ML20211Q319
| 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: |
| References | |
| 50-412-86-36, GL-83-28, NUDOCS 8612190239 | |
| Download: ML20211Q319 (9) | |
See also: IR 05000412/1986036
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U.S. NUCLEAR REGULATORY COMMISSION
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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
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Shippingport, Pennsylvania 15077
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Facility Name: Beaver Valley, Power Station, Unit 2
Inspection At: Shippingport, PA
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Inspection Conducted: November 17-21, 1986
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Inspectors:
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G.t apuda, tead Reactor Engineer
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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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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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Based on the above, this item is closed.
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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
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Standard 105D, which is an industry recognized sampling plan, for the ,
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re-inspection of shims installed in various supports. The following are
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pertinent features of the sampling re-inspection effort by QA/QC:
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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
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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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sketches; and
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documentation of each inspection including descriptio,n of unsatis-
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factory conditions.
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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
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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
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used for re-inspection of installed Hilti Bolts.
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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
reactor trip system will automatically initiate reactivity control systems
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on demand to assure that fuel design limits are not exceeded. The design
and regulatory philosophies for attaining the high reliability required of -
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the reactor trip system have been primarily based on the use of redund-
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ancy, periodic testing, and quality assurance.
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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 /
of the events. Based on these findings, certain actions were r'equired ,of -
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all licensecs.
These actions, transmitted in Generic Letter 43-28, fell
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into four areas:
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(1) post-trip review;
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(2) equipment classification and vendor interface;
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(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
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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
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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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required and to verify the satisfactory completion of testing before
returning the equipment to service. The. post-maintenance operability
testing must be performed using approved written procedures when
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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.
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The licensee is incorporating vendor; and engineering recommendations
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for safety-related equipment (including the RTS components) into the
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procedures and Technical Specifications as they are written.
The
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
evaluation to determine applicability for incorporation into affected
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procedures.
The
licensee, . during ' +.he
operations
phase,
will
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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
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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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Action 4.5.1, Reactor Trip System Reliability (System Functional
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Position
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
of supports, etc. , is controlled administratively by TQC. Inspection
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coverage is on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and seven day a week basis.
The
engineering aspect of TQC is provided 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> 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.
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
NRC Generic Letter 83-28, " Generic Implementations of Salem ATWS
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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
Beaver Valley Power Station 1/2 Operating Manual,. Chapter 48,
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Issue 3, Rev. 0
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SAP-3D, The Maintenance Work Request, Rev. 2
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
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,
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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
MSP-1.04A, Reactor Trip Breaker A (RTA) Bi-Monthly Test Rev. 1
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B.
QA Program Related Documentation
Operation Quality Assurance (0QA) Procedure OP-7, Test Program Prior
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to Operations, Rev. 0
OQA Instruction OAI-18.3.2, Quality Assurance Surveillances, Rev. 12
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Internal Memorandum DLCQA-6368
Audit Schedule 1986
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QA Surveillance Log
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Various Inspection Checklists
Deficiency and Nonconformance Report Log
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Audit DC-2-86-37 Checklist
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