ML20202H682

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FOIA Request for Documents Re Mcelhaney V Duquesne Light Co File RI-93-A-0027
ML20202H682
Person / Time
Site: Beaver Valley
Issue date: 09/29/1997
From: Xander K
REED, SMITH, SHAW & MCCLAY
To: Fuhrmeister R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20202H668 List:
References
FOIA-97-387 NUDOCS 9712100341
Download: ML20202H682 (6)
v • d • e


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REED SMml SilAW & McCLAY Nh*

435 SIXTN AVENUE m nem pa PITTS8UROH. PENNSYLVANIA 18219 1666 gw N PaoNe fit asse 412 266 3131

  • uP PAX a14 setJose NWWW muer -e,- e FAX 412 286 3063
  • W 7m M September 29, 1997

. NWPA REhe:8T Cao No: 97 g8L Mr. Roy L. Fuhrmeister DWT _.,_!Q-7-1 7 UNITED STATES NUCLEAR ActICO CC: S md ~

F 9f c ' h REGULATORY COMMISSION 475 Allendale Rosd Kin'g-of-Prussia, PA 19406-1415 Ret McE1haney v. Duquesne Light company Docket Nos. 50-334/50.412 rile No. RI-93-A-0027

Dear Mr. Puhrmeister:

As counsel for Defandant, Duquesne Light Company, we hereby request that the Nuclear Regulatory Commission, pursuant to the Freedom of Information Act, make available copies of the above file. Mr. McElhaney has filed an ADEA suit against our client in the United States District Court for the Western District of Pennsylvania at Civil Action No. 97-1577.

Mr. McElhaney's complaint to the NRC in February of 1993 regarding quality control iscues at the Beaver Valley Power Station, are cited in his Complaint before the United States District Court.

Please keep me informed as to the status of my request.

Thank yoti very much for your assistance.

Very truly yo'1rs, ND -

Y Karen M. Xander Paralegal cci Pamina G. Ewing, Esquire 0712100341 971204 PDR FOIA XANDER97-387 PDR ,,,_,y,,,,

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ALLEGATION MANAGEHENT SYSTEH ALLEGATION NUMBER - RI-93-A-0027 RUN DATE: 02/12/93 DOCKET / FACILITY / UNIT: 05000334 / BEAVER VALLEY 1 / 1 DOCKET / FACILITY / UNIT 05000412 / BEAVER VALLEY 2 /2 DOCKET / FACILITY / UNIT: / /

DOCKET / FACILITY / UNIT: / /

l ACTIVITY TYPES - REACTOR j MATERIAL LICENSES - l 1

FUNCHCdAL AREAS -

OPERATIONS i

l DESCRIPTION - TWO INDIVIDUALS ARE BEING HARRASSED AND INTIMIDATED IN TilAT THEIR PERFORMANCE APPRAISALS WERE UNFAIR, TilEIR STAFFING IS INADEQUATE, AND T!!EY WERE THREATENED BY THEIR MANAGER.

CONCERNS -

1 SOURCE - LICENSEE EMPLOYEE CONFIDENT - NO RECEIVED - 930210 BY - LW ROSSBACl! / RI ACTION OFFICE CONTACT - WJ LAZARUS RESPONSIBLE PGM OFFICE - R VIOLATION SECTION 210 ALLEGED - NO STATUS - OPEN SCllED COMPLETION - 930831 DATE CLOSED -

ALLEGATION SUBSTANTIATED - ALLEGER NOTIFIED -

OI ACTION - OI REPORT NUMBER -

REMARKS , PHONED IN TO RESIDENT OFFICE. INDIVIDUALS RAISED THE ISSUE INTERNAL TO COMPANY 9FEB93. VP INITIATED INVESTIGATION 10FEB93, NOTIFIED RESIDENTS 11FEB93.

SUPPORT OFFICE: RPS-3B, PPS ACTION PENDI!!G: CONVENE PANEL (SAC) (17FEB93)

DOCUMENTATION:

ALLEGER LAST CONTACTED: 10FEB93

REFERENCE:

KEYWORD: QA, H&I SS:U ENTERED SYSTEM - 930212 CLOSED SYSTEM - RECORD CHANGED - 930212 r

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SAul u RECORD or ALLEoAT!ou PANEL DEcrStoNS SITE: h e.# b e p.NEL ATTENDEES:

ALL30ATION NO. bM " #N chai ==a - II) , DumIh1 J

DATE: NMN ~(PanelNo.1$345)_ aranch chief - futi I 4 _

PRIORITY: Nigh Low Section Chief -( AOC) - lC*Wh-41 CONCURRENCE Br. Allemakinn e~ rd f ameg hnschv/

- TO CIASSOUT DO BC SC of Ranrementative -

CONFIDENTIALITY ORANTED: Yes No f othern hett E d.rw bihadd.H,M4r

-(See Allegation Receipt Report)

IS THERE A MARASSMENT/DISCRIMINA't!ON ISSUE: No IF YES,

1) has the individual been informed of the dol process and the need to file a complaint within 30 days Yes No
2) has the individual filed a complaint
  • with dol Yes No
3) has a letter been sent to the complainant seekihg' Yes No any safety concerne ,

IS A CHILLING EFFECT LETTER NARRANTED: Yes No IF YES, HAS IT BEEN SENT Yes No NAS THE LICENSEE RESPONDED-TO THE CHILLING EFFECT I.ETTER: ,

Yes No AgI1ggs' (State each'opecific action, including acknowledgment letter, as well as responsibility and ECD 35EP 3l2

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J TELEPHONE REPORT 3 DATE I$ 34M 'J3 TIME ./O.' '3 0 I FACILITY k m., A 6/a/[cy DOCKETNO.,jp,'lZf,hf2 LICENSEE'SOCCURRENCEIDENTIFICATIONNO.(!FANY) , ,, , l sRIEF SusaECTi- p J g / (g;J,q3,Q___;

DESCRIPTION OF OCCURENCE DEFICIENCY OR INCIDENT: j

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NOTIFICATION RECEIVED BY f x, aug in R0:1 Forn 50 June 74 l

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MAY 41993 l Docket Nos. 50-334 l 50-412 l

. Mr. J. D. Sieber Senior Vice President Nuclear Power Division Duquesce Ught Company Post Office Box 4 Sbippingport, Pennsylvania 15077

Dear Mr. Sieber:

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SUBJECT:

COMBINED INSPECI1ON REPORT NOS. 50-334/934 AND 50-412/93-05 '

. v......., ... -

This refers to the safety lana ~+iaa of maint==== activities WM,by;,Mr. F. L. Bower Power Station Units 1.and 2

of this office from March 29 - Apdl 2,1993, at Beaver Val @Mek Nos.' DPR-66 and

. Shippingpost, Pennsylvania, of activities authorized by NRC T 73 and to the discussions of our findings held by Mr. F. L. Bower of tLis office and Mr. D. Spocrry of your staff at the conclusion of the la=w21on.

Areas important to the health and safety of the public that were examined during this iaea-*taa are described in the NRC Region I Inspection Report enclosed with this letter.

Within these :::reas, the inspection consisted of selective examiantions of procedures and 1

representative records, interviews with personnel, and observations by the MY+:

W.

An adequate system of adctinistrative controls has been satisfactorily implemented for planning and performance of maintenance work. 'Ihe control of troubleshoodng acdvities b Main *=mam has been improved since the implementation of new admialatrative controls for these activities in- 1991. 'these are administrative controls in place for troubleshoodng I

performed by Operations; however, the control and &mm=tation of troubleshoodng under the control of Operations could be improved. Receipt inspection activities were in aonformance wit ~n the related administrative controls; staffing was adequate to support the Gally receipt inspection workload; there was no receipt inepetion backlog; and, no safety mncerns were identified in this area. Apparent procedural conflicts were identified that l

could allow the unwarranted waiving of quality control holdpoints.

