IR 05000412/1987027

Insp Rept 50-412/87-27 on 870330-0403.No Violations Noted. Major Areas Inspected:Qa/Qc Interface W/Startup Test Program & Implementation,Maint,Instrumentation & Control Organization & Procedures & Transformer Insp

ML20213G330
Person / Time
Site:	Beaver Valley
Issue date:	05/05/1987
From:	Blumberg N, Finkel A, Prell J, Denise Wallace NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213G310	List: IR 05000412/1987027 ML20213G307
References
50-412-87-27, NUDOCS 8705180236
Download: ML20213G330 (13)

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l U.S. NUCLEAR REGULATORY COMMISSION REGION !

l Report N /87-27 Docket N License No. CPpR-105 Licensee: Duquesne Light Company P. O. Box 4

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Shippingp_ ort, Pennsylvania 15077 Facility Name: Deaver Valley Power Station,_ Unit _No. 2 f

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Inspection At: h Shipphpo rt , _P_e_nn syl va n_.1 a  ;

l Inspection Conducted: March 30- April 3, 1987 ,

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Operational Programs Section, 00, ORS Ins Routine unannounced inspection conducted on March 30-Afr_pection Summary:i n Efl812(I n ip e cB iin~ E,~507412/67-27f

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A,reas Inspected: QA/QC interface with the startup test program and implement-ation; routino unannounced inspection of the licensee's startup test program and maintenance and !&C organization and procedures and transformer inspectio The inspection was conducted onsite by three region-based inspector Results: No violations were identified.

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I DETAILS 1.0 Persons Contacted Duquesne Light Co,

• 0. Claridge, Compliance Engineer

• N. Daugherty. Ofrector Systems Testing J. Dusenberry, QA Inspector

"J. Godleski, Senior Test Engineer

• 0 Hunkele, Director, QA operations

• J. Johns, Supervisor, QA Surveillance

• J. Kasunick, Maintenance Director, Startup Group

• A. Lerczak, BV-2 Procedures Supervisor

• T. McGourty, Senior Test Coordinator T. Noonan, Superintendent, Operations and Maintenance

• Pergar, QC Supervisor L. Rabenau, Lead Compliance Engineer

• C, Schultz, Chairman, Procedure Review Committee

• R. Swiderski, Manager, Startup

• L. Williams, Otractor, Startup

• T. Zyra, Director, $1te Test and Program Following

• Denotes those present at the exit meeting on April 3, 1987.

The inspectors also interviewed other personnel during this inspection perio .0 5tartup_ Test Program Requirements f / References

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Beaver Valley Power Station-2, Final Safety Analysis Report, Amendment 15, (March 1987) Section 14.2, Startup and Test Program

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Regulatory Guide 1.68, Revision 2, Initial Test Programs for Water-Cooled Nuclear Power Plants

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

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10 CFR 50, Appendix 0,Section XI Test Control

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Deaver Valley Power Station - Unit 2 proposed Technical Spectfication _ _ _ _ _ _ ___ _____ ______ _ _ _ _ _

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2.2 Program Review

The proposed startup test program for BV-2 was reviewed to determine if:

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the licensee had developed administrative controls which would help assure the requirements and commitments stated in section 2.1 were met;

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the proposed tests were consistent with FSAR and RG 1.68 commitments;

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a specified format and content for startup test procedures had been established consistent with RG 1.68 and ANSI N1 commitments;

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the licensee has assumed overall control of all startup test activities;

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interface controls between the various testing groups have been established;

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formal administrative measures have been established for controlling the conduct of testing;

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a formal program for evaluation of test results has been established;

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administrative measures have been established for test procedure review, approval and issuance;

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administrative measures have been established which control the revision of approved procedures; and

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operating procedures used during testing will be approved in accordance with the proposed Technical Specifications.

4 In addition a sample of Startup Test procedures were reviewed to determine their technical and administrative adequac The procedures reviewed are listed in Attachment A of this report.

