ML19331B874
| ML19331B874 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/06/1980 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8008130461 | |
| Download: ML19331B874 (11) | |
Text
__. - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _.
=
".r4 t,%ifa E4 ' Cd D t S*
< L(
M12) 456-6000 435 Seam Annue 7"
August 6, 1980 United States Neclear Regulatory Commission Office of Inspection and Enforcement Attn: Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 I.E. Inspection No. 80-09
Dear Mr. Brunner:
In response to your letter dated July 8, 1980, and in accordance with 10CFR2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violations include three infractions and one deficiency.
The measures taken to correct the specific items of noncompliance, along with the necessary corrective actions taken to prevent similar occurrences in the future, vill improve the implementation of the quality assurance program.
With respect to the discussion of certain unquantified deficiencies in engineering drawings and information as more fully discussed in the attachment hereto, it was alledged that these deficiencies may effect the quality of operation and ability to respond to emergency conditions. The operating drawings are revised to incorporate plant modifications by the operating staff as modifications are completed and are accurate to the best of our knowledge.
The new procedures described in the attached reply direct the operating staff to use the final modification information to correct these drawings along with design conceptual information which did not happen in the cited instance. We do not believe that deficiencies which exist in the engineering drawings has any material effect on the quality of operation or the ability to respond to erergency conditions.
['ddl St/
80081syg,,
Beaver Valley Power Station, Unit No. 1 Docket No.-50-334, License No. DPR-66 I.E. Inspection No. 80-09 Page 2-If you have any questions concerning this response, please contact my office.
Very truly yours,
} l w~
C. N. Dunn Vice President, Operations Attachment cc:
Mr. D. A. Beckman, Resident Inspector U.S. Nuclear R2gulatory Commission Beaver Valley Power Station Shippingport, Pennsylvania 15077 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C.
20555 e
l l
l
9 DUQUESNE LIGHT COMPANY Beaver. Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 80-09
. Letter Dated July 8, 1980 INFRACTION A' Description of Infraction (80-09-11)
Technical Specification 6.8.1.c states, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below:...c.
Surveillance and test activities of safety related
. equipment. Technical Specification 3/4.3.3.1 specifies, in part, the Radiation Monitoring Instrument Surveillance. Requirements for Containment Purge and Exhaust Monitors (RM-1VS-104A & B) and Fuel Building Gross Activity Monitors (RM-1VS-103A & B) and requires that monthly channel func-tional-tests be performed in Mode 6 (Refueling) and with irradiated fuel in the storage pool or building.
e Contrary to the above, on the dates specified:
1.
. Operating Surveillance Test (OST) 1.43.1, Technical Specification Required Area and Process Monitor Channel Functional Test, Revision 5 and OST 1.44.C1, Containment Purge and Exhaust Isolation, Revision 1, performed during the period January through April 1980, were inadequately maintained in that they did not reflect the actual system configuration resulting from recent modifications and did not provide for testing all required trip functions.
2.
OST 1.43.1, Revision 5,. performed on March 9, 1980, was inade-quately implemented in that the tests for RM-1VS-103A & B were documented as having been satisfactorily completed without identification of either procedural or system deficiencies even though the procedure did not reflect the actual system config-uration at the time'of the test. Existing documentation is inadequate to verify the operability of the equipment with respect to the test performance.
t 3.
OST 1.~43.1, Revision 8, which was required, in part, to verify the operability of equipment modified by Design Change Packages 201/
202 was improperly maintained; in that the procedure was not issued in a' technically correct form until April 17, 1980, and the affected Fuel Building Ventilation and Containment Purge and Exhaust sub-4 systems.were placed in operation in January 1980 and required to be
. operable during fuel handling activities and refueling during the period of January 29 through February 23, 1980.
A v
nw*
pr w,
<4, m,.
.y,g
--w-g m--mm w---
e-
Reply to Notice of Violation Inspection No. 80-09 Page 2 P
INFRACTION A (continued)
,s Description of Infraction (80-09-11) (continued)
J 4.
