ML19291C327
| ML19291C327 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/15/1979 |
| From: | Kehoe D, Kister H, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19291C324 | List: |
| References | |
| 50-334-79-18, NUDOCS 8001240206 | |
| Download: ML19291C327 (13) | |
See also: IR 05000334/1979018
Text
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-334/79-18
Docket No.
50-334
License No.
Priority
Category
C
--
Licensee:
Duquesne Light Company
435 Sixth Street
Pittsburgh. Pennsylvania 15219
Facility Name:
Beaver Valley Power Station - Unit 1
Inspection At:
Shippingport, Pa. and Corporate Offices, Pittsburgh, Pa.
Inspection Conducted:
Augpst 20-24, 1979
Inspectors:
\\/ f.
W W
D. V. Kehoe, Reactor Inspector
date '
l0
9
G.4Napuda, Reactor Inspector
'dat6
C. Sweinhart, Reactor Inspector Co-op
date
,
,
Approved by:
[
(Lt.wt
v-
/f/79
H.B.Aister,ChiefNuclearSupport
/ date
Section No. 2, RO&NS Branch
Inspection Summary:
Inspection on August 20-24, 1979 (Report No. 50-334/79-18)
Areas Inspected:
Routine unannounced inspection by regional based inspectors of
the Quality Assurance Program (QAP) implementation including:
QA/QC administra-
tion; design changes / modification program; design changes / modifications; records
management; offsite support staff; and, followup on previously identified items.
The inspection involved 54 inspector-nours onsite and 26 inspector-hours at the
corporate offices by two NRC regional based inspectors.
Results:
Of the five areas inspected, no items of noncompliance were identified
in three areas; one item of noncompliance was identified in one area (Deficiency -
failsre to store records per ANSI N45.2.9 requirements
paragraph 6); and, four
items of noncompliance and one deviation were identified in one area (Infraction -
failure to document 10 CFR 50.59 evaluations
paragraph 4.C(1); Infraction -
failure to maintain "As Built" drawings in station files
paragraph 4.C(2);
Infraction - failure to update Technical Specifications and procedure subsequent
to a modification
paragraph 4.C(3'; Infraction - Station Engineering perform-
ing Category 1 engineering
paragraph 4.C(4); Deviation - failure to comply
with commitments
paragraph 4.C(5)).
Region I Form 167-
1795 028
(August 1979)
800124 0
26C
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DETAILS
1.
Persons Contacted
- F. A. Arnold, Construction Specialist
- R. F. Balcerec, Maintenance Supervisor
- G. L. Beatty, QA Engineer
- J. J. Carey, Technical Assistant
- R. E. Conrad, Senior Engineer
- G. E. Ewing, QA Supervisor
H. G. Frus, Electrical Engineering Department Head
- R. L. Hansen, Q.C. Engineer
- L. K. Hutchinson, Station QA engineer
- F. J. Lipchick, Station QA Engineer
N. M. Logan, Acting Structural Department Head
- R. M. Mafrice, Supervisor On-Site Engineering
- A. C. Mazuckna, Q.C. Supervisor
- G. W. Moore, General Superintendent, Power Stations Department
'
- R. Prokovovich, Reactor Engineer
F. Salmna, Mechanical Engineering Department Head
- L. G. Schad, Operations Supervisor
- J. E. Starr, Station Engineer
- H. A. VanWassen, Project Manager
R. Washabaugh, Manager QA Department
- D. H. Williams, Results Coordinator
- H. P. William <, Chief Engineer
- E. J. Woolever, Vice President-Engineering & Construction
Other Accompanying NRC Personnel
D. Beckman, Reactor Inspector
The inspectors also held discussions with and interviewed other members
of the Power Station and Duquesne Light Company technical and administra-
tive staff.
- Denotes those present at the exit interview.
2.
Followup cn Previously Identified Inspection Findings
(Closed) Unresolved (334/78-26-01) Revision of Power Station Engineering
Procedures to delete provisions for performance of category I modifica-
tions.
This item is closed out for records purposes as a Deviation has
been issued against this connitment (Paragraph 4.C(5) of this report).