2.3 Program Implementation The administrative procedures to be used for the startup test program were reviewed and found to meet regulatory requirement In addition it was verified that a time schedule has been developed for the startup test program; that the licensee has identified and had

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prepared or was in the process of preparing test procedures for each test; that 28 out of 36 total startup test procedures have been approved; and that the 10 test procedures reviewed met administrative and regulatory requirement The following criteria were verified to be incorporated into each IST procedure reviewed:

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Management approval for each procedure was indicated;

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Appropriate committee reviews were indicated;

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Procedure format was consistent with ANSI N18.7 and Regulatory Guide 1.68;

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Test objectives were clearly stated and all FSAR commitments were included;

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Pertinent prerequisites were identified;

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Acceptance criteria were clearly identified and comparison of test results with acceptance criteria required;

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The source of the acceptance criteria was identified;

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Step-by-step instructions were provided for the performance of the test;

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Spaces were provided for initialing to indicate that all items, including prerequisites, were performed;

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Special precautions for personnel and equipment safety were specified; and,

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Technical Specification (TS) requirements were incorporated into the procedure .4 QA/QC Interface with Startup Test Program A review of the proposed QA program to be used during Startup Testing was made. From this review it was determined that:

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The QA Surveillance group plans to perform surveillance coverage twenty out of twenty-four hours per day - in two ten hour shift Present staffing levels for the QA surveillance group consist of one QA Surveillance Group supervisor, three Senior QA Specialists and one QA Specialist. Presently there are an additional five contractor personnel in the Group but there are currently no plans to use the contractor personnel for startup test coverag Paperwork has been originated to hire two more QA Specialist All personnel in the QA Surveillance Group, except two, have degrees. One of these two is presently a licensed SRO. Four personnel Qualification / Training records were reviewed and found acceptabl . .

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QA witness points have been established by the QA Surveillance Group for approved Startup Test procedure '

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After test procedures are approved and test witness points established, they are assigned to Specialists to become familiar with and develop detailed checklists. Generic

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checklists.for test procedures have been developed which are used as the basis for expanding upon by the responsible

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The QA Surveillance Group is responsible for performing

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surveillances at both Units 1 and 2. However during the Startup Testing Program they will devote most of their time to Unit Present plans call for them to witness all 36 test The inspector also reviewed two surveillance reports, POT-88-87 and

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.t 'm POT-71-87, from the Preoperational Test Program and it was determined s that responses to deficiencies identified were prompt and responsive and that the surveillances were in-depth.

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- 2.5 Findings While reviewing IST 2.018.03, " Control Roa Drop Time Measurement Test", the inspector determined that Step VI.A.12.a did not specify the correct TS maximum Reactor Coolant System (RCS) heatup rat The procedure indicated that the maximum RCS heatup rate was 100 F/hr vs 60 F/hr as specified in the current TS. The licensee stated that this would be corrected and pointed out that the Startup Manual and the Testing and Plant Performance procedure (TPP) require that procedures be reviewed against TS requirements 60 days prior to performance.'iThe inspector verified that the review does include verification of all references to the TS. The inspector had no y further question During the review of IST 2.01B.02, " Control Rod Drive Mechanism Timing Test", the inspector noted that for Mode 3, the procedure did not require all control rods to be tested by utilizing a sound pickup attached to the Control Rod Drive Mechanism (CRDM). The- '

inspector _ questioned the licensee in order to determine what purpose the microphones serve and whether the FSAR commitment to verify proper mechanism operation for each CRDM while in Mode 3 (FSAR, paragraph 14.2.12,3.3) would be fulfilled by the procedure. The licensee was not prepared to state the exact purpose of the micro-

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phones of that time, but submitted a " Request for Westinghouse

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Response" in orde'r to obtain the necessary technical basis for not s using the microphones on each CRD _

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During subsequent telephone communications, the licensee stated that microphones are to be used for troubleshooting the CRDMs, and are not essential for verifying proper mechanism operation. The licensee also stated that the rod position indication and CRDM coil current traces are the means by which CRD mechanism operation is to be verifie The inspector later reviewed Westinghouse Response, T-1084, "CRDM Microphone Timing Tests", which addressed the previously submitted