Within the scope of this inspection, no significant concerns affecting pubile health and safety, nor any violations of NRC requirements were observed.

OFFICIAL RECORD COPY A:BV9305.FLB G:BV9305.FLB

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Duquesne Light Company No reply to this letter is required. Your a.tp:ranwwith us ur Jhis maner is appreciated.

$incereb, D0pui Si@Dd I5 tee it Betiuhsn la H. Beuenitausen, Chief Operations Blanch Division of Reactor Safety Enclosuit: NRC Region I Combined Inspection Report Nos. 50 334/93 05 and 50-412/93-05 l ocw/ encl:

G. S. 'Ihomas, Vice President,' Nuclear ~ Services *

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D. B. Spoerry, Vice President, Nuclear Operations L. R. Freeland,' General' Manager,' Nuclear Operations Unit.e. ,- .. , , , ., ; .

K. D.' Grada, Manager, Quality. Services' Unit > , - - -

N. R. Tonet, Manager, Nuclear Safety Department H. R. Caldwell, General Superintendent, Nuclear Operations K. Abraham, PAO (2)

Public Document Room (PDR)

Local PubUc Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Comnxmww.lth of Pennsylvania State of Oblo ,, '

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Region I Docket Room (with concurrences)

SRI, Peny, Region III boc w/ enc! (VIA E-MAIL):

W. Butler, NRR

0. Edison, NRR i i

V. McCree, OEDO L. Benenbausen, DRS W. Ruland, DRS/EB SAIE Coordinator ,

R. Temps, DRS SALP Cuvidi svi

  • R. Puhnneister, ORA .

N. Blumberg, DRS .-.

F. Bw, DRS J. Caruso, DItS ' '

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OFFICIAL RBOORD COPY . . A:BV9305.FLB

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0:BV9305.FIE 4

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U. S. NUCLEAR REGULATORY COMMISSION ,'

REGION I Report No. 93 05 Docket Nos. 50 334 50-412

!' Ucense Nos. DPR46 NPF-73 j Ucensee: Duquesne Ught Company Post Office Box 4 I

Shippingpost, Pennsylvania 1507/ -

Facility Name: Beaver Valley Units 1 and 2 ~ ~ ' 7. ,,. , .

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Inspection at: Shl;p=-i 1, h Pennsylvania ll

. .;. . yo i Inspection Conducted: March 29 - April 2,1993 i N. /- /3 3 i fa M ars:

F. L. BbWiir, Reactor 5taghr Date Perfonnance Pmgrams Section Operations Branch, DRS a

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Perfonnance Pmgrams Section

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horman J.41umberg, Chief Ddte /

4 o u. 2. PerW Pmgrams ,Section ,,;, .

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" OpIerations Branch, DRS c

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Inanacetan Summan" 'aspection from Matth 29 - April 2,1993, Ompection Report Nos. ,

50 334/92-05 and 50 412/93-05)

Areas Inspected: An inspection was performed to review areas important to the twalth and safety of the public and to determine if the licensee had adequately implemented their maintaneam program in accordance with regulatory requirements in the areas of caritrol and 1+;" ^ ^'= of troubleet.oodng activities; work planning; gr.ality control of maintenance activities; procurement of matedals for maintenance; and receipt laaMon.

Bandts: 'Ibe inspectors found adequate ad=laiverstive controls were in place for the .

i O;4---" and i C = of Mainaananna Work Requests (MWRs). Prom a review of completed wut pachages, the inspeceors concluded that, in general, the limanaa had adequately iag.knaatad their adadalstrative controls for MWRs (Secdon 2.2). i

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1he impactors neied that good adadalatative contrais have 1 aan amhnd=8 for' ^

trostieshootleg actMeles perfonned by Malanaama 1 bees Mat =tive controis were udseenarny impiamented, isut hoisend inmances wee noted whee t- ' ^ ^'= comu be impmved.1be laat=*=s ntso acted that ed=ial*ative conomis hiive',ioen s established for '

trestleshoodas actMeles personned by operadone; hommer, it sei~oonetaled'"

tmebieshooting perfonned by operadons emid be impmved by logging and documendng the procedmes used to perform the troubleshoodng, docum ating equipment lineup changes, and logging s. b Tects. Spec. aedon arma==aat that is antered and exited (Seadon 2.3). ,

J 1be inspecean detennised that the incensee was in confonnance with admialmative contmis for asceipt inspection actMeles. Staning was adequate to support the dauy receipt inspection worksond; thee was no neosipt inspeedon bacidog; and, no safety concerns were idendSed in the sea of receipt inspeedon (Section 2.5). . . .-.,, , y, ,,

^

. 1he inspm:nors' redof t$dality control interface winimiintesasm ide EdSed concems agedias: (1) unilatend waMas of oc hoidpoints .that may im equired by engineering .

guidelines and 'etmedards w'thout . inidating a procedure change per technical;speciScottons; (2) en guidelines for incinding oc holdpoints into adan-mana work'p- %timay'not. be adequate; (3) the guidance and contmls provided to anow maintananaa supervisor 'to' delete.

i.e:, mark not applicable (N/A), steps in apprmd mal > pmcedums am,limitad; and ~

(4) Maintenance Wut Requests that do not spedfically reference which airetaan of the attached malama==aaa procedure are necessary to' complete the work activity. These concems were identified u an unresolved item (Section 2.6).

An unresolved lean concendag a lionnaan anmmitment to perform an assessment of the '

effectiveness of the' entire Fire Protection Frogram was closed (Secticid 3.0).

O O i.'

DIXAILS -

1.0 PI'RSONS CONTACTED  ;

1 j

Attachment 1 provides a listing of persons contacted duiing the inspection.

2.0 MAINTENANCE IMPLEhENTATION (62700)'

i

! 2.1 Scope An imipeadon was performed to review areas hnportant to the health and safety of the public and to determine if the llewmae had adequately 8mplemented their maintenance program in accordance with regalatory requirements in the areas of work planning; quality control of maintenance activities; gwat of materials for maintenance; and receipt inspection. , .

Additionally, this inspection perforinesi a review of the control and implemeojatigo of tsoubleshoodas activities aandarewt at' Beaver Valley.~nis included reviewingE @ ,, y

! troubleshocting activities performed by the Maintenance Department including *leni,-

.a-*4=t and instrumerdation and controls (IAC) troubleshooting; as well as troubleshooting i

activideiperformedVy operniiss'and other plant organhations.' .m , :: 7:; # ' k.e:p - ,

,, .;.pgj%:T G 2.2 asaine==ame. Controk Weit'4 4^ &W ,". .1,h. 4 +. A "y ~'" ~  % .d a ? ;.n n:.ph,:.c -

2.2.1 Malad*===c* Wort Request Aa=I=ldative Controb r.- ..

Procedmes have been developed by the licassee to provide ad t ninterative controls for.

inninannante activities. %e inspectors reviewed three procedures that relate directly to the, control of maintenance work planning and work performance, NOAP 7.5,- MM 4.5 and MM

- 4.10. De review identified an appropriate system of admlaterative controls establinhad for, .

the planning, performance and d<=mantation of maintanance work performed.

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usinannan,= Work P4ad'(MWR) packages are developed using a computerised k%.-

syndni'.* I1ied.idlifwing'isTlistWabene of the' attributes'that must be considered.w, hest,usipg the'cioniigiuter6ed MWR'systenipwinfe: .W r.mienhv.-- " wa se d m9.iggs@

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  • Plant mode (s) during which repairs should be made and lowest mode during which 3 testing can be performed r -

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  • Whether the stipair involves ' special controls, such as for an IST. pump or. valve, .a,s .

- containment isolation (type C) boundary valve, or equipment qualification

' nis identifies the inspection procedure number used duririg the conduct of this inspection.

