IR 05000412/1987015

Insp Rept 50-412/87-15 on 870223-27.No Violations Noted. Major Areas Inspected:Document Control,Records Mgt & Util Actions on Previous Insp Findings

ML20206C513
Person / Time
Site:	Beaver Valley
Issue date:	03/25/1987
From:	Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206C496	List: IR 05000412/1987015 ML20206C492
References
50-412-87-15, NUDOCS 8704130074
Download: ML20206C513 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-412/87-15 Docket N License No. CPPR-105 Licensee: Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Station Unit 2

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Inspection At: Shippingport, Pennsylvania

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Inspection Cond ed: February 23-27, 1987 Inspectors: / 3 2 O. Q M. Dev, Reactor Engineer date Approved by: - //k1/ E k Dr. P. K. Eapen, Chief, Quality Assurance ~ date Section, 08, DRS Inspection Summary: Routine, Unannounced Inspection on February 23-27, 1987 (Inspection Report No. 50-412/87-15)

Areas Inspected: Document Control, Records Management Programs, and licensee's actions on previous inspection finding Results: No violations were identifie {DR ADOCK 05000412 PDR

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DETAILS 1.0 Persons Contacted Duquesne Light Company (DLC) Beaver Valley Power Station Unit 2 (BV-2)

• T. Anderson, Record Management Supervisor

• D. Claridge, Compliance Engineer

• A. Cooper, Senior Procurement Engineer

• N. Daugherty, Director, System Testing C. Davis, Director, QA Eng. & Procurement

• R. Dodson, Record Management Administrator T. Doyle, Sr., Mechanical Procurement Engineer C. Earnest, Supervisor, QC Administration

• S. Fenner, Director, Quality Control J. Forney, I&C Engineer

• J. Godleski, Senior Test Engineer C. Haney, Director, T&C Training

• D. Hunkele, Director, QA Operations

• D. Hunter, Manager, Engineering Information Services

• J. Johns, Supervisor, QA Surveillance J. Kausnick, Maintenance Director, SVG A. Lerczack, Procedures Supervisor

• K. Lowrie, Procurement Supervisor (BV-1)

P. Mariuzza, Maintenance Proc. Engineer

• T. McGhee, OSC Chairman J. Miller, Senior QA Specialist

• R. Miller, Director, Record Management Transition

• A. Moody, Document Control Supervisor A. Morabito, Manager, Nuclear Training

• Pergar, QC Supervisor

• L. Rabenau, Lead Compliance Engineer R. Rath, Associate Licensing Engineer M. Rencheck, Supervisor, Maintenance Information Management

• C. Schultz, PRC Chairman J. Summers, Manager, Planning & Outage Management

• J. Tack, Record Management Supervisor, SVG

• J. Venzon, Proc. Supervisor

• G. Wargo, Assistant Director, SQC R. Williams, System Test Software Development Supervisor Stone & Webster Engineering Corporation (SWEC)

• G. Byrnes, Assistant Project Manager

• D. Lamson, Assistant Resident Engineer

• R. Wittschen, Licensing Engineer

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U.S. NRC

• A. Asars, Resident Inspector

• J. Beall, Senior Resident Inspector

• Denotes those attending exit meeting on February 27, 1987.

The inspector also contacted other administrative and technical personnel during the course of this inspectio . 2.0 Followup of Previously Identified NRC Concerns (Closed) Violation 85-21-01: The QC inspector's failure to identify non-conforming conditions in heating, ventilation and air conditioning (HVAC) system supports. In a previous inspection, the NRC inspectors identified nonconfonning dimensional tolerances in HVAC supports previously accepted by QC. The licensee initiated nonconformance and deficiency (N&D) report 32136 to resolve the dimensional deficiencies identified by the NRC inspector. The N&D was subsequently dispositioned and the system was accepted "as is".

