Text

Insp Rept 50-412/86-36 on 861117-21.No Violation Noted. Major Areas Inspected:Qa Program for Preoperational Testing & Followup of Licensee Response to Generic Ltr 83-28
	ML20211Q319
Person / Time
Site:	Beaver Valley
Issue date:	12/09/1986
From:	Eapen P, Hunter J, Napuda G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20211Q204	List: ML20211Q199; ML20211Q319;
References
	50-412-86-36, GL-83-28, NUDOCS 8612190239
	Download: ML20211Q319 (9)
	v • d • e

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U.S. NUCLEAR REGULATORY COMMISSION

l REGION I

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Report No. 50-412/86-36

Docket No.- 50-412

License No. CPPR-105

Licensee: Duquesne Light Company

Post Office Box 4

. Shippingport, Pennsylvania 15077

! Facility Name: Beaver Valley, Power Station, Unit 2

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Inspection At: Shippingport, PA

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Inspection Conducted: November 17-21, 1986

Inspectors: #4 /2./3 d

G.tNapuda, tead Reactor Engineer Aat(

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J./unter, R4 actor Engineer

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Approved by: -

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Dr. P. K. Eapen, Chief, Quality Assurance

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Section, 08, DRS

Inspection Summary: Inspection on November 17-21, 1986 (Report No. 50-412/

86-36). Routine unannounced inspection of the Quality Assurance Program for

pre-operational testing and followup of licensee response to Generic Letter 83-28 (Salem ATWS Event).

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i Results: No violations were identified.

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DETAILS

1. Persons Contacted

Duquesne Light Company (DLC)

A. W. Crevasse, QA Manager

H. J. Daugherty, Director, Systems Testing

S. C. Fenner, Director, Quality Control

J. Godleski, Senior Test Engineer

E. J. Horvath, Senior Project Electrical Engineer

D. C. Hunkele, Director, Operations QA

J. D. Johns, Supervisor, QA Surveillance

C. S. Majumdar, Assistant Director, Site Quality Control

T. P. Noonan, Superintendent, Operations and Maintenance

L. M. Rabenau, Compliance Engineer

G. Wargo, Assistant Director, Site Quality Control

R. J. Swiderski, Startup Manager

L. P. Williams, Director, Startup

R. G. Williams, Systems Software Supervisor

Stone and Webster Engineering Corporation (SWEC)

R. C. Wittschen, Licensing Engineer

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United States Nuclear Regulatory Commission (USNRC)

A. A. Asars, Resident Inspector

L. E. Briggs, Lead Reactor Engineer

H. F. VanKessel, Reactor Engineer

C. H. Woodard, Reactor Engineer

The inspectors also contacted other administrative and technical licensee

personnel during the course of the inspection.

Attended exit meeting held November 31, 1986.

2. Previously Identified Items

(Closed) Unresolved Item (85-26-03): Independent verification of accept-

able cleanness of systems flushed during Proof Test Phase activities.

Licensee management assigned the responsibility for independent verifi-

cation of cleanness criteria for flushed systems and other cleaning

programs to the Operations Section. This responsibility is delineated in

Startup Manual (SUM) Chapter 5.11.C.4 and requires that an Independent

Cleanness Verification Group be established. SUM Chapter 3.4.17 details

the manner in which the cleanness verification will be accomplished and

documented. Also, the QA Surveillance group has continued to monitor

flushing activities.

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(Closed) Unresolved Item (83-02-04): Acceptability of sampling plan for '

re-inspection of installed - shims. The licensee decided to use Military i

i Standard 105D, which is an industry recognized sampling plan, for the , "

re-inspection of shims installed in various supports. The following are ,t

pertinent features of the sampling re-inspection effort by QA/QC: i;,f

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an A0QL (Average Outgoing Quality Level) eq'ual to 1%;

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designation of supports in a given building as one lot ( t'cb" 1 ',$ f -

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sample size for the estimated population of each lot (building); '

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acceptance / rejection numbers for the double sample plan used; '

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attributes inspected including detailed acceptance'ecriteria and