1

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  • Applicable Technical Specification IJmiting Conditions for Operations and required completion times
  • Identification of reference documents such as procedures, drawings and technical manuals, etc.
  • Identincation of required supporting forms such as lihed lead and jumper logsheets; post-anale preoperational and operational testing forms; bot work, nannaad space, and are barrier perndts; and squests for clearance (blocking and tassine, ,
  • work permits, security permits, esc. , ..,,

i h inspectors concluded that the admirdttrative proceduren eviewed establish appropriate controls for providing work instructions. Attaramant 2 of procedure MM 4.5 establishes gs == for the level or detan required for work instructions for -=a .wortactivities.

'Ibe aanlaiverative procedmes also ass =hlia contmis that identify the soview and,ap$toval -

requhed to imus the MWR and authorise work to be performed in accordance widine t and MWR.

methods for 'Ihe modifyins inspoo;crs'also the.wak instrootions, noted doommentingthat these procedmes identify the iC; the climpieted i c:stifying as root conse of any related falhae. In genomi, the insp6cdrs)jud emeistaremj' vanni e,ative contress for the devdopment and A == of Mwar" 't.""";*

  • 2.2.2 steview'et comphned cornetin M a e-e work Phekages. . .,. j , ,

'Ibe inspectors reviewed appearimanaly forty canapleted Maintenance Work Packages to verify that the fouowlag attributes had been adequately adantinad and implemanead- Q. ,

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  • 'Ibe procedures specified in the .mintenance phi.p were adequate for the scope of the h performed; , .. .

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  • maquired adednistrative approvals.were the' work,obtained befae

' pingstions

' are psvisions'for.ebtaining approval inun operations when sh systems are runeved from servloe,and ready nbi.itestond.

as wou asiatifyin

-mo.. ,4 av,.: m, service are pienent; x "n:!9:w :.;;: '.; .. , ,.. . ..u.,.,,.,,._. .

  • Pancela==1 testing and calibrations, as necessary, were completed bh,; yeturn equipment to service, and the measming and test equipment uinid was hutined and in calibration; , ,
  • Quatinad' parts and material used were identified and recorded;....a.,.m,. ... ..

l

  • h ia@m and hold points are identified in the procedure and are based on a set of established guidelines, and inspections were performed hi'accordance with 4

procedurerequirements; and y

. - - - . _ _ - , . - _ , . - , . - . . . - , - - . - . - ~ , ~ - - . - _ _ , ,

______________ ___ _._ _ _ ._ _._. y_______.____

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  • The provisions for control of equipment, including lifted leads, jumpers, bypasses, l

and mechanical blocks were identified in the work control procedures.

f I

'Ihe inspectors concluded that the licensee had adequately implemented the . ove listed ]

j j attributes in the sample evaluated and no specific deficiencies were identified. However, the '

inspectors noted several om.wns in aarrp1**iag this review: (1) the Maintenance Work Requests did not specifically refesence which arckiant of the attmehad maint=mam procedure were === mary to complete the work activity; and (2) the exta.sive marking of conspplicable (N/A) procedural steps gave the inspectors some manarn especially when this was done within applicable sections of the maintranam procedure. These concerns are discussed further in sarvinst 2.6 of this report.

i 2.3 Control of Trwebleshooting , ..

.. ~ 4 -

2.3.1 Administrative Contret of Troubleshooting by Malar *=mam

. Paragraph 2.2.1 identified that the linesinaa has' developed procedures to provides

  • ,h j adadalstrative'contrais for ==iat===ar* activities.fA review-was annaicaad 'to deemniner:-
what ad=lalatrative sontrols kre in place to'aaadwi activities to 4 ' 2y and correct ;.+/639 equipment malfunctions, i.e., troubwhaa*ias. In general, the inspectors found that '

troubleshooting performed by the Maintenmane Department, including the awhaaie=1, electrical, and instrumentation and controls (IAC) groups, is controlled by MWRs piecess f and the related adeninistrative controls. Maintanaane Manual Section (MM) 4.5 provides

, guidaliaan for developing hPNR wrk instructions for maintmans activities that require

troutch0 ii; for unknown ccAitions on energized, pressurised, or operating equipment.

'Ibe !=5+M. nyiewed these g@li- to determine their adequacy.

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'Ibe inspectors noted S.a O trouble =haating guidalinan in MM 4.5 are additional giddalines o

provided to the mabttmManner for the evii-1-M of drenitad work instructions for the

  • Instructions" eantian of MWRs. Malataansw~perenel ladicatad that these guidalinam were l '

addeil'tu MM/4.5,gMarcti of 1991FXismnierfof the g@~* provided by MM4.5, j

L Attschment'1?*Luil.d.svuug GuidelinFW"isTs icilows:W::tr:.Fw.chg6 " .

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  • Prior to developing the troubkhaatia: methadology, the planner or maintenanna

supervisor should consult Systems nigia-s, Operations, Maia=1 Spanificatians, .

the PSAR, Vender Manuals,' applicable procedures and drawings, etc.,'to understand the equipment a.A system interactions l

  • ' As applicable, include the following~ln' work instructions to craft personnel:.- t l

I

'E - Notes, cautions'and' prerequisites for the specific task .

  • Steps to record as-found and as-left conditions .
  • Steps to record abnormalities observed during equipment operation
  • Steps to take if abnormal or unexpected conditions are observed

!' O 3 i

6 1 - *- Steps concerning the logging and control of lifu:o leads and jumpers

  • Steps for contmiling measuring and test quipmert
  • Steps to retain mnoved equipment for furtur :.alysis
  • Steps to take if a protective device activates during troubleshooting i
  • When troubla=haneing equipment important to safe and redable operation, an hupact l

eestament should be included that identifies the scope of the tr=>hlad=*ing, the j

j required eqt'ip==at status, the work boundaries, and any potential plant upsets i,

  • Pmvide precautions that foDow-up carrective malataamam outside the scope of the f original MWR should bei perfonned under a separate MWR j

! 'Ibe inspectors found no specific procedural requirement that all troublahaa*iag performed '

iaa with Maiataamaae t i by -iama== must be done using a MWR, but di e

=

l managers indicamd that in general it was policy to have all Maintenance contiomd tmubleshooting perfonned using MWRs. 'Ibc use of the MWR process for l

i tmubk Noting.contened by v.ine- n,* ensues that an the admiristrative contmis applied l to the oevelopment, neview', approval,' perfonnance and dae===entian of work perfctmed by l MWRs are appued to froubleshooting."Ibe'se adminiserneive contmis was decedbed in u :

paragraph 2.2.1 aboiin."We' @Uoiiconcluded that appropriateh --- ~E contmis are j in place for the use of Mainteorane Work Roonests and good gnidalinas have been c :blished for maintan=ar* to develop daenilad tmubleshooting instrucdons to be performed wi'.g MWR controls. It appears that proper implementatian of these adelaistrative controls l

wa.1 provide good contml of tmublakaating activities and an appropriately documented l

Warical reconi of the tacubleshanting' activities perfonned.

l s

2.3.2 RevWir of SignlGe.nnt Tme.b. .leshooting Events 'andactad by IWal=*==na*

'Ibe inspeceors perfarned,a'sesich'.of 9*neae Event Repor'ts (IEts) and licensee Incident l Reports (irs) to identify 'acy'reciEnt '(i.e,Tpost-1988) si@ Mainmamana Department ;

i troubleshooting events thaisindtad in'a plant tripf @v4 safety festme (ESP) actuation, i

significant safety system, degradation..or other, sis s i.e plant event. .,'Ibese searches identified too significant aMar* selated tmublesimoting evenis'tist resuhedin LERs .

l n iis's'tlie adequacy of the controls an'd their

! being anh=Imad Jhese LERs Me reviewed to'Es' La- "= tafgiauhes.h6ating' activities, lperf.ormed by mala . .*==aca

- - . . . . . ,, .,,z , p . ,. ; ,. ,. .y.

l w .c: . w v.s. u . .. .a ^ ",. .

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J IRR 91-G16 00 .- .

