ML20207B235

Insp Rept 50-334/86-23 on 861006-10.Violation Noted:Failure to Identify Safety Requirements in Maint Surveillance Procedure & Failure to Implement Requirements While Working on safety-related Batteries

ML20207B235
Person / Time
Site:	Beaver Valley
Issue date:	10/31/1986
From:	Finkel A, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207B198	List: ML20207B194 ML20207B205 ML20207B235
References
50-334-86-23, NUDOCS 8611110546
Download: ML20207B235 (8)

See also: IR 05000334/1986023

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U.S. NUCLEAR ~ REGULATORY COMMISSION

REGION I

Report No. 50-334/86-23

. Docket No. 50-334

License No. DPR-66

Licensee: Duquesne Light Company '

Post Office Box 4

Shippingport, Pennsylvania 15077

Facility Name: Beaver Valley Power Station, Unit 1

Inspection At: Shippingport, Pennsylvania

Inspection Conducted: October 6-10, 1986

Inspectors: b N h~v i hm so/3r / M

A. Unkel, Le~ad Reactor Engineer U date.

Approved by: N' ##l3#

J. Johnson, Chief, Operational date

Programs Section, Operations Branch, DRS

Inspection Summary: Routine, unannounced inspection on October 6-10, 1986

(Inspection Report 50-334/86-23)

Areas Inspected: Maintenance program and procedures, licensee action on

licensee event reports and quality assurance / quality control interfaces.

l Results: One violation was identified: failure to identify safety requirements

in the Maintenance Surveillance Procedure (MSP), and failure to implement these

l requirements while working on the safety-related batteries.

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. Details

1.0 Persons Contacted

Duquesne Light Company (DLCo.)

• H. Caldwell, Director, Site Instrumentation and Control

• C, Ewing, Manager, Quality Assurance

• R. Hansen, Director of Site Maintenance

• D. Hunkle, Director, Quality Assurance Operations

• A. Mizia, Supervisor, Quality Assurance Operations

• M. Pergar, Quality Control Supervisor

< *D. Roman, Supervisor, Quality Assurance Maintenance

• B. Sipecak, Engineering

• J. Sieber, Manager, Nuclear Safety and Licensing

United States Nuclear Regulatory Commission

• W. Tro.skoski, Senior Resident Inspector

The inspector also held discussions with managers, supervisors and other

licensee employees during the course of the inspection, including

operations, technical and administrative personnel.

• Denotes those present at the e'xit meeting on October 10, 1986.

, -2.0 Maintenance and Instrumentation and Control Organization

2.1 Administrative Controls

The inspector reviewed and evaluated the licensee's program control- ,

ling safety-related maintenance and I&C activities to assess whether

the administrative controls established were corsistent with the

plant Technical Specifications (TS), Regulatory Guide 1.33, ANSI

1 N18.7 and 10 CFR 50 Appendix B.

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The Maintenance and Instrumentation Directors are responsible for the

overall conduct of maintenance activities at the site. The directors'

report to the Unit 1 Station Manager.

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The Maintenance Work Request (MWR) is used for tracking, trending and

control of maintenance activities by both the Maintenance and the I&C

supervisors. The planning groups under both supervisors plan and

coordinate the activities that are to be performed by the mechanical,

electrical and I&C craft and update the MWR's when the tasks are

completed. Both preventive and corrective work orders are generated

by the MWR's as well as providing completed work order status data.

The review and approval of the Maintenance Work Request is performed

by the Maintenance and I&C supervisors to ensure that the operability

and maintainability of a designated system before and after mainte-

nance is not impaired.

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The inspector's review of selected MWR's verified that the Technical

Specification requirements-for both preventive and corrective mainte-

nance were identified and that the maintenance staff was complying

with the listed scheduled dates.

No violations were identified.

3.0 Maintenance and Instrumentation and Control Activities

3.1 Program Implementation

The inspector held discussions with the maintenance and I&C super-

visors, as well as directors in technical functions, and quality

assurance to evaluate controls in place to identify, schedule, track

and document-preventive and corrective maintenance.

The Maintenance Work Request Form, provides the following type of

information:

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-A component deta base containing equipment nameplate data, TS

schedules and maintenance status;

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Storage of maintenance and I&C history by task, component and

system;

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Identification lof maintenance backlog, priorities and approval

delays; and

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Scheduling of Preventive and Corrective Maintenance tasks and

Technical Specification surveillances.

The inspector verified that the MWR form documents the above

outputs.