" Request for Wesinghouse Response". The inspector verified from the review that the microphones are not essential for determining proper operation of the CRD mechanicms. The inspector concluded that the FSAR commitments for testing the CRDM mechanisms are satisfied in the procedure. The inspector had no further questions at that tim No violations or deviations were identifie .0 Maintenance / Instrumentation and Control Organization 3.1 Administrative Controls The purpose of this inspection was to review and evaluate the licensee's program plan for controlling safety related Maintenance and Instrumentation and Control activities and to assess-the progress of administrative controls established to date. Documents reviewed by the inspector are listed in Attachment B to this repor Recording of Unit 2 maintenance data is part of the Unit 1 main-tenance data system. The hard copies of the maintenance data are maintained in separate Unit I and Unit 2 repositories at this tim .2 Unit 2 Maintenance Status The Maintenance Work Request system (MWR), presently in place on the Unit I site for tracking, trending and control of Maintenance I&C activities, is to be used at the Unit 2 sit The planning groups plan and coordinate the activities that are performed by both the Maintenance and I&C organizations and also update the MWR status when the tasks are completed. Both oreventive and corrective maintenance work orders are generated by tre MWR system as well as work order status and trending data. Review and approval of the MWR is required by the Maintenance and I&C supervisors to ensure that the administrative controls are properly established and implemente The Station Administrative procedures (SAPS) for this site have been issued. The SAPS listed in Attachment B, of this report, were reviewed by the inspector to evaluate compliance with the FSAR and Technical Specification. The inspector also reviewed selected maintenance work requests (MWRs) for compliance with the Station Administrative Procedure, SAP-3 .

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No violations or deviations were identifie . Maintenance / Instrumentation and Control Procedures The intermingling of Unit 1 and Unit 2 Mainter.ance and I&C personnel staff has been occurring for the last few years. This has increased the awareness of Unit 2 personnel for the need to maintain proper quality while conducting Unit 2 maintenance activities. The use of similar procedures in Units 1 and 2 has allowed for fully developed and workable procedures to be available for use during maintenance work on the Unit 2 system The centralized use of existing Unit 1 Maintenance and I&C procedures for the Unit 2 systems has also provided the capability to plan and schedule maintenance activities between the two maintenance organizations. Maintenance Work Requests '

(MWRs) are processed, and the resultant work packages; including work orders, personnel requirements, tagging requests, radiation exposure permits, equipment requirements, etc., are identified and assembled by designated personnel knowledgeable of the program from their Unit 1 experience with the syste . Procedure Preparation and Review Status Maintenance and Instrumentation and Control procedures have been written and approved with the exception of a few procedures that are in the final review cycle. To determine if the procedures were in compliance with the Station Administrative Procedures (SAP's) and Maintenance and I&C Manuals, the inspector reviewed those pracedures identified in Attachment B to ensure that the criteria of the above reference documents were properly incor-porate The inspector also verified that maintenance and I&C personnel are required to read and understand their manuals and pro-cedurer. A self reading program and review by the responsible supervisor is an integral part of the self study progra No violations or deviations were identifie .3 Program Implementation The inspector held discussions with the Maintenance and I&C supervisors to evaluate the controls used to identify, schedule and track completed and scheduled maintenance and I&C MWR ,

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The inspector reviewed the records of both randomly and specially selected maintenance activities performed on safety related equipment to verify that:

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Required administrative approvals were obtained prior to initiation of work activities;

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Appropriately approved procedures, instructions and/or drawings were verified and used;

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Required post-maintenance testing was completed and verified prior to returning equipment to operations;

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Hold points were identified and completed or are in the process of being completed;

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Test equipment and tools used had their serial number recorded;

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Proceduces and appropriate data sheets were properly completed;

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Acceptance criteria was defined and complied with; and,

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Records were assembled, stored and retrievable as part of the maintenance histor A review by the inspector of the records associated with the procedures listed in Attachment B of this report, verified that the test results were within the procedure criteri No violations or deviations were identifie .0 Transformer Inspection The inspector reviewed the licensee's program for transformers to determine if a program of inspection and maintenance is in place for large transformers whose failure could cause challenges to or interaction with safety system The inspector selected the Station Service Transformer (SST) to verify if the licensee's inspection methods and programs used to determine the overall operational characteristics of their transformers was adequat Unit I has a Westinghouse S/N NRS-2895-2 transformer while Unit 2 has a McGraw Edison transformer. The transformer values are listed belo ._