. n o n, ~ . . w . .., . . . .n . . ,. .. . , . , . . .

'Ibe first 12R,.91,016 00,'datedJune,$. 1991 ,. 7:.. u ., . .cported that somei *B*,' train temperaturep l switches in the High Energi Iln'e' Break (HEI2)'Dh'Sys%eEfailedjo trip closed as '

j expected during surval11aare testing. 'Ibe'failuie resulted froen jumpers thatwere left in the

~

l circuitry. 'Ihese ju npers Gere left in the' circuitry by ovoingMIMg' efforts that i

had been postponed to obtain repair parts prior to continuing the t'roubleshooting; This 1

i

)

a i

I .

7 troubleshe:xing had been focused on one temperature switcu that was causing spurious "B" train operations.

The intpectors reviewed the troubleshooting MWR (910535) to determine if the trait *--:4ag instructions were appropriate and in conformance with the troubleshooting work instruction development guidance in MM 4.5. The '=:r+:us found the MWR instructions inadequate in that the instructions did not provide steps to record as-found and as-lea conditions nor steps venceTJiig the logging and cor. trol of lifted leads and jumpers.

"Ihese types of steps are requhed by the guidalinan for troubleshooting instructions in MM 4.5. It was also noted that the LER provided more detail ananerning the work "

performed during the troubWag and repair activities than the documentation of completed work found on the complet64 MWR record. Therefore, the lapws concluded that the level of detail contained in the 'Cause of Pailute" and ' Corrective Action" sections '

of the MWR could be imp @.. .

. s.

<.= &

The IER identified corrective actions to improve the administrative control of jumpers during u^ . l'-*-VJiig and maintaanana 'Ibe inspectors noted that the prreadme for the~

control of temporary madificatinne has been revised to provide adequate iristrixtions for '

controningl logging, and tagging jumpers inen11ad by. troubleshooting and 'maintadar*'Y ' ' ' ' '

activities.

r IER 91-024-00 . . . .

The mannad IER, 91024-00, September 4,1991, reported that while Ec-AES+#;g the "B" '

loop Bypass Feedwater Regulating Valve, the valve opened resulting in an m':-

  • of the steam generator. -This event occurred during troubleshooting activities when leads were f relanded to restore the control loop to ' service and an open damand signal to the valve was present.t The lineanae caracluded that the event occurred because the procedme used as gde cc was not written for the plant canditiane established during the~ troubleshooting *

. efforts and it was not written to be perfoimed whilethe valve lwas in service!' M!Wi*rA

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~;w. y;m-y~ :w.pn .,wn w.,,. m.~aum ....

u c.,; aA. w.,am :n

.an. ..

The Lispsuis reviewed the MWR (9l4298)'ts,deitermine if the,troubleW iristriintion.s were appropriate and in conformanbeWthe guidance in MM 4'.5."The inspectoia%*

determinad that the MWR instructioEWere'inadequde inM huowing"sircas: 3'(1)%ehnly,'

~

instructions provided on the MWR were'to check the contreuer/ auto-manual station" sad F repair as naneamry; (2) the instructions did not provide notes, cautions and prerequisites for the teari4 task; and (3) the MWR did not include an impact erstamartt, for troublesho6 ting equip &t important to safe and reliable operation thet identifian the scope of the ~

troublah*ing/the required MJr isititatus,{the work bdiadaries, 'and any potential pla~nt upsets? The troubleshooting gddelineis'in procedure MM 4.5 ~

l reiuire providing thisS*

information in troublesticoting MWRs.1The inenac*ars also noted that the icvel of detail recorded in the "Cause of Failure". and." Corrective Actionf sections could be improved since .

this information can provide an imIsortant historical record. l' S *

2 i

O O 7

1 .

8 i

, 'Ite inspectors further noted that the MWR was originated, developed and approved by the j same maintenance supervisor. Although this is allowed by the licensee's administrative i procedures, the iaeaa *ar considers this to be a poor work practice. From discussions with j licensee maintenance personnel and a review of other MWRs, this does not appear to be a j normal work practice, and it appears to have been done as a result of the emergent nature of this troubleshooting.

l 4

't Additional infonnation concerning this event, the licensee's corrective actions and the l

l resident insperrian staffs review of this LER were dacimwatari in Region I faca~'* ion Report Nos. 50-334/91-17 and 19. . '. .

2.3.3 Review of Mainte===ce Wout Request Packages for Troubleshooting Activities i

l *Ibe inspectors reviewed a =laesari nmple of MWRs to deter nine the effectivengs of the .

l Mainaananna Department's implannantatian of troubleshooting s,iddalinesianaemiaari-fin'

. . .~ , . . . . . .

y y 4,$,

i In general,11t appears that since.the issue of the hal,M seting gindalinen in March.of 1991, the unnamannana department's laiplesneath of these[giddaliaan hafi'liessi' sad is continuing i to improve. :'Ibe inspectors found a nurnber'of ineemanae where the'wailnstructions pmvided a good level of detail and met the guidali provided in procedure MM 4.5.

However, the. inspectors found innantewi inne=== whese the licensee.did not. implement.their

! ' guidelines adequately. 'Ibese areas included: (1)~psoviding an %r level of detail in the j work instructions provided prior to starting work; (2) providing or' docenenting additional work instrarviant, as required by procedure MM 4.16, when work psogresses beyond the ,

i initial instructions provided in the work instructions section of the MWR; and (3) providing l

better dae====wntiaa of the work ancamfiel=d to cesure an appropriately detailed history of

','  :. n ,', m

~ ' ~

l the work done. . . . r $._. ' . ...'..., ..

. r:.... . .= a x.m.d m,u . . ; , .,.,.  ;

j . . . , .

i 2J.4 Ad=dalstrative. Control of Traahle= hooting by Opess. tions

.. . Depnetment

, n . ' ,, ,

Os$Y Y $ , ... .ri. ....$11blooX*,,fl'*;*j;N.u[tf**.*1Y 9*.4 Lhottt '

$ y 'Q :p *.E ,ee j r .- n '

! A review of Operating Manual thwar (OM) 1/2.48.1D was anadM' to iletermma w' hat i adannistrative controls are in place 'for troub' 4-Kpfperfo,edd,bfOpfirkions."[. r '"'"

l 'Ibe %.neview;cf OM 1/2.48.1D identified the folkswing'punmary,'of controls.'

provided for troubleshooting aandar eari.~on'safeity'-related.ei[uipment'under the cognizanomf l

{ '

the Nuclear ShiR Sepesiesc .. ~ f ~ '[ M. ., %.".

l l .

  • 'Ibe Nuclear Shift Supervisor (NSS) shall authorize the exteint of troubleshooting to be perfanned prior to its start and the NSS shall inform affected shift personnel of .

possibic effects that the troubleshooting may tave on'nodria131En't status'pirior to its; L start; i I

j_

  • Trcubleshooting shall be performed by persons who possess adequate qualifications l l

i and does not require detailed stepby-step procedures; i

f I i

5 I l l

1-O n  : .

9 .

r

!