(Closed) Unresolved (334/78-26-07) Revision of Station Engineering Pro-
cedures to conform with ANSI N45.2.11.
This item is closed out for
1795 029
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3
records purposes as a Deviation has been issued against this commitment
(Paragraph 4.C(5) of this report).
(Closed) Unresolved (334/78-26-03) Transmittal of backlogged completed
Design Change Packages from site to Project Team.
This item is closed
out for records purposes as a Deviation has been issued against this
commitment (Paragraph 4.C(5) of this report).
(Closed) Unresolved (334/78-26-05) Review corrective action for QA audit
BV-1-78-2, Finding #8.
This item has been incorporated into an item of
noncompliance which is discussed further in paragraph 6.
(0 pen) Unresolved (334/78-26-06) Verify that QA/QC requirements with res-
pect to equipment calibration services procurement are commensurate with
intended use of said equipment.
Discussions were held with the licensee
representative who stated that the suppliers of calibration services
were evaluated and placed on the approved vendors list.
Further, Main-
tenance Manual Chapter 1, Section G requires all purchase requisitions
to be reviewed by QA.
This item remains open pending further review by
NRC:RI of this area with respect to the utilization of vendors for
calibration services.
3.
QA/QC Administration
The inspector reviewed the approved FSAR, Appendix A, Quality Assurance,
the Operational Quality Assurance Plan (0P's) and the Quality Assurance
Instructions (QAI's) to verify that:
The scope and applicability of the QA Program was defined.
--
Appropriate Controls were established to prepare, review and approve
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QA Program procedures, including changes thereto.
A mechanism has been established to review and evaluate the QA
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Program
No items of noncompliance were identified.
4.
Design Change / Modification Control
a.
References
EMP 2.6, Classification of Safety Related Structures, Systems
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and Components, Revision 2
EMP 2.7, Requests for Station Modification, Revision 0
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EMP 2.8, Handling of Design Change Packages, Revision 2
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1795 030
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EMP 2.11, Constre ,cion and Installation Specifications,
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Revision 2
EMP 2.17, Design Analysis, Revision 0
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EMP 2.18, Design Verification Control, Revision 1
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EMP 2.19, Design Review Verification, Revision 1
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EMP 2.21, Qualification Testing, Revision 1
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EMP 2.22, Engineering Memoranda, Revision 0
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EMP 2.23, Engineering Change Notice, Revision 1
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EMP 5.2, Correspondence Control, Revision 2
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EMP 9.1, Records Processing, Revision 2
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Maintenance Manual, Chapter 1, Conduct of Maintenance, Section P,
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Control of Design Changes, Revision 1
Maintenance Manual, Chapter 1, Conduct of Maintenance, Section G,
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Material Procurement
b.
Program Review
-
The documents listed above were reviewed to determine whether admin-
istrative controls for design cnanges/ modifications have incorporated
the requirements as described in the Beaver Valley Quality Assurance
Program.
This review determined that administrative controls have been esta-
blished which verify the following:
procedures for control of design changes / modifications have
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been developed
design document control has been established
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channels of communications between the design organization and
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the individual responsible for implementation exist
design change / modification packages are being converted into
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plant records
methods exist for identifying and reporting those design changes /
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modifications which are within the scope of 10 CFR 50.59
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1795 031
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5
procedural controls exist for temporary modifications, lifted
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leads and jumpers
responsibilities have been delineated in writing to assure the
--
implementation of the above.
No item of noncompliance were identified, however, three unresolved
items are discussed below.
(1) The inspector discussed the involvement of the quality control
organization with respect to design changes / modification with
the Quality Control (QC) Supervisor at the site, the engineer
in charge of the Project team and several of the engineering dis-
cipline engineers at the Pittsburgh office.
The development of
QC inspection plans and QC hold points in specifications is
the responsibility of the respective discipline engineer.
It is,
however, common practice for the discipline engineer to consult
with the QC Supervisor concerning QC requirements in design
change packages (DCP's).