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documentation of each inspection including descriptio,n *

of unsatis- ^,

factory conditions. '- f J( -

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It was noted that when the number of identified defectives resulted if the

rejection of a lot the licensee did a 100% re-inspectiori,of'that let as ',f .,

dictated by the sampling plan. Also, all identified defective condit.kns '

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,. were corrected. Additionally, the same sampling plan and techniques,/ wire

j used for re-inspection of installed Hilti Bolts. t/"

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Based on the above, this item is closed. ' "

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3. Salem ATWS Events, Generic Letter 83-28 Followup

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The reactor trip system, as part of the reactor protection system, is ( ',;

fundamental to reactor safety for all nuclear power reactor designs.

Transient and accident analyses are predicated on the assumption tFat the

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reactor trip system will automatically initiate reactivity control systems

on demand to assure that fuel design limits are not exceeded. The design

and regulatory philosophies for attaining the high reliability required of - /

the reactor trip system have been primarily based on the use of redund- / ,

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ancy, periodic testing, and quality assurance. j '

In February 1983 the Salem Nuclear Power Station experienced two failures

of the reactor trip system on demand. Regulatory and inc'ustry task forces /

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were formed to determine the safety significance and generic implications / *

3 of the events. Based on these findings, certain actions were r'equired ,of -

all licensecs. These actions, transmitted in Generic Letter 43-28, fell ,

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into four areas: /,

(1) post-trip review; <

(2) equipment classification and vendor interface;

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I (3) post-maintenance testing; and ,

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(4) reactor trip system reliability improvements. '

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By a letter dated March 30, 1984, Duquesne Light Company (DLC) described ,

their planned actions regarding the above areas for Beaver Valley Power ~

Station, Unit 2 (BVPS-2). The inspector reviewed the adequacy of the

licensee's actions for the following items by reviewing the . documents

listed in Attachment A with cognizant personnel,

a. Actions 3.1.1 and 3.1'.2, Post-Maintenance Testing (Reactor Trip

System Components)

Position

Licensees and applicants shall submit the results of their review of

test and maintenance procedures and Technical Specifications to

assure that post-maintenance operability testing of safety-related

components in the reactor trip system (RTS) is required to be

conducted and that the testing demonstrates that the equipment is

capable of performing ,its safety functions before being returned to

service.

Licensees and applicants, shall submit the results of their check of

vendor and engineering recommendations (regarding safety-related

components in the RTS) to ensure that any appropriate test guidance

is included in the test and maintenance procedures or the Technical

Specifications, where required.

Actions 3.2.1 and 3.2.2, Post-Maintenance Testing (All Other Safety

Related Components)

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Position

Licensees and applicants shall submit a report documenting the

extending of test and maintenance procedures and Technical Specif-

ications review to assure that post-maintenance operability testing

of all safety-related equipment is required to be conducted and that

the testing demonstrates that the equipment is capable of performing

its safety functions before being returned to service.

Licensees and applicants shall submit the results of their check of

vendor and engineering recommerdat' ions '(all other. safety-related

components) to ensure that any appropriate test guitlance is included

in the test and maintenance procedures or the Techt,'ical Specifica-

tions, where required.

Evaluation

. The licensee's requirements for post-maintenance operability testing

are found in the Beaver Valley Power Station Operating Manual 1/2,

Chapter 48 and Site Administrative Procedure 3D, "The Maintenance

Work Request (MWR)", used to control the conduct of maintenance. The

procedures require the Operations , Group to review the maintenance

requests prior to the start of work and following the completion of

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$ work to ' determine what post-maintenance operability testing is

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returning the equipment to service. The. post-maintenance operability

testing must be performed using approved written procedures when

i required 'to demonstrate operability as defined in the Technical

Specifications.

Since all safety related work is required to be performed using an

MWR, there is assurance that post-maintenance testing will be

performed and then reviewed by the Operations Department to verify

that each component will perform its intended safety function before

being returned to service.

4i The licensee is incorporating vendor; and engineering recommendations

for safety-related equipment (including the RTS components) into the

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procedures and Technical Specifications as they are written.

information used in developing the procedures is stated in the

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reference section of the procedure.