  • Normal precautions from the affected operating procedure . apply;
  • Documentation of component lineup changes is required to asmre proper system i restoration; I

t j * 'Ibe tc uporary installation of jumpers or components shall be controlled by logging F and tagging in accordance with NGAP 7.4; and

  • If troubleshooting is interrupted, the system or wuii,s..=:is to be returned to normal l-i status or left in a safe condition and propeziy blocked and tagged.

ne ia=== ears noted that administrative controls for troub'd+xkg by Operations provide ,

significantly less g=3danne than the administrative controls provided to Maintenance. It was j also noted that these administrative controls lacked g=h concerning the.limitptions for' '

i r.f g plant operations required for troubleshooting activities without detailed'%

./ . * . . . -

procedures.

l - ...;.... s. a,.

i

' f YO(

operators aaa== tag'the practices forl performing'troutdeshooting'activiticsd neser.M =

l Operations persnnnel indicated that troubleshootin'g*'is~ typically performed to id 1'y the H ~

l scope cf work required for a MWR. Prom these dineeiane it appeared that Operations I

. Department policy is that, when possible,' troubleshoot i i i- s W m.ad by using and adhering ng i l to existing operating procedures.- When noncomplex troubleshooting is performed that %

l l

' requires operations that are not covered by an existing procedure, these operations will be

.c l

. performed by licennad operators. '

ne Operations personned interviewed'Indientatthat if traahWag efforts became more J l' @ and canddared actions were not covered by existing procedures, them based on the y individual situation, actions would be,taken to: (1) make a tempo ary chsnge to an =idiag j pucedoie; (2) develop a rev' dasd approvid teniporary operating procedure;;cr> A +J 2 l (3) submit an MWR to maintenance for them to troubW the problem, ne inspectors concle'ded that'this" appears"tobetiiE koditable Mipros'ch for conducting troubleshootingim N j the inspectors rioted that'thi. approach'is not a policy or m.i.sh! 4h j activities; control that ishowever,ey'darnM q= l ilk'e"flGiministrative controls for troubleshooting,M r OM 1/2.48.1D. His lack of formal adminletrative controls for conducting troubicabooting - .

l in the Operations Department is further evaluated below (section 2.3.5) in the review ofi ~

Incident kport No. 2M14..A .eg

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2.3.5 Review of Significant Tronbleshooting..~, . Events Condacted by Operatio w .

I To determine if the Operations Department was complying with their administrative controls

{

for troubleshooting, the inspectors'and reviewed post-1988 significant troubleshooting events j- performed by Operations. One event, that occurred on March 2,1993, was identified for 1

4 1 9  ;

i -

' 10 review. 'Ihis event involved the isolation of the steam generator blow down valves during the troubleshooting of a 130 volt ground on DC bus 2-1. *Ihis troubleshooting event was j documented by the licensee in their Unit 2 Lacidaat Report (IR) No. 2-93-014. 'Ihe licensee i made the required 10 CFR 50.72 report and was drafting a LER as required by 10 CFR i 50.73 during this inspection. 'the IR did not indicate what procedure was being used to i conduct this troubleshooting and did not indicate what other troubtahaatia: actions or methodology had been used prior to the steam generator blowdown isolation.

l ,

l

Based on the plant records available for the inspectors to review, it was not evident if an j approved procedure was used to provide the guidance for performing the tronhtanhanting for i this DC bus ground. Although OM chapter 1/2.48.lD requires dammentatian of switch,
valve and 6
=f-:==t lineup changes made during troubleshooting, the inspectors could not determine all of the lineup chang that were made. Diemaions with Operations personnel l

indimead that procedmes 2OM-39.4.F. G & H provide g@~ for ching Qgrounds j- and would have been used as guldsace for this troubleshooting. 'Ibene personnd aldenoted ~

j that during this type of troubleshooting, drawings and load lists are marked up and used,by' the Control Room to keep track of troublakaating activities, but this dammantatian is ' '

, typically not. maintained as si permanent plant record.

., ,.,, g. c. m. .. u.

. +

$ + % ~ * - - -

g, ,

q, .

! 'the Nuclear ShlR Supervisor's (NSS), Assistant Nuclear Shift SupeMiVs (ANSS),'and the Nudent Control Operator's (NCO) Operating Reports (logs) for Mard 1 - 3,1993, were l reviewed to determine what additianal information was available concerning this .

i l troubleshooting event. M 3a==*: had the following observations ananarning the

dammantatian of troubleshooting

w i

  • No plant record was found that documented all the actions taken to iroubleshoot and l locate the ground. From a review of the logs, the !==+M-s could not de* ermine
- what procedure (s) were being used to search for the ground, nor could it bc . , ,

desennined which beesker'. were being manipulated, and only.some of,the power l

panels that wese being searched for the ground couM be idantiflad. . As repo$ted in

  • Section 2.3.4 above;OM 1/2.48.1D.ladistaa that switch lineup changes agfequired

. -to be dammaatad a.s.b d -e.n ,y.f. 6. w . e..- F e g s n g q d,"

j at.euJh ..: , . . , ,w. .; ,, . .

, , g ( _m,.

l

  • 'Ihe logs indimtad some of the maior equiperent =mai ud='ians t tahm to, search for the gmund, but not all of the logs indimiad that these actions were takenp part ~ of the sesch for the DC bus ground.abe inspectors had to review all three logs Q4SS, l-ANSSiand NCO) to get an understanding of the actions that;were being taken to particular

+ logsearch for the grounddIhe irspectors also noted.that the level o did n'ot remain naneistant from shift to shift. ... n . e.:(,y g ,g.

l i - Both.the NSS log'and the NCO logs reported that the trip, throttle valve for.the AFW l.

pump was closed. *Ihe inspetors noted that the logs did not report why the valve l was closed. 'Ihese log entri:s did not report that a Tech Spec action, statement ,

j n .

I

1 *

" - ***t ,

f 11 '

i j

(3.7.1.2) had been entered. 'the inspectors formd that the . administrative controls for

operating logs, OM chapter 1/2.48.5, require the NSS to log the entry and exit from i all Tech. Spec. action statements, 1

Based on the plant rooords available for the inspectors to review, including the Operating ,

l Logs described above, the inspectors concluded that the documootation of Operation 2 Department controlled troubWag and the Operating reports was weak in the following '

! areas: (1) all the procedures used to perform the troubleshooting were not referenced in 'the i

CPerating logs; (2) logging all the valve, switch, and mmponent lineup ser.s; (3) logging each Tedi. Spec action statarnent that is cataed and exited as required by OM 1/2.48.5A, i and (4) providing a nanniment level of detail in each Operating Report that nwen the -

! ndrninistrative requirements for that nog as identified in OM 1/2.48.5A.

f Prom the review of the operating logs, the inspectors had the following additiaggL obsavations ceca 4.g Maintenmana Department i T-:4#+2 in Operations Depat6aent ,,

l controDed troubleshecting activities: ~ ; i * .

,, , , ,j ,

l t

w ,v e . .

. .w, ., ,,..

i

  • 'Ibe ANSS log reported that the Relay' Crew supported the Operations Department;m l

troubleshooting efforts by .dsg and *iaaniae the ground detervian relay from <

its circuit. It was concluded that this was not the source of the ground.' 'Ibe- -

inspectors found that the work performed by the relay crew, removing and *i=*Hiag the relay, was done at the distdion of the np==*iaae department and was not done with a MWR. 'Ibe '@e' reviewed the ground isolation procedures in OM ?

C L 39.4 and found that removing this relay is not a step in thece procedures. .

j

'Ibe ' 5+:+w found that these proceduro only provides instructions for arwaing and l

clo6 g breakers to identify the portion of the circuit that cantnins the ground.

l-

" '. .ywy,. . , .

  • .On March 3rd; the ANSS reported that I&C was troubleshooting this DC' bus ground
.and the alarni cleared with no' problem identified. 'Ibe NSS log was moreu. e .

., : .. %, .71 t reported that when'an external test lamp was applied to the DC C2 i

^ "' brink @er that thi ground went tiisexo solts.C It reported that IAC subsequea l

that tim ground voltmeter and alarm relay was fnarvinnat 'Ibe ins W M a W the scope of the I&C troubleshooting with permannel from the Maintenanna~

' . ~

j deipartment. 1t wais stated that tids troubleshooting included performing continuity .

checks and was performed under the' direction of Operations and without a MWRs.