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- Unit I 138KVA 955*c 19200KVA, 25600KVA, 3200KVA 065*c 21504KVA, 28672KVA, 35840KVA Unit 2 138KVA 955 c 19200KVA, 25600KVA, 3200KVA 965*c 21504KVA, 28672KVA, 35840KVA The station operators daily inspect the SST and record the following data:

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Winding Temperatures;

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Transformer's oil temperature and levels;

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Bushing oil levels;

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Cooling fans operating condition; and

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Oil pump pressure The test results and oil samples are reviewed and analyzed by the 11-censee's central chemical laboratory. The station maintenace organization also reviews the results of the laboratory data and issues the transformer status as part of their Consolidated Preventive Maintenance Evaluation Report. Various Doble transformer tests and data analysis are also per-formed by the license The procedures and test data documentation reviewed by the inspector is listed in Attachment C of this repor No violations or deviations were identifie .0 Independent Verifications The inspector verified that the " Isolation of Unborated Water Sources" valve lineup for IST 2.14A.01, " Systems for Sampling for Core Load," was

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Chemical and Volume Control Piping Drawings:

12241-0M-207-1 12241-0M-207-2 12241-0M-207-3A 12241-0M-207-3B 12241-0M-207-4 No violations or deviations were identifie i1 . .

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6. 0' Plant Tours The inspectors toured the control room, turbine building, service building, auxiliary building'and containment. A review of the work in progress and cleanliness was made. Good housekeeping practices were found in evidence in areas turned over to the license .0 Exit Interviews An exit meeting was held on April 3, 1987 to discuss the inspection scope and findings, as detailed in this report (See paragraph 1.0 for attendees).

At no time was written material given to the license '

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-ATTACHMENT A PROCEDURES REVIEWED RELATED T THE STARTUP TEST PROGRAM ADMINISTRATIVE TPP 12.1, Rev. O, Preparation, Review, Approval and Revision of Unit 2 Startup Test Procedures TPP 12.2, Rev. O, Administrative Guidelines for Performing Unit 2 Startup Tests TPP 12.3, Rev. O, Unit 2 Test Records Management TPP 12.4, Rev. O, Unit 2 Test Evaluation and Reports TEST PROCEDURES IST-2.43.02, Rev. O, Plant Radiation Survey and Verification of Shielding Effectiveness IST-2.01A.10, Rev.-0, Startup Testing Program 2.018.02, Revision 0, Control Rod Drive Mechanism Timing Test 2.018.04, Revision 0, Rod Control System Test 2.01B.03,-Revision 0, Control Rod Drop Time Measurement Test 2.06.01, Revision 0, Reactor Coolant System Leak Rate 2.03.01, Revision 0, Incore Movable Detector System 2.14A.01, Revision 0, Systems Sampling for Core Load 2.018.01, Revision 0, Control Rod Position Indication System Test

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ATTACHMENT B

' Site / Station Administrative Procedures Chapter 1 Administrative Controls and General Instructions 3D Maintenance Work Request Maintenance 14 Station Surveillance Program 33 Control and Coordination of Surveillance Test and Calibrations 33 Temporary Modification BVPS 1/2 Maintenance Manual Section 1 General Rules for Implementation 2 Control and Calibration of Measuring Devices 5 Relay Testing 6 Maintenance Training Program 9 Preventive Maintenance

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Preventive Maintenance Procedures

.480 Volt Bus Circuit Breaker Inspection and Test Procedure, PMP N EJS-BKR-IE, Revision 4, March 1987; Station Battery Operability Test and Inspection Procedure, PMP N BYS-BAT-5-6-4E;

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ATTACHMENT C Transformer Maintenance Documentation

-- -Duquesne Light Company Transformer Oil Dissolved Gas Analysis Report, BVPS Unit 2;

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System / Component Consolidated Preventive Maintenance Evaluation System Report;

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Transformer 011 Sampling Procedure, PMP No. 2-75-TRF-7E, Revision 1, January 1986;

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Station 2A & 28 Service Transformer Undervoltage Automatic Transfer Initiation Procedure, BV2-TA-1-25R-36A;