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Startup Manual Chapter 2.2, " Regulatory / Technical Information

Management", provides instructions for processing Regulatory and

Technical Information documents to assure distribution, review and

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evaluation to determine applicability for incorporation into affected

procedures. The licensee, . during ' +.he operations phase, will

% implement SAP-24, " Correspondence Coerol", and various subtier

procedures to provide controls for the' distribution, evaluation and

followup of documents containing safety-related vendor, industry and

site generated information. Licensee procedures will also be

reviewed every two years to insure that the appropriate vender

, technical and technical specification test guidance has been

incorporated.

Conclusion

Based on the above, the inspector telncludes that the licensee's

actions are consistent with the NRC staff positions for Actions

3.1.1, 3.1.2, 3.2.1 and 3.2.2 of Generic Letter 83-28.

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M b. Action 4.5.1, Reactor Trip System Reliability (System Functional

' Testing)

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Position

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On-line functional testing of the reactor trip system, including

independent testing of the diverse trip features, shall be performed

on all plants. The df verse trip features to be tested include the

breaker undervoltage and shunt trip features on Westinghouse, B&W and

CE plants.

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Evaluation

The licensee will perform bi-monthly on-line functional testing of

the Reactor Protection Logic System including independent testing of

the diverse trip features. Procedures 2MSP-1.04I and 2MSP-1.05-I

provide for functional testing of the undervoltage trip attachment

but do not currently address independent testing of the shunt trip

attachment. The licensee is reviewing the procedures used to conduct

the independent on-line functional testing of the diverse reactor

trip features for Unit 1. The independent functional testing of the

shunt trip attachment will either be added to the existing Unit 2

procedures or new procedures will be develoyd using the Unit 1

procedures as a reference.

Based on the above, the inspector concludec that the licensee's

actions are consistent with the NRC staff position for Action 4.5.1

of Generic Letter 83-28, with the exception of the independent

testing of shunt trip attachment. The Licensee's procedure for

testing the shunt trip attachment will be reviewed in a future

NRC inspection.

4. QA/QC Interface and Overview Activities

The procedures listed in Attachment A were reviewed, discussions and

interviews were held with management and personnel, and various activity

logs and records were examined to evaluate the implementation of QA

Program responsibilities by the Quality Assurance Unit.

4.1 Organization

The licensee has initiated the transition of the existing QA/QC

groups into the organizational configuration planned for the opera-

tion of two units during the course of this inspection. Accordingly,

the Site QC (SQC), and Test QC (TQC) groups now report to the

Director, Operations QC; and the QA Surveillance group now reports to

the Director, Operations QA. Supervisory incumbents and staffing

remain the same but changes are anticipated as the complexion of

activities evolve.

The resumes of the QA Surveillance staff were reviewed and interviews

conducted with selected individuals. It was determined that all

exceeded the basic requirements for their positions, and those inter-

viewed were knowledgeable with respect to their duties.

4.2 Implementation

Site QC (SQC) becomes retoonsible for any inspections when the Start-

up Group (SUG) returns custody of a component / system to construction

forces for repair or rework. The assurance of SQC involvement is by

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the issuance of a Work Authorization Request (WAR), Request for

Inspection by the work forces, work listing for " Electrical Tickets",

in process inspection points previously established in work

procedures, Open Item listings and/or a Nonconformance and Deficiency

(N&D) Report. Also, the supervisors and lead inspectors have day-

to-day contact with work foremen.

Test QC (TQC) is responsible for the inspection of work done by the

SUG forces. This is assured because work can be done only when a

Startup Work Request (SWR) is issued and each SWR is reviewed by an

engineer within this group and appropriate inspection points are

established. An Inspection Report (essentially a checklist with

acceptance criteria) is developed and forwarded to the SVG with the

reviewed SWR. Tracking of issued SWRs is by a programmed Personal

Computer assigned to the group.