Further the QC organization is review-
ing DCP's and either developing inspection plans or contacting
the discipline engineer for incorporation of applicable QC
requirements into specification and/or procedures.
The inspec-
tor identified that there is no procedural control for the above
process.
The licensee acknowledged the inspector's comment and
stated that a procedure would be prepared to identify the above
process, and that this would be complete by February 15, 1980.
This item is unresolved pending review by NRC:RI of the above
stated procedure (334/79-18-01).
(2) During discussion, the QC Supervisor stated that during the
upcoming outage on Unit #1 it is expected that all QC work with
respect to DCP's will be performed by a contracted QC organiza-
tion.
Further, the onsite QC' organization shall perform a sur-
veillance of the contractor QC organization.
The licensee also
stated that the procedure governing the surveillance of con-
tractor QC is now under development and would be issued prior
to the upcoming outage.
This item is unresulved pending review
of the new procedure by NRC:RI during a subsequent inspection
(334/79-18-02).
(3) The inspector noted during his review of the Engineering Manage-
ment Procedures (EMP's) that the requirement of ANSI 18.7-1972
for a periodic review of procedures was not delineated in the
EMP's.
The licensee acknowledged the inspector's comments and
stated that the EMP's would be revised by February 24, 1980 to
include this requirement.
This item is unresolved pending review
by NRC:RI of the subject procedure revision (334/79-18-03).
1795 032
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c.
Implementation Review
The inspector reviewed the following design change packages (DCP's):
DCP 109
Drain Orifice Installed on Recirculation Spray Lines
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DCP 223
Manual Field Flashing of Diesel Generators
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DCP 233
Installation of Hydraulic Snubbers on Safety Injection
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Piping
DCP 251
Pressurizer Pressure 2 out of 3 Logic in Lieu of
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Coincident with Level
DCP 270
Replacement of IA Charging Pump with a Unit No. 2
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Charging Pump
The modifications listed above were reviewed to verify that the
following requirements have been implemented.
10 CFR 50.59 reviews were performed and documented.
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design :hanges/ modifications were reviewed in accordance with
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the requirements of the technical specifications and the QA
Program
design changes / modifications were accomplished in accordance
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with written procedures
acceptance testing was accomplished and deemed satisfactory
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procedures and drawings required to be changed or generated as
a result of the design change / modification were updated or
generated
the design change / modification package has been transmitted to
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the records retrieval department for incorporation as a plant
record
Four items of noncompliance and one deviation were identified and
are discussed below:
(1) The inspector reviewed the safety evaluations which were per-
formed by the Onsite Safety Committee (OSC), pursuant to 10 CFR 50.59, and documented in their meeting minutes.
The inspector
noted during this review that the safety evaluations for DCP-223
and DCP-233 were simply statements of conclusion which.did not
address the basis for the conclusions.
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1795 033.
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An acceptable means of complying with the requirements of
10 CFR 50.59 is as follows:
Any proposed change to a system or procedure as described in
the SAR either by text or drawings is to be reviewed by the
licensee to determine whether it involves an unreviewed safety
question.
This review must be a written safety evaluation.
In
all cases requiring a written safety evaluation, the safety
evaluation must provide the basis for the determination that
the proposed change does or does not involve an unreviewed
safety question.
A simple statement of conclusion in itself
is not sufficient.
10 CFR 50.59 states that records of facility changes shall be
maintained and that these records shall include a safety evalua-
tion and the basis for the determination that the proposed
change does or does not constitute an unreviewed safety question.
The Station Maintenance Manual, Chapter 1, Section P, Control of
Design Changes, revision 1, states that the OSC shall perform
the safety evaluation and shall provide the basis for the deter-
mination that the proposed change does or does not constitute
an unreviewed safety question in the OSC meeting minutes.
The failure of the OSC to provide the basis for the conclusions
of their safety evaluations on DCP-223 and DCP-233 in the meet-
ing minutes constitutes en item of noncompliance at the infrac-
tion level (334/79-18-04).
The inspector noted that a discussion of a DCP by the OSC with
documentation thereof in the meeting minutes is being used as
the 10 CFR 50.59 safety evaluation.