The licensee determined that the QC inspector's failure to identify dimensional nonconformance was attributable to the lack of communication between the QC inspector and his lead inspector. The NRC inspector verified that the licensee did institute disciplinary actions including suspension of one individual, reassignment of another and the demotion of a third individual. The QC supervision for the HVAC activities was also restructured. The licensee also conducted an independent review of the earlier assignments of the QC inspector and found them to be satisfactor The licensee held several meetings and re-emphasized the need for better communication between the supervision and QC inspectors to identify nonconformances expeditiously. The NRC inspector also verified the appropriateness of training, indoctrination and certification of the individuals who conduct quality control activities for HVAC syste Based on the above review, the NRC inspector concluded that the licensee actions were adequate to resolve the concern identified in this violatio This violation is close .0 Records Management program The basic requirements and guidelines for collection, storage and maintenance of Quality Assurance records are described in:

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10 CFR 50, Appendix B, Criteria XVI Final Safety Analysis Report (FSAR), Section 17.2.1 . - ... . _ _ _

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ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plant Regulatory Guide 1.88, Rev. 2, Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Record ANSI 18.7-1976, Administrative Controls and Quality Assurance for the Operational. Phase of Nuclear Power Plant ANSI N45.2-1977, Quality Assurance Program Requirement .1 Program Review The requirements and guidelines found in the reference documents of paragraph 3.0 are implemented by the licensee's Quality Assurance Program by utilizing Site Administrative procedures, Quality Assurance procedures, and Document Control procedure The inspector reviewed the licensee's records management procedures (listed in Attachment 1) to verify compliance with the requirements and guidelines of the above referenced documents and to assure that the licensee's procedures adequately established the following:

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Requirements to maintain and retain records required by the licensee's quality assurance program;

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Responsibilities to identify and maintain QA records;

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Responsibilities to transfer and retain construction and preoperational phase records;

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Maintenance, retrieval, collection and disposition of records;

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Access control to stored records;

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Identification of record storage facilities;

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Designation of custodians;

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Verification of receipt of all transmitted records;

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Authorities and responsibilities are specified for authorizing the disposal of records no longer required to be maintaine .2 Program Implementation and Findings This inspection was conducted to assess the adequacy and effective-ness of the licensee's records management program relative to pre-operational readiness of Unit 2. The licensee is currently estab-11shing a centralized BVPS records management program to ensure that

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records generated during the design, procurement, construction, test, ifcensing and operation of Unit 2 are identified, received, indexed, stored, archived and retrieved in accordance with applicable pro-cedures. A nuclear group directive for BVPS records management program is currently in the management review cycle. According to this directive the General Manager, Nuclear Engineering and Records Unit has authority and overall responsibility for the program. The Manager, Engineering Information Services Department assists the General Manager in defining, developing and administering the records management progra The inspector reviewed with the licensee's records management personnel the scope of the records management program tasks which are being implemented to process, retrieve and maintain all SWEC generated Unit 2 construction and engineering records. The task identifies incorporation of a Project Record Type List.(PRTL) for BVPS-2 engineering, design and construction records. It also provides for DLC/SWEC computer based data conversion interface and required personnel training. The licensee's records management project milestone indicated that the transition of records control from SWEC to DLC will be accomplished by the end of 198 Also the licensee is updating the site Administrative Procedure Chapter 7 which establishes the organization, responsibilities, administrative controls and quality assurance requirements for the records management program. This procedure will be applicable to the Unit 2 safety-related (Category I and Category F) functions during the operation phase. The procedure provides for the distribution and control of documents including procurement, quality assurance records, engineering records, and other security and special nuclear material related record The inspector reviewed the following startup test reports, on a random basi Preop Test N Description P0-2.06.06 PRT & PORV P0-2.06.07 Pressurizer Pressure and Level P0-2.07.03 CVCS Test P0-2.10.01 RHR System Test PO-2.11A.03 SI Flow Test P0-2.13.03 Quench & Air Recirc Test P0-2.20.01 Fuel Pool Cooling System Test P0-2.21A.01 Atmospheric Steam Dump Valves Test P0-2.248.01 Aux Feedwater Piping System Test P0-2.30.01 Service Water System Test PO-2.39.01 Battery Chargers /Enverters