OST 1.43.1, Revision 8, as issued originally on March 31, 1980, was further inadequately maintained in that it was reviewed, approved
.and issued in a form which failed to adequately test the operation
.of all damper / radiation monitor trip functions modified by Design Change Package 201/202.
Specifically, the OST did not require verification of correct damper positions for dampers VS-0-4-1A and B, VS-D-4-1A and B and VS-D-5-2.
Corrective Action Taken As'noted in the report, corrective actions for items A(1), A(2) and A(4) have been completed and need not be addressed in this reply.
I,.
Also as noted in the inspection report, corrective action for item A(3) was completed on April 17, 1980, in that a technically correcr procedure was issued at that t1me.
Action Taken to Prevent Recurrence Station Engineering Procedure 2.3, Design Change Coordination, has been revised to ensure adequate coordination of all station activities related to design changes.
The revised procedure includes provisions for maintaining a controlled file of design change information at the station for use by station personnel h1 procedure preparation and revision and for ensuring completion of all necessary procedure preparation and revision prior to the station's operational acceptance of design changes.
In addition, a letter was issued to all station personnel concerning their responsibilities when signing a document to verify the satisfactory completion of a prescribed activity.
The duty to adequately record and verbally report abnormal conditions or procedural deficiencies was also addressed.. We feel that this statement of Station Management position on this subject will eliminate any confusion in the future.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
INFRACTION B
' Description of Infraction (30-09-12)
.10CFR50, Appendix B, Criterion V states, in part, " Activities affecting
_ quality _shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings." The BVPS FSAR,
+
Reply to Notice of Violation Inspection No. 80-09 Page 3 INFRACTION B (continued)
Description of Infraction (80-09-12) (continued)
Appendix A.2, Operations Quality Assurance Program, Attachment, endorses the guidance of ANSI N45.2.8, Draft 3, Revision 3, September 1973, Supple-mentary Quality Assurance Requirements for the Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants. ANSI N45.2.8 provides requirements for the temporary use of equipment which is to become part of the permanent facility but has not been completely turned over from construction and/or testing.
The standard requires that authorization for usage be provided via a written approval which shall include:
(1) conditions for use or operation; (2) naintenance requirements; (3) inspections and tests required to maintain operatiitty and quality during the period of temporary use.
QA Procedure No. OP-ll, Control of Maintenance and Modification, Revision 3, Section 11.4 requires, in part, "11.4.1 The station administrative directives and detailed implementing pro-cedures shall establish the necessary measures to adequately identify the status of inspections, tests and operability..
11.4.2 The measures described in the station administrative directives and detailed implementing procedures shall provide means for assuring that required inspections and tests are per-formed and that the acceptability of systems and equipment with regard to inspections and tests performed is known throughout operations, maintenance, modification or refueling..." Station Administrative Directive No. 5, Equip-ment Turnover, issued August 1, 1974, requires that Beaver Valley Proof Test Manual Procedure 1-4 be the official detailed administrative procedure for equipment turnover.
Contrary to the above, the transfer of responsibility (turnover) for the temporary use (operation) of the systems modified by Design Change Packages 201/202 took place on January 19, 1980, via a " conditional system release" in order to support the Technical Specification requirements for refueling and associated activities. Neither Procedure 1-4 nor any other procedure was utilized to control the transfer of responsibilities with respect to the requirements of ANSI N45.2.8.
Corrective Action Taken Following the identification of the problems concerning the turnover of Design ' Change Package (DCP) 201/202, personnel from the Power Stations Department and the Construction Department Nuclear (CDN) met to evaluate the station design control program and determine whet improvements were required to ensure adequate station control of the transfer of responsibil-ities during equipment turnovers.
Subsequently, the station design control program was revised as described below under " Action Taken To Prevent Recurrence."
Since the scope of DCP 201/202 has been expanded to include additional modifications, specific actions regarding this DCP will be performed upon completion of the modifications presently being performed.
i i
Reply to Notice of Violation
' Inspection No.-80-09 Page 4 i
i I
INFRACTION B (continued) j Action Taken To Prevent Recurrence On May 20, 1980, the Construction Department issued procedure CDN 3.7.3 titled, " System Release Turnover Procedure," to amplify the instructions for system release.