The acceptability of an OSC discussion of a DCP as documented
in their meeting minutes as a written safety evaluation will be
addressed during a subsequent inspection.
(2) The inspector reviewed the drawings referenced in the respective
design change packages to verify that they reflected the "As
Built" condition of that system or component with respect to
the changes made by that design change.
The drawings reviewed
were as follows:
DCP No.
Drawing No.
0251
8700-RE-21PQ
8700-RE-21SD
8700-RE-4AM
1795ON
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DCP No.
Drawing No.
0223
8700-RE-3BF
8700-RE-3BD
8700-RE-14A
8700-RE-148
0071
8700-RE-25W
-
8700-RE-3FS
8700-RE-3CW
8700-RE-3CX
The inspector noted that there were no "As Built" drawings in
the station files which depicted the above referenced design
changes.
10 CFR 50, Appendix B, Crition II states that the QA Program
shall be documented by written policies, procedures and instruc-
tions and the program shall be carried out in accordance with
these policies, procedures and instructions.
The approved FSAR establishes a commitment to ANSI N45.2.8,
Supplmentary Quality Assurance Requirements for Installation,
Inspection and Testing for the Construction Phase of Nuclear
Power Plants.
ANSI N45.2.8 states that a system of controls
be established to assure that "As Built" information is being
processed.
Station procedure OP-4, Station Design Control,
states that the station superintendent shall update the station
file with "As Builts" as socn as preoperational testing is com-
plete and the test results are approved.
The failure to maintain "As Built" drawings in the station files
which reflect the above design changes is an item of noncompli-
ance at the infraction level (334/79-18-05).
(3) The inspector noted during his review of DCP-233 that procedure
ISI 5.0, Reactor Coolant System Hydraulic Pipe Support Examina-
tion, and Technical Specifications table 3.7.4 had not been
updated to reflect the installation of safety related snubber
SI-HSS-529.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and
Drawings, states that activities affecting quality shall be pre-
scribed by documented instruction of a type appropriate to the
circumstance.
Maintenance Manual, Chapter 1, section P, Control
of Design changes, states that the senior engineer shall update
the station files and procedures subsequent to a design change.
The failure to update the station procedure and the applicable
technical specification section is an item of noncompliance at
the infraction level (334/79-18-06).
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1795 035
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9
(4) The inspector noted during his review of the documentation asso-
ciated with the replacement of charging pump IA, that Engineering
memo No. 60076 was responded to by the Power Station Engineering
Group (PSEG).
The subject memo requested engineering support in
the mounting of the gear box and motor units as these items could
not be aligned properly with the existing mounting holes.
The
PSEG authorized the slotting of the mounting holes and the use
of oversized washers, which was a modification to the charging
pump.
The corporate engineering group was not made aware of the
modification and as a result the seismic analysis of the charging
pump replacement was not properly completed and the plant was
permitted to retern to an operational status without the required
review.
The f.mpector expressed concern that although, in this
case, it was determined that the loads applied at the mounting
bolts were negligible and therefore, had no significant effect
on the results of the seismic analysis, adequate controls were
lacking which would ensure that field change information is for-
warded to the responsible design organization for proper review.
Inadequacies in the station design change program administrative
controls had been discussed during previous Region I inspections
(IE Inspection Reports 334/78-09 and 78-26).
10 CFR 50, Appendix B, Criterion V, states that actiu ties affect-
ing quality shall be documented by procedures appropriate to
the circumstances.
The BVPS FSAR establishes a commitment to
ANSI N45.2.11 via Regulatory Guide 1.64.
ANSI N45.2.11 states
that design changes and field changes shall be transmitted to
the affected persons and organizations.
that each organization shall ident*fy those quality affecting
activities performed by that organization and to adequately define
those activities in documented procedures.
The failure of the PSEG to have procedural controls that insure
all field change information be transmitted to the responsible
design organization for proper review is an item of noncompliance
at the infraction level (324/79-18-07).