No violations were identified.

3.2 Documentation Review and Equipment Inspected

The inspector reviewed records including MWR's of selected safety-

related eauf pment to verify that the following subject areas were

controlled as required by TS and the Quality Assurance Program:

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Required administrative approvals were obtained prior to

initiation of work;

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Appropriate approved procedures, instructions and/or drawings

were used;

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Post maintenance testing was required prior to returning

equipment to service;

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Hold points were appropriately identified and implemented;

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Qualified test equipment and tools used were identified;

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Procedures and appropriate data sheets were properly completed;

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Acceptance criteria identified and complied with; and

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Records were assembled, stored and retrievable as part of the

maintenance and I&C history.

During the course of'the above verification process the inspector

inspected and made observations'of the following in progress

maintenance and I&C activities:

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Preparation for inspection of the Laundry and Containment Shower

Discharge Flow Loop Valve FLW103, Maintenance Surveillance

Procedure (MSP) 17.05 and,.

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Maintenance Surveillance Procedure (MSP) 39.02, Revision 24,

July 2, 1986, Battery No. 2 Test Inspection.

During the testing of the No. 2 battery the licensee's technician

recording the battery parameters had a metal chain hanging from his

neck, a metal watch and band, a group of keys hanging in the rear of

his belt and a metal belt.

When the inspector questioned the technician regarding the appro-

priai.eness of wearing metal objects, the technician removed the metal

or placed it such that the equipment would not be affected. The

Precautions and Limitations sections of the procedure did not speci-

fically define the conditions that should be used in testing of this

type of equipment. Instead of a specific requirement the procedure

had the following general statement:

" Ensure that the applicable. safety precautions of the Duquesne Light

Company Accident Prevention Manual are followed throughout this

procedure". This manual is a general employee information document.

To determine if this condition (lack of specific precautions) existed

in other maintenance procedures the inspector randomly selected the

following MSP's for review:

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MSP 39.03, 04, 05 and 08, Battery Testing and Inspection,

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MSP 43.09, Revision 5, June 5, 1986, Radiation Area

Monitor-RM-RM2158, Containment Gas Calibration

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MSP 21.19, Revision 12, May 20, 1986, P-474 1A Steam-line

Pressure (Loop 1) Protection-Channel 11 Calibration,

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MSP 1.5, Revision 30, July 24,1986, Reactor Protection Logic

System Train"B" 31-Monthly Test, and

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MSP 2.04, Revision 28, July 30,1986, Power Range Neutron Flux

Channel, N-N142, Quarterly Calibration.

In each of the listed MSP's, the wording in MSP 39.02 is also listed

in these documents. It appears that the MSP procedures do not have

specific precautions to protect the safety-related equipment identi-

fied in the procedures.

The failure to prescribe and implement specific precautions in the

Accident Prevention Manual prohibiting the wearing of metal objects

to protect the safety-related battery equipment during testing is a

violation (50-334/86-23-01).

4.0 Quality Assurance Audits

The licensee's audit group has performed two recent audits in the mainte-

nance and I&C area for 1986. However, as of this inspection period the

reports have not been completed or reviewed by licensee management and are

scheduled for issuance during the first part of November, 1986.

The inspector reviewed the maintenance audits that were performed during 1985.

The inspector selected the following audits for evaluation:

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Audit BV-1-85-11, June 11 - July 1, 1985, and

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Audit BV-1-85-36, September 30 - October 10, 1985.

4.1 Audit BV-1-85-11, June 11-July 1, 1985

The purpose of the audit was to evaluate the welding requirements

applicable to the Mechanical group and the control of Measuring and

Test Equipment in the I&C, Mechanical and Electrical Maintenance

Groups. Areas reviewed during the audit included calibration and

control of Measuring and Test Equipment, welding and procedure

control.

The audit inspection checklist that was prepared by the audit group

was developed from the insurers (ANI/MAELU) recommended engineering

inspection criteria document, section 10, Revision 2. It is a

complete and thorough check-list with the exception that a technical

evaluation of existing procedures is not included.

4.2 Audit BV-1-85-36, September 30-October' 10, 1985

The purpose of this audit was to evaluate the maintenance groups

compliance to requirements delineated in the conduct of the Mainte-

nance Manual, Station Administrative Procedures and the Nuclear

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Division-Directives. Areas reviewed during the audit included:

, ' Maintenance Work Request (MWR's), hydrostatic testing, housekeeping,

relay testing, dispositions of materials, control of procedures, and

load handling.