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These records were well organized and contained completed test data sheets, test logs, test deficiency reports and resolution, as applicable; l also included were pertinent sections of the completed test procedure, including general test methods, special test equipment, test prerequisi-ties, initial conditions, precautions, acceptance criteria and reference The status of the licensee's preoperational test program was easily i , verifiable by the licensee's computerized tracking system. The completed test reports are transmitted to the document control facility under the cognizance of SWEC record management progra The licensee's Operating Manual, Chapter 54, establishes requirements for the Station Logs to be maintained during the normal power operation of the Unit 2. The log sheets are kept in the permanent station files. The forms are divided into sixteen different groups including general summary reports of the major station activities, summary reports of various station groups, operating logs, daily heat balance, and the containment local leak rate test records. An incoming shift staff member assumes duty only after making himself fully aware of the information necessary to perform his duties. He signs to that effect on the previous shift lo '

The relieved staff also signs the log to indicate that the data contained in the appropriate operating logs are accurate, and that he had been properly relieve The inspector also verified that the control room has maintained a list of chart recorders which provided information regarding equipment vendor, model, type, order number and stock number for ready referenc The licensee has established a procedure to conduct design changes and modifications, and other changes affecting facility FSAR and Technical Specifications. A cognizant engineer is assigned with the responsibil-ities to prepare documentation for approval, and update the records. The inspector reviewed the licensee's records for FSAR related changes. The records identified the related change notices, originating entity, review comments, resolution, approval, and references to safety evaluation, as applicabl The licensee's procedure for Material Management, Section 21.0, delineates the requirements for Accumulation, Distribution and Retention of QA Records for Material. The procedure identifies QA records required for stock materials as well as non-stock materials. The documentation includes records of purchase orders, purchase requisitions, procurement quality documentation, receipt inspection reports, material checklist, material transfer forms including SWEC initiated purchase orders, Westinghouse unpriced purchase orders, Westinghouse quality release report, reclaimed material reports, and other procurement related record At the time of this inspection, procurement of spare parts is accomplished through the licensee agent, SWEC. The inspector reviewed one such procurement record and verified that the stock item report was reviewed by a cognizant engineer and QA/QC personne _ _ _ _ .

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The records also included the special quality documentation paragraph for 10 CFR 21 requirements, technical specification requirements and other vendor informatio The licensee's training organization is responsible for providing training and indoctrination to the plant personnel including operators, chemists, technicians, craftsmen and others performing quality control activities at Unit The training department maintains and updates the training records of the participants. In addition, eacF department carries on its own department procedural 1 training progum including on-the-job training, and maintains training records of its member The inspector reviewed the training records of three QC inspector The records provided information regarding their qualification, experience and certification for the level of their competenc l The inspector reviewed audit reports DLCQA-6120, 6256 and 6408 for l documentation adequacy. These audit records and related documenta-tion were well organized and comprehensiv The licensee has established Administrative Procedure, Chapter 16, to set forth the organization, responsibilities and functions of the Technical Advisory Group (TAG). The TAG initiates, reviews and evaluates facility Incident Reports (irs) and Licensee Event Reports (LERs) in accordance with the TAG procedures. The licensee also maintains an IR/LER trending program to ensure that appropriate corrective action has been taken for each incident. The licensee is in the process of extending the scope of this program to Unit 2 operation Site Administrative Procedure, Chapter 32, defines the data collec-tion, reporting interfaces, methods, timeliness and implementation of the Nuclear Plant Reliability Data Systems (NPRDS) for Unit Accordingly, a cognizant individual who performs the scoping of NPRDS reports completes the NPRDS portion of the maintenance work requests (MWRs) and failure report forms and provides NPRDS related component information to INPO. .The licensee's Nuclear Engineering and Records Unit reports and maintains records of all NPRDS engineering data to INPO for reportable systems and components. The Planning and Outage Management Department reports and maintains records of all NPRDS engineering data to INP Discussion with the Nuclear Engineering and Records Unit, and the Planning and Outage Management personnel indicated that the licensee would extend NPRDS data collection and reporting to Unit No violations were identifie The effectiveness of the licensee's Records Management Program implementation will continue to be reviewed in future NRC inspection . .