This procedure clarifies the_ system release interface j
requirements between the Construction Department, the Onsite Engineering i
Group and the Power Stations Department.
On May 23, 1980, the station issued Revision 2 to Station Engineering Procedure 2.3 titled, " Design Change Coordination," to control the transfer of responsibilities during equipment turnover.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
k INFRACTION C Description of Infraction (80-09-13) 10CFR50, Appendix -
srion VI, states, in part, " Measures shall be established to contro'
_uance of documents such as instructions, pro-
'cedures and drawings, _..uding changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized
_ personnel and are distributed to and used at the' location where the prescribed activity is performed." The BVPS FSAR, Appendix A.2, Section A.2.2.6, Docu-
~
ment Control, states, in part, "The Operations Quality Assurance Program includes. provisions for assuring that documents, including changes are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed prior to
'the onset of work"... " Quality Assurance Procedure OP-8, Document Control, Revision.0, Section 8.3, states, in part, "8 3 1 Measures shall be ectablished to control the issuance, review, approval, distribution and use of documents such as instructions, procedures and drawings which prescribe _acrivities affecting quality.
Changes to Crese documents shall be controlled in the same manner _as
.the original documents.
8.3.2 These document control measures shall include provisions for:... (b) identifying the proper documents to be used in performing the' activity.
(c) Coordination and control of interface documents.
(d) Ascer-i taining that proper documents are' being used... '8.3.3 The following requirements are to be included to assure effective implementation of the document control system:... (c) Release and' distribution of information will be controlled so that
. cognizant groups are always provided with the current information... (d) Obsolete or. out-dated information must be removed to prevent its inadvertant use or appli-l cation..." 'lys Procedure OP-4, Station _ Design Control, Revision 6 Section 4.6.2, states, in part,
"...When pre-operational testing is complete and test results
-are approved, the Station Superintendent shall update the station file with the l
as-built drawings and document.'.."
m O
,w
-v.
e
,-,,y w--
r<w~-,2---.--
- ~ =
. Reply to Notice of Violation Inspection Nov-60-09 Page 5 INFRACTION C (continued)
Description of Infraction (80-09-13) (continued)
Contrary to the above, with respect to Design Change Package 201/202,
~
adequate document control measures were not implemented in that:
Construction.information, including design change output documents, was transmitted to the station staff but was not distributed, made reasonsably available or used by personnel responsible for prepara-tion review or approval of operating and surveillance procedures required to support post-modification safety related operations and testing. Operating Surveillance Test (OST) 1.43.1, Revision 8, was i
prepared without benefit of the controlled information formally transmitted to the station.
Station and control room controlled drawing files contained obsolete drawings concerning systems modified and preoperationally tested as part of DCP 201/202 and which were required to be operable by Tech-nical Specifications.
The following elementary electrical diagrams are examples of such dravings which were transmitted to the station via Controlled Document Transmittal Sheet No. DCP 201/202-46, dated March 5, 1980, and not incorporated into station files:
8700-RE-21-MQ, Fuel Building Ventilation, Revision 1B-6 1
8700-RI-21-MS, Leak Collection Venet1ation, Revision 1A-3 8700-RE-21-ME, Purge & Exhaust Ventilation, Revision 1B-4 On April 11, 1980, the control room controlled drawing files con-tained Revision 1, dated November 10, 1976, for each of the drawings above.
The as-Built drawing for the modifications such as those listed above were not received by tha statien until March 17, 1980, and were not introduced into the station distribution / filing system until April 9, 1980.
The Controlled Document Transmittal Sheet above was annotated to indicate that the drawings transmitted had not yet received final engineering checking.
Corrective Action Taken l4 Following the identification of the problems concerning the turnover of Design Change Package (DCP) 201/202, personnel from the Power Stations i
Department and the Construction Department Nuclear (CDN) met to evaluate the station design control program and determine what improvements were te
Reply to Notice of Violation Inspection No. 80-09 Page 6 INFRACTION C (continued)
Corrective Action Taken (continued) required to ensure adequate station control of the transfer of responsibil-ities during equipment turnovers.