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The audit l findings and status are maintained in the audit Follow-Up

Report System (FRS). The report identifies the Audit No., Findings,

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Response to Findings, Comments, and History of Audit Findings. A

review by the inspector indicated that answers were received in a

reasonable length of time and that corrective action to resolve the

, findings was adequate for'the selected sample.

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4.3 Qualification of Auditors

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The inspector reviewed the-licensee position regarding on the use of

technical specialists in performing QA Audits. The licensee stated

that the quality. assurance unit performs audits to assess the compli--

ance to existing approved procedures and that the technical adequacy

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of these procedures is assessed during their initial review and

approval. Using this concept the licensee rarely uses technical

specialists to accomplish or support the auditing of the quality

assurance program at this. site.

It is not clear that the requirements of 10 CFR 50, Appendix B,

j Criterion XVIII, to evaluate the effectiveness of the quality assu--

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rance program are met without including the adequacy of the procedure

being audited.

This item is considered unresolved pending further NRC review of the

licensee's audit program for this site. (50-336/86-23-02).

5.0 License Event Report (LER)

To assure that the licensee's LER program is in compliance with the

t requirements of 10 CFR 50.73, Licensee Event Reporting System, " Reportable

i Events," the inspector selected the following LER for review and evalua-

l tion:

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LER-86-005-00, Inoperable Filter Bank Sprinkler Nozzles. A test to

verify the operation of Train "A" of the Main Charcoal Filter Bank

Fire Suppression Sprinkle System was in progress. Forty-Five of the

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ninety sprinkler nozzles were found to be obstructed by particles of

a substance later identified to be charcoal.

During the inspection of the nozzles the licensee established that the

major blockage to flow of water was foreign material on the outside of the

nozzle with some material identified inside the nozzle. The original LER

had some errors that are to be addressed in a re-submittal that the

i licensee plans to provide. This event is being followed and tracked as

item No. 50-334/86-15-03. The LER will be reviewed by the NRC during a

future inspection.

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6.0 . Seismic Monitoring Instrumentation System

The inspector reviewed the seismic monitoring instrumentation data and

hardware installation for compliance with the criteria of 10 CFR 100,

Appendix A, VI (a)-(3) " Required Seismic Instrumentation," Regulatory

Guide 1.12 " Nuclear Power Plant Instrumentation for Earthquakes," and the

facility Technical Specification (TS) table 4.3-4,

6.1 Seismic Instrumentation and Control Procedures

The seismic monitoring instrumentation surveillance requirements are

listed in the TS table 4.3-4. A review of the data associated with

functional testing of the instrumentation and sensors was selected

by the inspector on a random basis and is listed below:

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Monthly testing channels checks,

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Eighteen month calibration of the Time History Accelerographs,

Triaxial Peak Accelographs, Triaxial Seismic Switches and

Response Spectrum Recorders.

In reviewing this test documentation the inspector verified that the

equipment met the requirements of the Maintenance Surveillance Proce-

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dure (MSP) 45.03, Revision 7, Seismic Monitoring SMA-3/SMP-1 Calibra-

tion which was written to implement TS paragraphs 4.3.3.3.1 and 4.3.3.3.2.

6.1.1 Response Spectrum Recorder (RSR)

The 18 month data for the RSR located at the Containment

Foundation, the Top Floor of the Auxiliary Building and the

N.W. Corner of Control Room is sent to 'Endahl Enterprises

for review. In a letter of July 2,1986 the consultant

approved the test data and certified the equipment to be

operable and within the design specification for th' site.

6.1.2 Seismic Equipment Installation

In verifying the seismic instrumentation installation and

location as listed in the Technical Specification, page 3/4 3-39,

the inspector selected the Control Room Seismic Panel, the

Top Floor of the Auxiliary Building and the N.W. Corner of

the Control Room. A review of the equipment history records

and test results indicated that the maintenance records

were within the TS requirements.

No inadequacies were identified during this review.

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7.0 Unresolved Items

Unresolved item are matters about which more information is required in

order to ascertain whether they are acceptable items, or violations.

Unresolved items identified during this inspection are discussed in

paragraphs 4.0 and 5.0.

8.0 Exit Meeting-

The inspector met with licensee and contractor representatives (denoted

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in paragraph 1) at the conclusion of the inspection on October 10, 1986.

The inspector summarized the scope and findings of the inspection as

described in this report.

At no time during the inspection was written material provided to the

licensee by the inspectors.

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