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4.0 Document Control Program The basic guidelines and requirements of the licensee's document control program are contained in:

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10 CFR 50, Appendix B, Criteria II, V, VI

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Final Safety Analysis Report (FSAR) 17. ANSI N45.2 - 1977, Quality Assurance Program Requirements

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ANSI N18.7 - 1976, Administrative Controls and Operational Quality Assurance for the Operational Phase of Nuclear Power Plants ,

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Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Requirements (Operation)

4.1 Program Review The requirements and guidelines established in the reference docu-ments in paragraph 4.0 are implemented by the licensee's Quality Assurance Program by utilizing Quality Assurance Procedures, Site Administrative Procedures and Stone & Webster Engineering Corporation Jobsite Document Control Procedure The inspector reviewed the licensee's document control procedures (listed in Attachment 1) to verify that the program is consistent with the requirements and guidelines of the referenced documents in paragraph 4.0 and to assure that the program contains the following attributes:

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Require that current as-built drawings, including piping and instrument drawings (P&ID's), will be provided to the plant site in a timely manner; l

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Require that proposed drawing changes and the revised drawings receive the same level of management review as originals;

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Provide provisions for identifying and marking drawings with outstanding revisions;

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Establish control of obsolete drawings;

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Require that discrepancies found between as-built drawings and the as constructed facility are handled as design changes;

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Require master indices to be maintained for drawings, manuals, l technical specifications and, procedures that indicate the

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Provide a mechanism for document issuance, distribution, use l and periodic review.

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4.2 Program Implementation and Findings This inspection was conducted to assess the adequacy and effective-ness of the licensee's document control program for Unit 2 preopera-tional readiness. As indicated in the previous section (3.2), the DLC Letter of Promulgation has established the basis to implement the Unit 1 Operations Quality Assurance Program to Unit 2 preoperation testing phase. Accordingly, the licensee is in the process of up-dating all Station Administrative Procedures, Departmental Proce-dures, Instructions and Directives to incorporate Unit 2 operatio Currently, the document control activities at Unit 2 are implemented through SWEC Field Construction Procedure FCP-30, "Jobsite Document Control". The licensee has developed a Nuclear Group Directive to identify the responsibilities and requirements for the establishment and administration of a centralized BVPS Document Control Progra The program ensures that controlled documents and changes'thereto are received and approved by authorized personnel and distributed to and used at locations where work activities are performe It also pro-vides means to identify and control changes to the Baseline Config-uration as defined on the control documents. The General Manager, Nuclear Engineering and Records Unit has authority and responsibility for the BVPS Document Control Program as established by this direc-tive. The Nuclear Group General Managers are responsible for identifying the approved Unit 2 Baseline Configuration Documents, and provide documentation for all changes to the Baseline Configuratio The Nuclear Group Directive for the BVPS Document Control Program is currently in the management review cycle. The licensee's document control program defines and controls the identification of Unit 2 structures, systems and components, establishes review and approval requirements and responsibilities to control distribution, identifies the implementing procedures and instructions; and provides for disposition of superseded documents. The effectiveness of the licensee's document control program implementation will be reviewed in a future NRC inspectio The inspector randomly selected the following vendor documents and as-built drawings and verified that the copies available in the control room, licensee satellite document control center, and engineering group agreed with the master lis .330-694-011, Technical Manual for Model 288A & 290A DP Indicating Switch ITT Barton, Rev A 2507.650-209-035, OP/Maint. Manual OMM 2357, Part No. 86010 & 86010-1 Electrohydraulic Operators, Copes-Valcan, Rev D 2509.290-423-004, Radiation Shielding Door, Mosler, Rev D