The QC Surveillance group that monitors housekeeping, re-installation

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of supports, etc. , is controlled administratively by TQC. Inspection

coverage is on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day and seven day a week basis. The

engineering aspect of TQC is provided 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months a day and seven days a

week. This TQC schedule was initiated in June,1986.

The QA Surveillance group is responsible for monitoring the adminis-

trative aspects of pre-operational testing and the "turnback" work

not addressed by SQC or TQC. Test procedures and the testing

schedule are formally distributed to this group for review. QA

involvement is assured by establishing witness points in the test

procedures, day-to-day contact with the Test Engineers and awareness

of scheduled testing. Checklists are prepared for each procedure

with a witness point and they are tailored for that specific acti-

vity. Personnel are on a ten hour shift for six days and off for

three days. There are two such shifts per day with two individuals

assigned to each shift. Surveillances are also done for selected

proof tests and testing by the operating staff (e.g. Solenoid

Operated Valves). Deficiency Report (DR) trending is also done using

a small computer assigned to the group.

An audit of the SUG was ongoing during this inspection. The check-

list was reviewed and the lead auditor was interviewed. One such

audit was conducted earlier this calendar year and two the previous

year.

4.3 Findings and Conclusions

The transition phase of the QA Unit is being done in such a manner

that current procedures can be used. SQC has not waived any Cate-

gory I inspection points and only a small number of non-seismic Cate-

gory II inspections. TQC has not waived any inspection points to

date. QA surveillances have been conducted on more than 40 pre-

operational tests with some multi-monitoring of long lasting testing;

46 proof tests; and, testing of 44 Solenoid Operated Valves.

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On one occasion, a negative trend was identified that resulted in a

meeting with the SVG to discuss issues and methods to improve the

quality of work performance. There is no backlog of open Deficiency

Reports and none are older than six months.

It was determined that inspections, surveillances, audits and correc-

tive action followup continue to be accomplished in accordance with

licensee commitments and regulatory requirements.

No violations were identified.

5. Management Meeting

Licensee management was informed of the scope and purpose of the

inspection at an entrance interview conducted on November 17, 1986. The

findings of the inspection were presented to licensee management (see

paragraph I for attendees) at the exit meeting on November 21, 1986. At

no time during the inspection was written material provided to the

licensee. No proprietary information was involved in this inspection.

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ATTACHMENT A

A. Generic Letter Related Documentation

1. References / Requirements

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NRC Generic Letter 83-28, " Generic Implementations of Salem ATWS

Events"

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Beaver Valley Station Unit 2 FSAR

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DLC0 Response to Generic Letter 83-28 for BVPS-2, March 30, 1984

2. Procedures

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Beaver Valley Power Station 1/2 Operating Manual,. Chapter 48,

Issue 3, Rev. 0

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SAP-3D, The Maintenance Work Request, Rev. 2

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SUM-2.2, Regulatory / Technical Information Management, Rev. 1

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SAP-24, Correspondence Control, Rev. 0

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LCP-10, Updated FSAR, Rev. 4

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LCP-9, Technical Specification Change, Rev. 1

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LCP-2, Preparation of Responses to NRC Correspondence, Rev. 2

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TAG-6.0, Review of INPO Data and Vendor Technical Bulletins,

Rev. 7.

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2MSP-1.04-I, Reactor Protection Logic System Train "A"

Bi-Monthly Test, Rev. 0

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2MSP-1.05-I, Reactor Protection Logic System Train "B"

Bi-Monthly Test, Rev. 0

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MSP-1.05, Solid State Protection System Train "B" Bi-Monthly

Test, Rev. 31

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MSP-1.04A, Reactor Trip Breaker A (RTA) Bi-Monthly Test Rev. 1

B. QA Program Related Documentation

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Operation Quality Assurance (0QA) Procedure OP-7, Test Program Prior

to Operations, Rev. 0

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OQA Instruction OAI-18.3.2, Quality Assurance Surveillances, Rev. 12

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Internal Memorandum DLCQA-6368

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Audit Schedule 1986

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QA Surveillance Log

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Various Inspection Checklists

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Deficiency and Nonconformance Report Log

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Audit DC-2-86-37 Checklist

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ML20211Q319

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