re-evaluation of ALARA program considering additional-
L information provided by licensee.'
'22 Radwaste Licensed radioactive material designated as
low specific activity.
Basis: More correctly defines material addressed.
38 Control Assurance Basis: More correctly defines function.
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