IR 05000412/1986028

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Insp Rept 50-412/86-28 on 860930-1003.Violations Noted:Sys Changes Not Properly Reflected in Preoperational Tests & Failure to Assure That All Sys Prerequisites Satisfied Prior to Performance of Testing
ML20214D414
Person / Time
Site: Beaver Valley
Issue date: 11/06/1986
From: Briggs L, Joe Golla, Van Kessel H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214C670 List:
References
50-412-86-28, NUDOCS 8611240073
Download: ML20214D414 (9)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-412/86-28 Docket No.

50-412 License No. CPPR-105 Category B

Licensee:

Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name:

Beaver Valley Power Station, Unit No. 2 Inspection At:

Shippingport, PA Inspection Conducted:

September 30 - October 3, 1986 Inspectors:

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H. F va e sel Reactor Engineer idt Chll h(A ll l3

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J. A.

11, eat r Edgineer kla e'

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Approved by:

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L. E. Briggs, Chief paye

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Test Program Section, 08, DRS Inspection Summary:

Inspection on September 30 - October 3, 1986 (Inspection Report No. 50-412/86-28)

Areas Inspected:

Routine unannounced inspection by two regional based in-spectors of the Preoperational Test Program, including the review of Joint Test Group (JTG) approved procedures for preoperational testing, the test witnessing c? preoperational test P0.2.07.03, "CVCS" and phase-1 test 2 MSP-6.42-I,

'Tressurizer Level Loop 2 RCS-L460, Protection Channel II Calibration", the review of activities in the QA interface, and the review of unresolved items identified by the inspector in previaus inspections. The status of phase-1 tests for the Main Steam Isolation Valves was reviewed.

Results:

Two violations were identified for system changes not properly re-flected in preopetational tests (Section 2) and failure to assure that all system prerequisites are satisfied prior to performance of testing (Section 3.2).

Note:

For acronyms not defined refer to NUREG 0544, " Handbook of Acronyms and Initialisms.

8611240073 861117 PDR ADOCK 05000412 G

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DETAILS 1.

Persons Contacted Duquesne Light Company (DLC)

D. J. Coller, Assistant Shift Supervisor

  • N. Daugherty, Director Systems Testing
  • J. P. Godleski, Senior Test Engineer
  • J. D. Johns, Supervisor QA Surveillance A. Klutka, Training Supervisor L. Kubas, System Test Engineer
  • T. P. Noonan, Superintendent Operations and Maintenance

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  • M. Pavlick, Director Support Services
  • L. M. Rabenau, Compliance Engineer R. J. Swiderski, Startup Manager
  • S. P. Verma, Assistant Director, Startup Proof Test L. P. Williams, Director Startup phase-1
  • R. G. Williams, Supervisor Software Development

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U.S. Nuclear Regulatory Commission

  • A. A. Asars, Resident Inspector J. E. Beall, Senior Resident Inspector L. Briggs, Chief, Test Programs Section, Division of Reactor Safety
  • Denotes those present at exit interview on October 3, 1986.

2.0 Licensee Actions on Previous Inspection Findings (Closed) Unresolved Item (412/86-22-02), " Trouble Shooting problems caused by system change to Boric Acid System."

Scope Initial trouble shooting conducted to resolve test deficiency No. 16 of the Boric Acid System Test (PO.2.07.02) was ineffective because a system change had been made shortly before the test; but, SVG personnel were not aware of this change and its impact on the logic diagrams.

In the previous inspection 50-412/86-25 the inspector determined the following:

An E&DCR (D-0117-B02) had been prepared by Stone and Webster in August to accomplish the wiring change introduced by Westinghouse via a Field Change Notice (FCN).

The wiring change had been executed prior to the test (and turnover of the system) in accordance with E&DCR D-0117-B02.

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  • The official system drawings including the logic diagrams had not been revised at the time of the test to reflect the wiring changes.

Since these drawings were used by the test engineer during the test fcr trouble shooting he checked the wrong relays in the wrong cabinet.

As a result of the trouble shooting efforts during the test, it was discovered that the system modification did not meet the intent of the designer. The existing E&DCR D-0117-802 was revised to satisfy the design intent via E&DCR-D-0117-S01.

WAR-5824 was issued to accomplish the correction.

The inspector was also concerned on the awareness of test and operating personnel of the existing document / drawing control system as it applies to drawing changes for system hardware changes.

References

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Startup Manual, Chapter 6.1.1, rev. 2, page 3, VI.C 2.

Field Construction Procedure, FCP-30, Change No.15, dated May 12, 1986," Jobsite Document Control, Beaver Valley Power Station-2,"

Stone and Webster Engineering Corporation.

3.

Startup Manual, Chapter 6.2.1, " Certification of SVG Personnel,"

rev. 2, dated 8-13-86, including attachment 6.2.1-2, example of SVG Personnel Indoctrination Reading Checklist.

4.

