ML19347B190
| ML19347B190 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/30/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19347B183 | List: |
| References | |
| 50-334-80-09, 50-334-80-9, NUDOCS 8010010809 | |
| Download: ML19347B190 (4) | |
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O APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted on March 8-April 19, 1980, it appears thct certain of your activities was not conducted in full compliance with the conditions of your NRC License No. DPR-66 as discussed below.
Items A, B, and C are infractions.
Item D is a deficiency.
A.
Technical 5)ecification 6.8.1.c states, in part, " Written procedures shall be establis1ed implemented, and maintained covering the activities refe-renced below:...c. Surveillance and test activities of safety related eguip-ment.
Technical Specification 3/4.3.3.1 specifies, in part, the Radiation Monitoring Instrument Surveillance Recuirements for Containment Purge and Exhaust Monitors (RM-1VS-104A & B) anc Fuel Building Gross Activity Moni-tors (RM-IVS-103A & B), and requires that monthly channel functional tests be performed in Mode 6 (Refueling) and with irradiated fuel in the storage pool or building.
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 inade-quately 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 inadequately 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 configuration at the time of the test.
Existing documentation is inadequate to verify the operability of the equipment with respect to test performance.
(3)
OST 1.43.1, Revision 8, which was required, in part, to verify /202 the operability of equipment modified by Design Change Packages 201 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 r % ystems were placed in operation in January 1980 and required to be operable during fuel handling activities and refueling during the period of January 29-February 23, 1980.
8010010 F09
e 2
(4)
OST 1.43.1, Revision 8,intained in that it was reviewed, approved and as issued originally on March 31, 1980, was further inadequately ma issued in a form which failed to adequately test the operation of all damper / radiation monitor trip functions modified by Design Change Pactage 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 8, and VS-D-5-2.
B.
10 CER 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appro)riate to the circumstances and shall be accomp-lished in accordance wit 1 these instructions procedures, or drawings." The BVPS ESAR, Appendix A.2, Operations Quality Assurance Program, Attachment, endorses the guidance of ANSI N45.2.8, Draft 3, Revision 3 September 1973, SupplementaryqualityAssuranceRequirementsfortheInstallation,Inspec-tion, 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 l
approval which shall include:
- 3) inspect)onsandtestsrequiredtomaintainopera-condition (1
tenance requirements; bilityandqualitydur(ingtheperiodoftemporaryuse.
i QA Procedure No.
OP-11, Control of Maintenance and Modification, Revision 3, Section 11.4 requires, in part, "11.4.1 The station administrative directives and detailed implementing procedures 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 performed and that the acceptability of systems and equipment with regard to inspe,ctions and tests performed is known throughout operations maintenance, modification or refueling...."
Station Administrative Directiv,e No. 5, Equipment 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 temporaryuse(operation)ofthesystemsmodifiedbyDesignChangePackages 201/202 took place on January 19 1980 via a " conditional system release in order to support the Technicai 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.
C.
10 CFR 50, Appendix B Criterion VI states, in part, " Measures shall be establishedtocontroltheissuance,ofdocuments,suchasinstruction, pro-cedures and drawings, including changes thereto, which prescribe all activi-ties affecting quality.
These measures shall assure that documents, includ-ing changes, are reviewed for adequacy and approved for release by authorized
p n
3 personnel and are distributed to and used at the location where the pre-scribed activity is performed." The BVPS FSAR, Appendix A.2, Section A.2.2.6, Document Control, states, in part, "The Operations Quality Assur-ance Program includes provisions for assuring that documents, including changes are reviewed for adecuacy and approve
- or release by authorized personnel and are distributec to and used at the location where the pre-scribed 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 established to control the issuance review, approval, distribution, and use of documents such as instructions, procedures and drawings which prescribe activities affecting quality.
Changes to these 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 per-forming the activity.
(c) Coordination and control of interface documents.
(d) Ascertaining that proper documents are being used....
8.3.3 The fol-lowing requirements are to be included to assure effective implementation of the document control system:
...(c) Release and distribution of infor-mation 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 application...." QA Procedure OP-4, Station Design Control, Revision 6, Section 4.6.2, states, in part,
"...When pre-operational testing is conplete and test results are approved, the Station Superintendent shall update the station file with the as-built drawings and document...."
Contrary to the above, with respect to Design Change Package 201/202,ade-quate 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 reasonably 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 prepared without benefit of the controlled information formally trans-mitted to the station.
Station and control room controlled drawing files contained obsolete drawings concerning-systems modified and p operationally tested as part of DCP 201/202 and which were required to be operable by Techni-cal Specifications.
The following elementary electrical diagrams are examples of such drawings which were transmitted to the station via Controlled Document Transmittal Sheet No. DCP 201/202-46, dated March 5, 1980 and not incorportted into station files:
8700-RE-21-MQ, Fuel Building Ventilation, Revision IB-6 8700-RE-21-MS, Leak Collection Ventilation, Revision 1A-3 W
=
4 i
8700-RE-21-MH, Purge & Exhaust Ventilation, Revision 1B-4 On April 11, 1980, the control room controlled drawing files contained Revision 1 dated November 10, 1976 for each of the drawings above.
The as-built drawings for the modifications such as those listed above were not received by the station 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 indi-cate that the drawings transmitted had not yet received final engineer-ing checking.
D.
10 CFR 50, Appendix B, Criterion XII, states, "M osures shall be estab-lished to assure that tools, gages, instruments, and other measuring and test devices used in activities affecting, quality are properly controlled, calibrated,andadjustedatspecifiedperiodstomaintainaccuracywithin necessary limits." The BVPS FSAR, Appendix A.2, Section A.2, Section i
A.2.2,12, Control of Measuring and Test Equipment, states, in part, "The j
Operations Quality Assurance Program establishes measures to assure that tools, ties affecting quality are properly controlledgages, instruments and ot activi calibrated, and djusted at specified periods or prior to tuse to malntain accuracy within necessary limits.
Specific procedures shall include the identification of I
the calibration technique, the calibration frequency, and the method estab-lished for the tagging of measuring devices to positively indicate their status...."
QA Procedure No. OP-12, Control of Measuring and Test Equip-ment, Revision 3, states, in part, "12.2.1 Station administrative direc-tives and/or detailed implementing procedures shall be prepared to assure that measuring and testing devices are properly identified, controlled, calibratedandadjustedatspecifiedperiodsorpriortoissuetomaintain accuracy within necessary limits.
Such procedures shall include:
- a. Cali-bration frequency.
- b. Identification of calibration technique.
- c. Method of tagging to indicate a devices status...."
Contrary to the above on March 24, 1980, dial indicators utilized in accord-ance with Corrective Maintenance Procedure No. CMP-1-44VS-E-4B-1M, 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 acceptance criteria for coupling alignment on the safety-related compressors.
Additionally, the BVPS Maintenance Manual, Chapter 1, Section F, Control and Calibration of Measuring and Test Equipment does not establish or implement calibration or control measures for dial indicator devices.
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