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12241-RE-1BE-2, SH 6,125 VDC One Line Diagram (E&DCR D-5085-S01)

10080-RE-1AM-10, SH 5, 120 VAC One Line Diagram (E&DCR D-0273-801 and2PA-12168)

10080-RM-44A-38, Auxiliary Building Access Aisles 10080-RM-34A-6D, Units 1 & 2 Cross Tie Piping Schedule The inspector also toured the licensee's Site Engineering Group Document Control Center and observed the verification and disposition of obsolete and recalled drawings. The status of certain selected E&DCRs were also verified and the documentation agreed with the controlled engineering drawings, and the master list. These documents were easily retrievable. The inspector also observed that the licensee's document control facility was staffed with experienced and trained personnel. They are working in conjunction with SWEC personnel to facilitate an efficient and effective records transfer operation from SWEC to DL No violations were identified. However, the inspector noted that some of the Station Administrative Procedures have not yet been updated to reflect the incorporation of Unit 2 in the program. The effectiveness of the licensee's action will be followed up by the inspector (50-412/87-15-01).

5.0 Exit Interview An exit meeting was held on February 27, 1987 to discuss the scope and findings of this inspection, as detailed in this report (see Paragraph 1.0 for attendees). The licensee did not indicate that any proprietary material was contained within the scope of this inspectio At no time during this inspection was written material provided to the license . -- .

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ATTACHMENT 1 DOCUMENTS REVIEWED 2BVM-29, Vendor-Supplied Documentation Control Procedure (SWEC), Revised July 31, 1985 2BVM-83A, Project Records Type List (SWEC), Rev 8, January 12, 1987 2BVM-209, Site Engineering Group Input to Manufactures Handling System (SWEC),

Revised September 9, 1985 FCP-30, Field Control Procedure (FCP), Jobsite Document Control (SWEC),

Rev 15, May 12, 1986 '

FCP-32, Microfilming Site Permanent Plant files (SWEC), Rev.10, August 23, 1985 BVPS-0M-2.54.1, Chapter 54, Station Logs, Preliminary Issue, Rev. O BVPS Unit 2, Chart Recorders and Types BVPS Unit 2, Records Management Program, Rev. C, February 20, 1987 Duquesne Light Record Management Manual, Procedure No. II-5.0, Transmittal and Receipt of QA Records, Rev. O, May 26, 1983 Quality Control Instruction (QCI)-17.1, 0QC Records Instruction for BVPS Operations, Rev. O, March 10, 1986 Site Administrative Procedures (SAP), Chapter 3D, the Maintenance Work Request, Rev. 3, January 1, 1987

i SAP Chapter;7, Office, Records Management and Security, Rev 7, July 10,1985 SAP Chapter 11, Procedure Preparation, Review and Approval, Rev 7, December 5, 1986 l SAP Chapter 16, Technical Advisory Group, Rev. 3, May 30, 1986 SAP Chapter 32, Nuclear Plant Reliabiltiy Data System, Rev.1, January 23, 1987 l MMS-21.0, Accumulation, Storage, Distribution, and Retention of Records (Material management section), Rev. 2, January 9, 1987 Startup Manual Chapter 1, BVPS-2 Startup Group Organization and Responsibili-ties, Rev. 2, May 30, 1986 Startup Manual Chapter 2, Administrative Controls and General Instructions, Rev. O, August 27, 1985 Startup Manual Chapter 6.2, Personnel Training and Indoctrination, Rev. 1, August 29, 198 Startup Manual Chapter 7.1, System / Subsystem Turnover Program, Rev. 5, April 1, 1986