! Ibe '.a-r&i again reviewed the ground innistian procedures from OM 4.,,e 39.4 7' 'and found that performing' continuity chcr*n-is not a stepAin the procedure.A i

l

" "Previously noted,~ this procedure only provides instructions for opening and closing

~

! breakers to identify the portion of the circuit that enntains the ground. W..

j The in.r&. note that these are two e-- c-f

  • where troubla*hanting activities ex-ded the i instructions provided in plant procedures. Troubleshooting without detailed step-by-step i procedures is allowed by the Operations Department administrative controls for
troubleshooting in OM 1/2.48.1D. However, this appears to be contrary to. the typical i

i

4 l' n a '

. 12 l approach, described by Operations personnel, to use existing procedures, terr.porarily change
existing procedures or write temporary procedures for troubleshooting activities. No

' administrative control was found that precludes Maintenance personnel from participating in troublahaa*iag activities under the directiot of Operations without the use of a MWR.

l However, the inspectors concluded: (1) that the documentation of Operation Department

controlled troubleshooting was weak and did not meet the adminletrative requiranents j

ent=hlinhad in OM 1/2.48.5A; and (2) implannemtation of the MWR process and the

== ear 4mtad administrative controls for this troublahaatia: activity would have provided l

daenhd work instructions and more complet/darnmentation of the troublesho) ting work i

i m .

s 2.4 - Receipt T- =;+In of Materials for Malataan= Activities The inspectors reviewed thea L "- =h of the on site receipt inspediorf program,and the J

l ~

! material storage and receipt inspection fadlities available at Warehouse No. 22 as part of an

-w-aae'of QC oversight of amih activities. In addifiaa, the inspectors evaluated l

anarwenn identified by ==lataama%d during interviews regarding work delays due to

! unavailability'of material and parts W during previous outages. .

.~ w .

l

'[jg igjg'yjgggd the ggtigg gdpg ggpgy{ggr ggd gygg3] QC Intnectorg '

]

l concerning general activities involving the handling and processing of matrials. 'Ibe i monthly Deficient Material /na- *,laa Itaport" dated March 2,1993, was mM.

l

'Ihis report provides the status of identihd receipt ana~+ian i deficiencies and the status of j requests for support and/or resolution fuorn various site E= *?== The report also trends open deM*= den and hold tags for the past twelve manths. 'Ibe 8nspectors verified that the licensee's conformance with the Quality Services procedures, QSP 15.1 and QSP 15.2, for ~ .

l tagging and controlling Nonconforming Materials was adequate through a review of records

" ^ +' F u-i

, aM a tour of de wW aa' :~u.x  : .

y g +,

In"revie$ag Sis'arita,ithe'.*Mi.had the following' observations and conclusionsc At the 1

time'ofibis liiipection'these was no iaM bacidag isthe receipt inspectics area;WW i

however, a bacidag had previously erietad between Daremher 1992 and March 15, .1993.'

F An additianal QC. inspector has recently been assigned to the receipt =5+fm area fonowinghe~ completion of a cross <paliflhafinn~pr6gramTQCInspector staffing was

adequate to support the daily worldood. In an effort to ensure there are adequate nwnbers of i daa area, i inspectors available to.' cover fluctuating workloads armering in the receipt aa

! managessent is continidag to take steps to cross <[ualify plant QC inspectors to work in j receipt! =i+f-MItecent planningL e.c --tsoch asitaging pacicurement pWa

receipt inspection before ordered parts have been received,'liave e I-r d afbi-y.

Currently there is less emergent work, a better flow of work, and better allocation of.QC

! resources. 'In coniclueion, no safety concerns were identified in the area of receipt inspection.

4 .

3 i

4 1 '

)

l 4

h

O O  : -

13 2.5 Quality Contret and Maintenance Interface ,

'Ihe inspectors performed a review to hudne what quality controls were applied to maintenance imalamentation. ' Ibis review was also conducted to verify that inspection points and holdpoints are identified in work documents and are based on a set of established guidelines. As part of this review the inspectors reviewed the applicable maintenance administrative controls and records of Quality Control (QC) surveillance of maintenance activities. ,

'Ibe ing+-:.:-: reviewed a selected sample of completed daily QC General Inspection Reports.

'lhe guidatinas for moducting these isspecticas are di-enad in Quality Services Procedure, QSP 10.1, Section 3.12. 'Ihese reports damment QC inspector observations and findings .

from oversight of maintenance activities and document completion of the required QC holdpoint # dons. It has been the,QC Department's practice to perfong in pction '

survam- of the nomentine maintramana work activities from start to finish winfthe availahitity of h.yecties resources permit. <*Ihe results of daily QC General In'epeerian Reports == father reviewed and trended in management reports. 'Ibene .ctioss were ' .

viewed by'the ivars'as a positive initiativEto ~ ' '

improve QC oversight,of

~

' ~'

critical

  • *
  • safety"'C#'

N maintenanne acdvides.

As part of this review, the iame*ars questioned the intent of a guidalina in Maintenanne Manual Section 4.1, paragraph VI.D.5.a stated, "QC Supervision shall nodfy Mainaanmane

_ Supervision of any QC holdpoints to be inserted. QC will normally perform independent QC

'""*iaa. In those cams where this is impi.ctical, a q=11fied pewi.si who is not responsible for the work may perform the inspection...." ' Ibis procedme as previously~

written appeared to contradict other *=idia* procedural requiraments regarding,QC '

department oversight of maintenanna activities.1 'Ibe licensee initiated a procedme change request to change the procedme to read, "... Work shall not progress 48,ed a boldpoint until

. QC verificatinn has been performed and a QC signatme obtaland or holdpoint has been" property waived by a QC representative." 'Ibe inspectors noted this procedme change should re clarify and ensme 9:= 'r=y'with,the liresinae's other current: procedural.%quirenunts on1.99.g3:

Q%. l g i. - u  ; .

this = h +J h ; W .; p , .:. x :Af' ? ' 'g.

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2.6 > Quality Contrei Holdpo$ts and Procedural doutrols for .Maine

- s

===nev

n p .- AItivities

. .. e _. .~ ~

This review was conducted to venfy(thaOn=S'-,a holdpoints are identified in work 6.*-

documents and are based on a set of established guidelines. "Ihe In=+: -is C',4 Quality Assmance adenial*ative control procedures, OP-10, QSP-10.6, QSP 5.6, and QSP;10.1/ ~

concerning the use and implementation of QC holdpoints. ' - .: , v . q .. .

During this review, the inanar4ars identified that the methods and controls" established in QSP 10.6, for the unilateral waiving of QC holdpoints, are in apparent conflict with Technical' Specification requirements, and other upper tiered procedures and administrative controls established for making procedure changes. QSP 10.6 was issued as a new procedure, in

4 i

O n -

!- 14 i

! November 1992, to proceduralize guidelines and criteria for Quality Services Supervisors to waive unilaterally QC holdpoints from modification and maintenance procedures. The l

j inspectors concluded that QSP 10.6 offers provisions that if exercised might result in violation (s) of the licensee's controls for making procedure changes. However, the i inspectors found no instances where this provision for unilateral waiving of quality control

holdpoints in procedures had been exercised by the licensee.