(5) Letter B. H. Grier to C. N. Dunn dated November 3,1978, requested
a detailed schedule with identifiable milestones for the imple-
mentation of corrective action associated with unresolved items
334/78-26-01, -02 and -03.
Letter C. N. Dunn to B. H. Grier dated
November 28, 1978, states in part, "in response to your request
for a schedule for corrective action on unresolved items 78-26-01,
-02, and -03 the following is proposed . . . Immediate Action:
The Power Station Engineering Group (PSEG) has been directed that
design perfcrmance of all category I modifications shall be assigned
to the Duquesne Light Company Engineering Deiartment.
This shall
include any changes to design deemed necessary during installation
,
1795.036
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10
. . . . January 31, 1979 - Complete revision of Station Engineer-
ing Procedures . . . February 28, 1979 - Completion of transmit-
ting all completed Category I design change records to the Beaver
Valley Project Team for records update .
Inspection 334/79-06
"
..
conducted on February 27 - March 2, 1979 identified that the Power
Station Engineering Procedures had not been revised and the design
change records associated with completed Category I modifications
had not been transmitted to the Beaver Valley Project Team for
records update.
Consequently, a revised schedule of May 1, 1979
and March 15, 1979, respectively was proposed for these items.
During this inspection it was identified that the policy statement
with respect to the PSEG not performing Category I work had not
been established or implemented at the station, the PSEG procedures
had still not been updated and the design change package associated
with completed Category I modifications had not been forwarded
in their entirety to the Beaver Valley Project Team.
The inspec-
tors noted that internal audit BV-1-79-7 also identified this
condition.
This item is considered to be a deviation (334/79-18-08).
(6) During a telephone conversation on August 29, 1979 between Mr. D. A.
Beckman of NRC:RI and Mr. J. A. Werling of the licensee's staff,
Mr. Werling stated that the records missing from the design change
-
packages are a result of the station's design change program ini-
tially not conforming to the requirements of ANSI N45.2.11.
This
failure to conform with ANSI N45.2.11 was identified during 1978
by the DLC Quality Assurance Deoartment and subsequently verified
by NRC:RI.
As a result of these findings, the station took action
to achieve compliance with ANSI N45.2.11 but determined that no
need existed to backfit the ANSI requirements to previously com-
plated design changes, thus resulting in the absence of some record
information required by ANSI N45.2.11.
Mr. Beckman informed Mr. Werling that, notwithstanding the licensee's
previous positions on ANSI N45.2.11, those design change packages
having incomplete documentation require evaluation to ensure that
the applicable requirements of ANSI N45.2.11 have been addressed
and that the omission of the documantation has no impact on the
quality of the design change or safety of operation.
Mr. Werling
acknowledged these comments and stated that it was the intention
of Duquesne Light to ensure adequate resolution of the NRC:RI
concerns.
Further, it is acknowledged that some of the records missing from
the design change packages are records which were not being gene-
rated under the old program, however, there are record types miss-
ing which were required under the old program.
These are the
records to which the deviation discussed in paragraph-(5).above
is addressed.
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(7) The ins *
..i axpressed concerns to the licensee about the
licenses. . QA F Sgram and Management controls in the area of
'Lign%odfication based on the following experience history.
.E Inspection Report 334/77-24 (July 1977) noted that a
--
licensee internal audit identified inadequacies in established
design / modification control procedures, the required corrective
action was in progress and RI intended to review (unresolved
item) the completed corrective action.
IE Inspection Report 334/78-09 (March 1978) addressed in
--
part the design / modification control area, noted that recent
licensee internal audits had identified a number of additional
problems in the subject area and expressed further inspector
concerns.
IE Inspection Report 334/78-26 (October 1978) noted that the
--
corrective action associated with design / modification control
was still in process but inconsistently implemented and
therefore the licensee was requested to address the inspectors'
concerns (unresolved items) in a written reply.
In the requested written reply (November 1978) to the RI
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Director, the licensee's Vice President outlined actions
that would be taken to correct the design / modification
control problems and specified completion dates.