Subsequently, the station design control program was revised as described below under " Action Taken to Prevent Recurrence."
Since the scope of DCP 201/202 has been expanded to include additional modifications, specific actions regarding this DCP will be performed upon completion of the modifications presently being performed.
Action Taken To Prevent Recurrence on May 20, 1980, the Construction Department issued Procedure No. 3.7.3 titled, " System Release Turnover Procedure," to amplify the instructions for system release.
This procedure clarifies the system release interface requirements between the Construction Department, the Onsite Engineering Group and the Power Stations Department.
This procedure provides the require-to turnover four (4) copies of type 1 as-built drawings (flow diagrams, ment elementaries, wiring diagrams and logic diagrams) for the Design Change Package.
Stations Engineerir ; Procedure 2.3, Design Change coordination, has been revised to ensure adequate coordination of all station activities related :o destsn changes.
The procedure now includss provisions for maintaining a con-trolled file of design change information at the station for use by station personnel in procedure preparation, etc. and for updating station drawings required to operate and maintain the station with as-built informatica prior to station acceptance of design changes.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
DEFICIENCY D Description of Deficiency (80-09-01) 10CFR50,-Appendix B, Criterion XII, states, " Measures shall be established to assure that tools, gages, instruments and other measuring and test devices used in activities affecting quality are properly con-tro119d, calibrated and adjusted at specified periods to maintain accuracy within necessary limits." The SVPS FSAR, Appendix A.2, Section A.2, Section A.2.2,12, Control of Measuring and Test Equipment, states, in part, "The Operations Quality Assurance Program establishes measures to assure that tools, gages, instruments and other measuring and testing devices used l
W
Reply to Notice of Violat' ion Inspection Report No. 80-09 Page 7 t
DEFICIENCY D, (continued)
Description of Deficiency (80-09-01) (continued) 1
.in activities affecting quality are properly controlled, calibrated and sdjusted at specified periods or prior to use to maintain accuracy within i
necesary. limits. Specific procedures shall include the identification of the calibration technique, the calibration frequency and the method estab-lished for the tagging of measuring devices to positively indicate their l
}-
status..." QA Procedure No. OP-12, Control of Measuring and Test Equipment, Revision 3, states, in part, "12.2.1 Station administrative directives and/or detailed implementing procedures shall be prepared to assure that measuring and testing devices are properly identified, controlled, calibrated and adjusted within necessary limits.
Such procedures shall include:
(a) Cali-l j
bration frequency.. (b) Identification of calibration technique.
(c) Method j
of tagging to indicate a devices status..."
j 4
i Contrary to the above, on March 24, 1980, dial indicators utilized in accordance with Corrective Maintenance Procedure No. CMP-1-44VS-E-4B-1M, i
4B Control Room Air Conditioner Overhaul, Revision 0, were not calibrated and controlled in accordance with the above requirements.
The instrument was utilized to make quantitative measurements subject to procedural i
acceptance criterie for coupling alignment on the safety-related compressors.
Additionally, the BVPS Maintenance Manual, Chapter 1, Section F, Control and l
Calibration of Measuring and Test Equipment does not establish or implement I
calibration or control measures for dial indicator devices.
Corrective Action Taken t
i In general, dial indicators are not used to obtain data to be used as i
- quantitative measurements subject to procedural acceptance criteria. These instruments.are used, for the most part, in maintenance activities where acceptance criteria readings are subsequently made with other devices which are controlled in accordance with Section F of-the Maintenance Manual.
~
In the future, when dial indicators are used for acceptance criteria measurements where failure to meet the acceptance criteria would render the equipment unable to perform its safety function, they will be calibrated prior.to use, i
Action Taken To Prevent Recurrence Section ? of the' Beaver Valley Power Station Maintenance Manual will be' revised to reflect the stated corrective action.