Startup Manual, Chapter 3.4.7," Training of Operations Personnel,"

rev. 2, dated 4-16-86, including attachment 3.4.7-1," Required Reading / Training Sheet" and 3.4.7-2, " Additional Reading Requirements."

5.

Duquesne Light Company Memorandum from M. Pavlick to All SVG Personnel, "BVPS-2 Design Outputs Affected by E&DCRs."

Discussion A visit was paid to the control room to inspect the existing drawing stick files and drawing control documentation for system hardware changes. The drawing stick files were found to have controlled copies

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of logic diagrams and elementaries. These stick file drawings, however, did not indicate impending drawing changes from Engineering and Design Change Requests (E&DCRs).

It was suspected that this E&DCR information would be filed elsewhere in the control room. The Assistant Shift Super-visor on duty was asked where this drawing control information was.

He was not aware that this information was available in the control room and indicated that he did not know how the document / drawing control system was i

supposed to work.

Inquiries of three operators also failed to identify l

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and locate E&DCR files. The inspector then contacted the document control center in the South Office Building.

The document control center person-nel explained how the system was supposed to work. A computerized track-ing document has been created to track the E&DCRs outstanding against any drawing affected by the associated hardware changes. Copies of these tracking documents, providing information on what E&DCRs are outstanding against any given drawing, are distributed weekly to all user stations including the control room.

The new E&DCRs are also distributed to these same user stations. With this information in hand, the inspector again contacted the Assistant Shift Supervisor, who jointly were able to locate the E&DCR files.

It was concluded that there exists a drawing control system for system hardware changes but that it is not always used in the control room by either testing or operating personnel.

A check was made of the Startup Manual training requirements for the document control system for both testing and operating personnel.

It was noted that the reading checklist for operating personnel (ref. 4) was extensive and included SUM chapter 6.1.1 (ref. 1) which contains reference

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to FCP-30 (ref.2), the " Job Site Document Control" procedure. Nonethe-less, the operators failed to recognize this when questioned as described above.

It was also noted that this reading requirement only applied to

" Technical Support Personnel" and not Supervisory personnel. The Quali-fication file of the Assistant Shift Supervisor on duty confirmed that SUM Chapter 6.1.1 was not required reading, which supports his lack of knowledge of this area. The reading checklist for SVG personnel (ref.3)

is determined by the Test Director. There are only very general instruc-tions in ref. 3. which is not the case in ref. 4.

Findings 10 CFR 50 Appendix B, Criterion VI requires in part that " Instructions, procedures and drawings, including changes thereto affecting quality are reviewed for adequacy and are distributed and used at the location where the prescribed activity is performed."

Contrary to the above, initially as identified on August 22, 1986, in inspection report 50-412/86-22 (August 18-22,1986) during performance of preoperational test P0-2.07.02, " Boric Acid System Test," changes made to the system in E&DCR D-0117-802 were not reflected in the preoperational test. This is a violation (412/86-28-01) Unresolved item (412/86-22-02)

is considered closed. A contributing factor to this violation is an ap-parent weaknesses in knowledge of the document control system by test and operations personnel including supervisors.

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3.0 Preoperational Test (POT) Program 3.1 Test Procedure Review Scope Test procedure PO-2.44A.01," Control Building HVAC System Test,"

approved by the Joint Test Group (JTG) on July 3, 1986, was reviewed for administrative and, selectively, for technical adequacy and to verify that test planning satisfies regulatory guidance and licensee commitments.

Discussion The test procedure was examined for the attributes listed in

Inspection Report 50-412/86-11.

The test objectives and test methods for this test were compared to the commitments made in the FSAR (paragraph 14.2.12.62.1). The comparison yielded acceptable results.

Finding No unacceptable conditions were noted in this procedure.

3.2 Test Witnessing 3.2.1 Preoperational Test Procedure (phase-2)

Scope

Selected steps of procedure PO-2.07.03, "CVCS" were witnessed. Test witnessing included observations of the attributes listed in Section 3.2 of Inspection Report 50-412/86-20.

Discussion

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The plant computer malfunctioned several times during the test.

The inspector noted that valve 137 could not be stroked

initially because circuit breaker No. 8 on panel VITBS2-38 was left open rendering the valve inoperable. This breaker was left open because of some work performed earlier.

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Circuit breaker status was not checked prior to the test

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nor was it required by the procedure.

It was also noted that the corrective action had not been filled in on the test deficiency (TD) report from the

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failed test of valve No. 137 prior to retest.

The test engineer, however, had verbal confirmation that the main-tenance work on the valve had been completed and that a retest could be performed without any problem.

The test deficiency form was completed later after completion of the retest.

A retest was done on valve No. 4608. This test involved stroking of the valve from the Alternate Shutdown Panel (ASP). When this test was started, it was discovered that the ASP was not energized.

Findings 10 CFR 50 Appendix B, Criterion XI requires in part that

" test procedores shall include provisions for assuring that all prerequisites have been met."