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IE Inspection Report 334/79-06 (March 1979) addressed the
noncompletion of these corrective actions by the specified
dates and cautioned the licensee that these actions and
dates were commitments to the NRC.
--
During the current inspection a number of apparent noncom-
pliances and apparent deviation were identified in the
design / modification control area.
The inspectors expressed further concern regarding the effectiveness
of the licensee's QA Program and Management controls in the
design / modification activities area during the planned lengthy
upcoming outage in view of the fact that approximately forty
major modifications are to be accomplished during this time.
The inspectors then stated that these current concerns would be
referred to NRC management for appropriate action.
The licensee acknowledged the inspectors' statements.
1795 038 -
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5.
Periodic Procedure Reviews
The inspector requested to see documentation of the annual procedure reviews
of the Office Administrative Procedures.
Procedure OAP 1.2, paragraph 6.9,
requires that the Station Office Manager perform annual reviews of the Office
Administrative procedures.
The responsible individual was not available
during the inspection and other personnel were unable to locate any documen-
tation that would indicate that the annual reviews were performed.
The
inspector stated that pending further review of this area during a subsequent
inspection this item is unresolved (334/79-18-09).
6.
Records Storage
The inspector toured the records storage room at the station and the QA
records storage room and noted the following:
Station Document Storage Room
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Record containers not properly stored
Binders containing records not in containers
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records stored loosely on top of shelves
Doors not Class A fire rated
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Structural items such as floor drainage, ventilation, fire protection
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and sealant not provided
QA Records Room
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Door not Class A fire rated
Ventilation inadequate
--
10 CFR 50, Appendix B, Criterion XVII, states that the requirements for
records retention shall be specified.
The FSAR states that provisions
include a permanent on-site records storage facility complying with the
applicable requirements, records preservation, records protection and
facility accass control.
Further the FSAR commits to Regulatcry Guide 1.88
which endorses ANSI N45.2.9.
ANSI N45.2.9 states that records shall be
firmly attached in binders for storage on shelving in containers and spe-
cifies physical requirements for a permanent records storage facility.
Failure to comply with the records storage requirements as specified above
constitutes an item of noncompliance at the deficiency level (334/79-18-10).
7.
Offsite Support Staff
A review of the offsite support staff was conducted by the inspector which
included procedure reviews, reviews of personnel qualifications, personnel
interviews, procedure implementation and audit repnrt reviews to verify
the following:
..
1775 039
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13
Administrative controls which describe the responsibilities, autho-
--
rities and lines of communications have been developed and are
readily available
The applicable procedures referenced in subparagraphs a of other
--
paragraphs in this report are in conformance with the requirements
of 10 CFR 50, Appendix B, and the licensee's approved QA Program
The managers, group leaders and support staff members are aware of
--
their responsibilities and authorities as defined by the applicable
referenced procedo es
The personnel which comprise the offsite support staff are qualified
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to execute the respcnsibilities defined by the applicable referenced
procedures
The offsite support staff activities are effective and any deficient
--
conditio.1, as identified by QA audits, are dispositioned in a timely
and effective manner
No items of nonctmpliance were observed, however, one unresolved item is
discussed below.
The inspector de' ermined, based upon interviews with Duquesne Light
Company (DLC) discipline engineers at the Pittsburgh offices, that the
engineers are rot fully aware of their responsibilities as delineated in
the Engineering Management Procedures (EMP's).
The inspector further
identified tnat there is an EMP training program in progress and the DLC
discipline engineers are attending...The program appears to be making the
engineers aware of their responsibilities delineated in the EMP's.
This
program is scheduled for completion on September 11, 1979.
This item is
unresolved pending review by NRC:RI of the completed training package and
further interviews of DLC discipline engineer subsequent to September 11,
1979 (334/79-18-11).
8.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncompli-
ance or deviations.
Unresolved items identified during this inspection
are discussed in paragraphs 4, 5, and 7.
9.
Exit Interview
The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on August 24, 1979.
The scope and
findings of the inspection as stated in this report were presented and
the licensee verified the target dates for the unresolved items as dis-
cussed herein.
,
1795
040