Date dn'Which Fell' Compliance'W111 Be Achieved 4
Full compliance _will be achieved by August 29, 1980.
I b
._~
' Reply to Notice of. Violation.
Inspection No. 80-09 Page 8 REQUEST FOR INFORMATION - (Unresolved item Paragraph 10 of Report 80-09) i-Provide an assessment of past practices with regard to the Auality of information utilized in the preparation of operating, mainte-nance, test, modification, etc., procedures with respect to the availability of accurate as-built information. Such an assessment should be' based upon a systematic review of the potentially affected safety-related activities and should provide the bases i
for the conclusions drawn. The discussion should also include these activities or systems which can result in the radiation l
release to the environment.
Provide an assessment of and the plans and schedules for correct-ing any deficiencies in issued drawings and engineering documents which have resulted from construction phase changes which are not currently reflected in controlled documents available at the station.
This assessment should address the capability to perform safety-related operations, maintenance and engineering activitics and j
respond to plant emergencies with currently available information.
i Discussion of Unresolved Item (80-09-14) l l
Ths quality of information utilized in preparation of operating, mainte-nance and test procedures during the construction and initial plant startup period was very accurate. This informat19n was verified by several different and-independent formal programs which demonstrated by actual use and test that the safety-related systems were installed and operate as designed. Although emphasis was placed on Category I systems, these programs as described here were-utilized for the test and acceptance of all systems in the plant.
4 The formal proof test and preoperational test programs for BVPS Unit 1 were quite extensive with participation by several independent groups. Proof Test Procedures were prepared by the Architect / Engineer (AE) which verified logic as designed.
These tests were performed by an Advisory Operations Group consisting of AE and_Duquesne Light Comp;ny personnel.
The preopera-tional test program utilized test descriptions prepared by the AE and NSSS supplier to determine the objective of the individual tests, but the operating manual and information from the Operating Group supervisors was utilized in preparing the formal test procedures thus the preoperational test program served to verify the operating precedures.
During the initial construction and plant startup phase, activities were closely followed by the Operating Group supervisors who were assigned in 1971 to prepare ~the operating manual. These supervisors witnessed actual r
equipment-installation and walked down the systems as they were being built.
They were thus able to compara actual installation against the certified drawings. system descriptions and logic diagrams supplied by the AE.
With this information, the system descriptions and operating procedures for the operating manual were prepared.
1 v-
~..
.-,_.-_.-,,,_-,__.-_,..,,_.m,...-
Reply to Notice of Violation Inspection No. 80-09 Page 9 Discussion of Unresolved Item (80-09-14)
The formal equipment and systems turnover program utilized checklists prepared by the Operating Group which verified quality installation of equipment and systems prior to acceptance by the Operating Group. The schematic piping diagrams were certified by independent and joint walkdowns by representatives of the constructor, Advisory Operations and the Operating Group.
Maintenanet Surveillance procedures were prepared from calibration procedures prepared by the AE and from drawings and instructions supplied from the NSSS. This information was used in the original calibration and checkout of the I&C equipment which was then verified during the test pro-grams.
For the period from plant startup to the issuance of Station Engineering Procedure (SEP) 2.3 " Design Change Coordination," all the Category I design changes that have been incorporated into the Station are reflected in updates to both copies of the operating drawings. We will assess by means of a systematic review of all Category I design changes completed during this period to assure that the necessary LP. formation is available to all station groups to complete their applicable input to the activ1 ties described in SEP 2.3.
With the issuance of SEP 2.3, there are provisions for maintaining a controlled file of design change information at the station for use by station personnel in procedure preparation and for updating station draw-ings. This procedure also encores completion of all necessary procedure preparation / revision prior to the station's operational acceptance of design changes.
We do not believe that the unqaantified deficiencies in the accuracy of drawings which may exist will have an effect on the quality of operation and ability to respond to emergency conditions. We believe that the operating drawings needed for the safe operation of the plant and for emergency con-ditions are maintained by the operating staff and are accurate. Prior tc maintenance and modification activities, any needed engineering drawings are checked out for accuracy prior to commencement of the work.
__ _-