I Provisions in QSP 10.6 allow natistaral waiving of QC holdpoint steps in Onsite Safety l

Committee (OSC) approved procedures without1 .is.dag a procedure change. These provisions are in apparent ennflier with the following Tachnical specificatlane ('I3) >

iw4+ r (1) written procedures are established, implemented, and maintained covering l

{ the procedures referenned in Regulatory Guide 1.33 that include maintenance procedures and

. modification work procedures; Q) the OSC reviews applicable procedures; Q) the OSC l m' d procedures reference PIPS and other engineering mandards that require inclusion of applicable mandatary QC holdpoints; and (4) temporary changes to these proc &are initiated using emanhhhad TS M== The nai1=taral waiving of.QC holdpoints as

)-

permitted in QSP 10.6 appears to enantienta a procedme diange but doisiiiot regishe the l

i i

procedure between the controls change controls amahEhad i.,4-M in ~QSP 10.6byand TSTSto@be ,y.] implesnanted

. ,' U. ,1 bis'is s - ' +

3,u t

! Opesations Quality Assurance Procedure, OP-10, "Maintenanna and Modification Pl*==ing,"

is an upper tiesed administrative procedure for pi-lag of safety-related umlatemanna and l '

modification activities. OP-10 requires: (1) the use of approved writhm procedures; Q) the l

use of appropriate inspection and performance testing; Q) that work orders, procedures, and j insta. vh* receive an indapandant review; (4) that mandatary holdpoints be identified on appropriate darnmaats for !=5+ Mans, and these documents shall provide for in==*ian and

) witnessing of critical steps in the progression of work; (5) that procedure cks,a will be i

i prepared, reviewed and approved in the same snanner.as the. original; and (6) that revised work orders will be approved by authority equivalent to that which apinoved the Viiginal .

l work order."In apparent ennflict with these OP-10 requirements described aboIvn,"QSP 10.6 i kilows valistar=1 waiving of QC holdpoints. '. This QSP,10.6. provision aBowing the == Hem!

waiving of QC-boldpoints appears to be a procedure dunge that is madIwith' o ut'following the procedure change controls requhed by OP-10 and Inhaical %= 3MM.The waiving

( of QC boldpoints appears to be ~a procedure change that is not receiving the'same, required review,'and approval as the original procedure. Further, it does not require, approval by an authority equivalent to that which approved the original (i.e., review by,the OSC 'and '

approval by the General Manager of Nuclear Operations). The i=5+ms noted that OP-10

.is a higher tiered adminimerative procedure than QSP-10.6. . . . , , , .

l n "

. r: - .

x ,"

\

be considered Additionally,1QSP ~10.6 aDows nnitateral' waiving of QC holdpoints that l unandatory by R.$=Aeg Design Documents such as; the Plant Inynbtion Process i

Standards (PIPS). The PIPS provide generic engineering standards and guidelines for j specific installation activities that are based on the original design specifications (see j- Attachment I for PIPS reviewed). Each of the individual PIPS has a section specifying i

f

7 O ,'.

15 .

mandatory inspection requirements that are developed into QC Inspection : Plans for incorporation into modification and maintenance work packages. QSP 10.6 allows QC to make procedure changes to delete holdpMats that nury be cortsidered mandatory by .

engineering design documents. 'Ihis is an extension of the conocrn dinssed in the above Paragraph.

QSP 10.6 places a priority on petxzdures by classifying them eitha a priority "A" or "B."

Both types of procedures may be waived by this precedure; however, priority "A" procedures will normally be subject to 100% inspection hequency. He b.pe&6 asked QA management, what the technical basis was for clann:fying procedures in the "A* or "B" category. De inspectors were told that the priority was assigned based on the past history of problems experienced with that type of activity. De L.peciiss were wecerued that this prioritiratian overlooks the requirements established for incorporation of mandatary-

  • holdpoints as di==M gcilessly in the points presented above. ,,

,A.. .

De concerns di-*=ad above regarding unilateral waiving of QC boldpoints were brought to the attention of site management During an interview the Manager of Quality Servicea, he.

Indi= tad that QSP 10.6 was not initiated pi fJy for cost savings benefits but to improve .

safety by dheneg and allocating QC inspection resources to cover the most safety significast work activities. He stated that the authority to waive QC hold points dates back to at least the year 1978 in Quality Assurance Promdures such as OP-11, " Control of Maintenance and Madifimtina " He also noted that before the inananne of QSP 10.6 specific gWa= and.

controls did not exist for waiving of QC hold points. In interviews with several QC f .-

a+si.ss no specific use of this waiver authority was remiled. In addition, the inspector reviewed over forty -:+g-:-M maintenanna work packages and no waivers of QC boldpoints were identified. 4

. . mm ,

De inspectors concluded that the inethods and controls established in QSP 10.6, for the,.. e anitataral waiving of QC holdpoints, are in apparent conflict with Techalmi Wh'iaa,m requiramente, and upper tiered procedures.'- %e inspector did not find any indistiaan that..

the provisions of QSP 10.6 have'been actually used by the licensee.g.However, the,y pecius are concerned that the us of these provisions might result in unwarranted waiving _ofg ,

mandatary QC holdpoints or a violation'oflinaaeae controls for ntaking procedure changes.

De Manager of the Quality Services Unit has agreed to' reevaluate the issues ge- e+1 and take action as appropriate. His item is umesolved paading linenw action to address the .

  • concerns presented above (URI 334 and 412/93-05 01), m

_. : .- .. 4, y L.. .

Procedure QSP 5.6, " Instructions, Procedures and Drawings," provides guidaliaan for . ,

insertion of QC holdpoints into famintenaana work documents. QSP-5.6 states that mandatory QC holdpoints for the verth+iaa of factors affecting quality shall be identified in work documents. QSP 5.6 provides eight guidelines for the adding QC holdpo*mts to maintenance work documents. He inspectors determined that QSP 5.6 does not identify the need to use PIPS or other engineering standards to incorporate QC holdpo'mts in maintenance work ~

documents. Dese engineering standards are used to incorporate mandatory QC holdpoints in

Q Q 16 Modification work packages to ensure that the holdpoints verify conformance to requirements and to assure the quality obtained is at least equivalent to that specified at initial installation.

He inspectors were concerned that the guidelines provided in QSP 5.6 for insertion of QC holdpoints into maintenance work documents were inadequate in that programmatic controls were not established similar to those found for incorporation of QC holdpoints into Madihian Packages. His is especially a concern when performing extensive maintenance activities such as rep 1meement of an equivalent safety related valve that involves establinhad

+3

' engineering standards containing mandatory holdpoints. De Director of Quality Services Inspection and Rxaminatian has agreed to reevaluate the progr===eir controls established for insertion of QC holdpoints in maintr=nne procedures. His item is another example of the is.g&s' concern relative to precedural control of QC holdpoints and is nnneidared part of the previously identified unresolved item (URI 334 and 412/93 0541).

Maintenanne Manual tar +ian 4.16 and procedure QSP 10.1 allow maintannare supervisors to designate the monapplicable steps of a maintenmana work procedure as N/S Whe'n orfly portions of a matchuince procedure needs to be implemanand to g, 42 a task. In reviewing -:-:- ;'r@Mainte,ance Work Packages, the laea~*ws were onnnarred with the limited p'hw and controls provided to maintenance supervisors for applying this authority to mark approved procedure steps N/A. His is especially a enneern when specific step; I within applicable portions of a procedere are marled N/A. Mditinnally, from the review of forty completed Maintenance Work Packages (see report Section 2.2.2 for dernilt) it w's noted that the work instrueriana, in the MWRs reviewed, provided only a narrative description of the work to be accomplished by the referenced procedure. De work instructions did not denote the specific portions of the referenced procedure that were 4 any innennees where required to w-,.L.;; the work task. De laea~*ars did not ' -.3fy nacenery steps were insssly marked N/A in a w-,A ;;l procedure, %e Manager of Maintan=nna Planning and Mminletration has agreed to reevaluate the adequacy of the gv==d- controls established for maintennam supervisors in the use of their N/A authority when applied to maintenance procedures. His item is another example of the inspectors' concern relative to pmcedural controls and is considered part of the previously identified unresolved item (URI 334 and 412/93-05-01).

3.6 OPEN ITEM FOIIDWUP (92701)*

(Closed) Unresolved Itan 50-334/92-16-03 and 50-412/92-11-03 His item dealt with the assessment of the Fire Protection Program (FPP). His item found that the neme*=ments that had been performed were narrow in scope and did not address the entire Fire Protection Program. De report noted that the Supervisor of System Engineering his identifie4the inspection, procedure number tued during the conduct of this s portion of the inspection.

N - -

17 is responsible for assessing the effectiveness of the program and noted that an assessment of the FPP and the staffing to support this assessment was scheduled to be perfonned within the last quarter of 1992.

'Ihe laen~ ears found that an assessment of the FPP was performed by System Eng'meering.