Contrary to the above the licensee test procedures did not assure that prerequisites were satisfied for testing of CVCS valves 137 and 4608.

This is a violation (412/86-28-02).

3.2.2 Phase-1 Test Witnessing Scope The inspector witnessed the initial loop calibration of the RCS Pressurizer Level instruments.

1.

Duquesne Light Company Maintenance Surveillance Procedure, 2MSP-6.42-I, rev. 1, " Pressurizer Level Loop 2 RCS-L460 Protection Channel II Calibration, approved by PRC on 10-1-86.

1 2.

Test Loop Diagram, " Reactor Coolant System Pressurizer Level Protection, Set II," S&W dwg. No.

!06-105, approved 12-28-85.

3.

Supplement to 2 MSP-6.42-1, " Initial Instrument

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Testing," rev. O, approved 10-2-86.

l Discussion

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The procedure package (ref. 1, 2, and 3) was reviewed for i

administrative adequacy.

The test engineers followed the instructions contained in the referenced procedures.

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problems were encountered,

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Findings No violations or deviations were observed.

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4.0 Independent Inspection Effort Scope The inspector continued to collect information on repair problems of the Main Steam Isolation Valves (MSIVs) and their root causes.

References 1.

Main Steam Isolation Valve Problem Summary Document, prepared by DLC and handed to inspector during inspection 50-412/86-28.

Discussion The reference document provides an overview of the generic MSIV problems

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experienced to date. Although these ball valves were purchased by five Nuclear plants, four domestic and one overseas, only Beaver Valley (BVPS)

2, and one other Region I facility have continued with the valve applica-tion. According to a DLC spokesman, the other facility had the lead in the repair program for these valves. DLC is following the vendor efforts (Crosby) to resolve the repair problems encountered during the valve test-ing at the other nuclear facility.

Since BVPS-2 has not done any phase-1 testing on their MSIVs at this time, none of the problems experienced at the other facility have manifested themselves on the BVPS-2 MSIVs.

DLC plans to incorporate valve modifications tested in the lead facility's MSIVs. MSIV operation should not affect the start of the HFT.

Longer term repairs based on the fixes defined for the lead facility's valves are scheduled for completion by mid March 1987 according to reference 1.

Findings No violations were identified.

5.0 QA/QC Interface Scope The participation of the Duquesne Light QA Surveillance Group in the preoperational test program was evaluated by the inspector.

Samples of j

the surveillances performed on the most recently performed preoperational tests, including phase 1 and phase 2 tests, were obtained for review and l

l are identified in Attachment A.

Discussion Of the surveillances reviewed, there was only one Surveillance Deficiency

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i Report, i.e., for OPS-07-86 (SDR#1).

l The deficiency of SDR No. I consists of the lack of a verification sig-l nature, time and date on the cover sheet of the " Working Copy" of

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Temporary Operating Procedure TOP-368-30B that the working copy was veri-fied against a controlled copy prior to use to verify the validity of the procedure. This constitutes a deviation from the Startup Manual (SUM)

requirements as shown in section VI.H of SUM 3.4.4.

It is also a repeat of the finding in QA surveillance OPS-03-86, which was responded to by Startup Management in BVPS; RJS 12241: 3608, dated June 19, 1986. This letter committed to the refamiliarization of the Operations personnel to the SUM.

Findings While 10 CFR 50 Appendix B, Criterion XVI requires that corrective act'lon preclude recurrence, the licensee corrective action to the QA Surveillance OPS-03-86 finding was not totally effective to prevent reoccurrence.

Since this was a licensee identified reoccurrence, no additional regula-tory action will be taken at this time. However, the inspector will fol-low the additional licensee corrective actions to determine the adequacy.

6.0 Exit Interview At the conclusion of the site inspection, on October 3, 1986, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1). The findings were identified and previous inspection items were discussed.

At no time during this inspection was written material provided to the licensee by the inspector.

Based on the NRC Region I review of this report and discussions held with licensee representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction r-~

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ATTACHMENT A to 50-412/86-28 REVIEW OF QA SURVEILLANCE REPORTS SURV. NO.

DESCRIPTION ACTIVITY TEST PROC. NO.

DATE REVIEWED OPS-07-86 Test Witnessing EDG-A TOP-368-30B 9-29-86 Exercising Run.

(SDR-1*)

CPT-39-86 Service Water System 2T-SWS-30-1.15 9-09-86 Flush - Witnessing

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(No deficiencies)

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CPT-40-86 Witnessing phase-1 2T-HVK-44F-2.15 9-29-86 test for Service Bldg.

"B" Train Battery Room Exhaust Fan (no deficiencies)

SOV-35-86 Witnessing phase-2 50V-33C.02 9-29-86

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test for Wet Pipe (Section Z, AA)

and Deluge System,

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Section Z, AA. (no deficiencies)

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  • Surveillance Deficiency Report - SOR

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