Maintenance hgiaming and Am==t Department memo ND3 MEA:0019, dated February 10,1993, and the ansched " Beaver Valley Power Station Fire Protection Program Assessrnent of Effectiveness for 1992" was reviewed by the iana~ ears. To assess the effectiveness of the entire PPP, System Thp= dug reviewed the following indicators:

(1) Independent audits and inspections; (2) Incident Reports; (3) Equipment Availability; (4) Beaver Valley Power Station response to segulatory issues; (5) Training; (6) personnel iespontibilitico; and (7) Procedures. ' Itis assessment identified programmatic waakaa==a= .

and corrective actiont Schedular commitments for completing the corrective actions were '

identified for some of the cocidve actions. 'Ibe iana~ ears mneluded that.Sysg

"=p-:-ig had performed an adequate amermement of the Fire Protection Program,N therefore, the mneerns identified by this item were addressed and this item is closed. -

4.0 EXIT MEETING .

~

'Ihe inspis,c; met with licensee sepresentatives at the conclusion of the inspection, on April 2,1993, at Beaver Valley. 'Ihe findings of the inspection were periodically discussed ,*

with licensee personnel during the course of the inspection. 'Ibe ia==~

  • ion scope, findings and observations were summarized and dierneeed at that time. At that time the iaea~ ears discussed the Unresolved Item concerning: (1) unilateral waiving of QC holdpoints that may be required by engineering guVdines and standards without !@h:h a procedure change per your techalmi ep irw=*iae: (2) the guidaliaan for including QC haldaaints into maintenance work damments may not to adequate; and (3) the guidance and controls provided to allow .

maintenance supervisors to deicte, i.e., mark not applicable (N/A), steps in approved 2.

maintenanna procedures are limited. 'Ibe personnel in attendance are listed in A**=eh=ac.t 1.

c

. 2 m. ,v Annehments:

1. Persons Contacted
2. Documentation Reviewed G#

G

i..

~

i. ) -

O l 18

- ATTACHMENT 1 PERSONS CONTACTED I Duomne'I laht Comoany J. Baumler, Quality Services Audit and Surveillance Director -

  • Cliff Custer, Director, Ceaaa*=t Ep= --lug
  • S. C. Penner, General Manager, Mainterance Unit

'

  • Larry R. Freeland, General Manager, Nuclear Operations SKen Grada, Manager, QSU l

Mark Kilpatiick, Senior QA Spalist

!

  • Prank J. IMid' Senior I i~aeing Supervisor T. McGee, Chairman, Onsite Safety camminee "T. P. Noonan, General Manager, Nuclear " p=- 4sg and Safety Unit "T%

i.

  • M. Pavlick, Manager, MP&AD L

l E. Peace, Senior C&t "=y==, Mechnical Maintenmana

-

  • Mike Pergar, Director, Quality Services Ta=a~*W & praminatinn

. ' Mark Pettigrew, Qupervisor, System Eg*== >

" .o .c ,

P. ?-M_; Senior Quality Control Inspector '

  • Pred Schuster, BV-2 Operations Manager j.'

i

  • Brian Yah Ii~a*iag hgia - ,

C. Shannon, Receiving and Procurement Program Auditor R. J. Snowden, Quality Control, Maintenance, Refueling & Operations, Supervisor i

  • Dele Spoerry, Vice President, Nucicar Operations -
  • James E. Starr, SwiK4, "npr+-leg Mass.se.asit .

[ Nelson R. Tonet, Manager, Nuclear Safety l

s

  • Ron Zabowski, Director, System Engineer U..h' E+atae N5La benta*nry Commission f

. . . , . c, -

  • P. Sena, Resident Inspector .,,. ;(" - , 7_"

l

  • L. Rossbach, Senior Resident Inspector
  • Denot'es those at the exit meeting held on' April 2,1993.

During the course of this iaan~+ inn, the '@T matacted other members of the lic' Maintenmace, Operations, Technim1, and Quality Assurance department staffs.

O 1

Q ..

19 ATTACIIMENT 2 DOCUMENTATION REVIEW Procedures e- Maintenance Manual, Section 4.1, " Work Order Control," Rev.1, dated December 30,1992 e Maintenance Manual (MM) Section 4.5, " Daily Maintenance Job Planning and Scheduling " Issue 2, Revision 4, dated November 10, 1992 e Maintenance Manual (MM) Section 4.16, ' Performance of Maintenance Procedures," ,

Issue 1, Revision 0, dated November 6,1992 .. .. A e Maintenance Manual, h 4.17, ' Control and Te==we of Maintenance '

Procedures," Revision 2, dated 10/15/92.. ,

e Nuclear "=p= -Mg Admininhative Procedine (NEAP) 4.1, "Pseparation of Data Sheets and Modification Work P*56," Revision 1, dated February 25,1991 e Nuclear Group Administrative Procedure (NGAP) 7.5, "'Ibe Maintawme Work Request," Revision 3, dated December 14,- 1992 e Nuclear Group Adrnini#rative Manual, NGAP 7.7, ' Plant Installation Process Standards," Revision 1, March 26,1993 e Nuclear Group Adininistrative Procedure (NGAP) 8.71, " Quality Services Audit, Survdll**w*, Inspection, Rraminatinn & Assessment Programs," Revision 1 e Nuclear Power Division Administrative Manual (NPDAP) 2.3, 'P tzedure .

Preparation, Review, and Approval,' Revision 4, March 19,1993

  • Oprating Manual Chapter (OM) 1/2.48.1D, ' Conduct of Operations, OrEnnization

- and RP*ihilities of the Operations Group, Operstions Shift Rules of Practice,"

Revision 11 e Operating Manual Chapter (OM) 1/2.48.2C, " Conduct of Operations, Operating Procedures, Adherer.cc and Familiarization to Operating Procedures," Revision 11 e- Operating Manual Chapter (OM) 1/2.48.5A, " Conduct of Operations, Figures and Tables, Logs and Reports," Revision 11 k e Operations QA Procedure (OP) 4, " Design Control," Revision 5, dated May 13, 1991

. n n ,

d 20 e Operations QA Procedure, (OP) 6, " Material Control," Revision 4, dated August 28,1992 e Operations Quality Assu=<e Procedure (OP)-10, " Maintenance and Modification Planning," Revision 2, dated January 4,1991 o Operations Quality Assurance Procedure (OP)-11, " Control of Maintenance and Modification," Revision 3, March 28,1991

  • Plant inentiation Process Standards (PIPS) M06.1, " Category 1 Piping Installation,"

Revision 0.

l e Plant In*11stion Process Standards (PIPS) M03.3, " Pipe Support Installation,"

Revision 2,5/12/92 ..

. . s l e Plant Inen11stian Process Standards (PIPS) M08.3, " Category 1, 2, 3 and F Pressure Boundary Bolting," Revision 1. .

e Plant ine=11stina. Process Standards (PIPS) B02.3, " Cable Tray and Supports,"

Revision 1,6/5/92.

e Quality Service Procedures (QSP) 2.2, "Qi=11 Mon and Certification of QC In==c*ian. Personnel," dated December 23,1992 e Quality Service Procedures (QSP) 5.6, " Instructions, Procedures, and Drawings,"

Revision 2, dated D=W 23,1992 e- Quality Service Procedures (QSP) 10.1, "QC ta@ of Plant Maintenance,"

Rev. 2, dated December 23,1992

  • Quality Services Procedures (QSP) 10.6, "Prioritization of QC Inspections,"-

Revision 0, November 4,1992 e Quality Servke Prwedures (QSP) 15.1, " Control of Naarmforming Materials,

- C+P**, and Parts," Revision 2, dated February 15, 1992 e Quality Service Procedures (QSP) 15.2, " Hold and Reject Tagging Instructions,"

. Revision 3, dated February 15, 1992 e Updated Final Safety Analysis R@ ort (UPSAR), Section 17.2, " Quality Assurance Program Description Operations," Revision 2 i

s

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