IR 05000412/1985004
| ML20133P483 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/28/1985 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Carey J DUQUESNE LIGHT CO. |
| References | |
| NUDOCS 8511010027 | |
| Download: ML20133P483 (2) | |
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t DCT 2 81985 Docket No. 50-412-Duquesne Light Company ATTN: Mr. J. J. Carey Vice. President Nuclear Group Post Office Box 4
'Shippingport, Pennsylvania 15077
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-Gentlemen:
Subject:, Inspection Report No. 50-412/85-04 This refers to your letter dated May.30, 1985, in response to our letter.
dated April 23, 1985 and your revised response dated July 29, 1985.
Thank you for informing us of the corrective and preventive actions documented in your letters. Your response to violation no. 85-04-04~regarding instrument and impulse lines using a common support states that neither the instrument or impulse lines are now considered redundant safety-related systems. However, at the time of the inspection, metal tag nameplates attached to the instrument and impulse lines included an asterisk (2CCP*FT117A2, 2CCP*FT11782) which is
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used to indicate safety-related components and systems.
Furthermore,.examin-ation of the installation drawing by the inspector and licensee personnel in-dicated the lines to be category 1 redundant lines.
Verification of this discrepancy as well as your corrective action for viola-tion'nos. 85-04-02 and 85-04-03 will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, OriGir01 SiG"CdB7*
Jacquo?.Durr f
Stewart D. Ebneter, Director Division of Reactor Safety
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8511010027 851028 g
PDR ADOCK 05000412 G
PDR lg OFFICIAL RECORD COPY RL BV2 85-04 - 0001.0.0 10/18/85
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Duquesne Light Company
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E. J.-Woolever, Vice President, Nuclear Construction Division-R. E. Martin, Manager, Engineering R. J.- Swiderski, Manager, Startup Group E. Ewing, Quality Assurance Manager E. F. Kurtz,: Jr., Manager, Regulatory Af fairs P. RaySircar, Stone and Webster Engineering Corporation Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
Commonwealth of Pennsylvania bcc:
Region I Docket Room (w/ concurrences)
DRP Section Chief
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OFFICIAL RECORD COPY RL BV2 85-04 - 0001.1.0 10/09/85
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= =8 (412) 923-1960 Nuclear Construction Division Telecopy (412) 787-2629 Roolnson Plaza. BuHding 2. Suite 210 Pittsburgh. PA 15205 May 30, 1985 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starostecki Division of Project and Resident Programs SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/85-04 s
Gentlemen:
This is in response to the Notice of Violation cited in Inspection No. 50-412/85-04 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever, dated April 23, 1985.
The due date for submittal of this report was extended (until May 31, 1985) by the NRC Senior Resident Inspector in response to a request from Duquesne Light Company.
Notice of Violation 85-04-02:
Instrument Tubing Separation 10CFR50, Appendix B,
Criterion X, states in part that:
"A program for inspection of activities affeeting quality shall be established and executed by or for the organization performing the activity to verify conformance with... drawings for accomplishing the activity."
Specification 2BVS-977, page 1-39, line 13-15, states in part that: "All Group A and Group C tubing systems serving redundant instruments shall be routed to provide a minimum distance of 4 f t.-0 in, between each pair."
Contrary to the above, on January 30, 1985, the inspector ident ified redundant instrument line Nos. 2CCP*FTil7A and 2CCP*FTil7B1 and line Nos.
2CCP*FT117 B2 and 2CCP*FT117A2, which did not meet the 4 ft. separation criteria.
This characteristic is not included as an attribute check of the instrument inspection plan IP-7.2.9.
This is a Severity Level IV Violation (Supplement II).
Response The above instances identified by the NRC as being pos sible deviations from the 4 ft, minimum separation criterion were in regard to redundant,
safety-related impulse lines run in plant areas not containing any high energy line break (HELB) hazards.
The 4 ft, separation criterion, as C > T~ 4 /' / rM O C D w
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Unitcd Stcteo Nucicar Rigulctory Commission
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'Mr. Richard W. Starostecki USNRC IE Inspection Report No. 50-412/85-04
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contained in the 2BVS-977 subsection titled " Category I separation," was promulgated for - redundant safety-related impulse lines located in the vicinity of high energy lines and thus exposed to HELB hazards.
However, because 2BVS-977 was not clear regarding the required separation dis-tances for HELB hazard and nonhazard areas (as discussed below), SWEC
' issued STOP WORK E&DCR 2PH-0097 on February 5, 1985, to halt all work involving QA Category I instrument tubing until an overall review of this issue was completed.
Subsequently, specific actions were taken by SWEC in the following areas:
- The separation for redundant impulse lines was reviewed.
This review determined that the 4 ft. minimum separation distance could be reduced.
(It exceeds the 18 in, minimum separation distance recomme nded in Regulatory Guide 1.151, Rev. 0.)
- The engineering and design process was reviewed.
It was also verified that the...BVPS-2 Hazards Analysis Program (Procedure 2BVM-165) ade-quately considers the separation of safety-related instrument impulse lines as a final engineering confirmation.
- The instrument installation specification (2BVM-977) for separation criteria for instrument tubing was reviewed.
This review determined that clarifications were required to distinguish between hazard 'and nonhazard areas; these clarifications were issued as E&DCR 2P4652B on February 27, 1985.
- All issued isometric drawings for QA Category I instrument tubing were reviewed. Some 75 of over 900 reviewed required revision by means of a note to indicate where specific deviations from E&DCR 2P-4652B were allowable pending confirmation by the Hazards Analysis Program.
However,. the review in general confirmed that the intended design requirements were being fulfilled.
- A specific project procedure (2BVM-228) governing instrument tubing layout was developed.
This procedure clearly translates separation requirements of 2BVS-977 into detailed design procedures and design verification steps.
The information presented above reaffirms the responses provided to Audit SPC-4 regarding SQC verification of adequate instrument tubing separa-tion.-
The engineering and design process for instrument tubing isome't-rics, coupled with SQC verification of tubing installation in accordance with the isometrics, provide sufficient controls to ensute compliance with separation criteria.
Th5 circumstances surrounding Violation 85-04-02 have been reviewed for possible reportability under the provisions of 10CFR50.55(e).
This review was completed on March 7, 1985, and concluded that deficiencies meeting the criteria - for reportability under 10CFR50.55(e) did not exist
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Unitsd Stctes Nuclesr R2gulctcry Commission
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- Mr. Richard W. Starostecki USNRC IE Inspection Report No. 50-412/85-04 Page 3 in either the applicable engineering and design processes, in Specifica-tion 2BVS-977, or in any actual physical installations.
Based on the information and actions described above, STOP WORK E&DCR 2PH-0097 was fully released on February 27, 1985,. to reinstate all work
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on QA Category I instrument tubing.
Violation 85-04-03: Vents on Flow Lines 10CFR50, Appendix B, Criterion III, states in part that:
"... measures shall include provisions to assure that appropriate quality standards are specified and included in the design document and that deviations fran such standards are controlled...."
Specification 2BVS-977, page 1-42, lines 5-8, states:
"Each vent and drain shall have the piping / tubing connected to its discharge so as to direct the effluent away from any possible contact with the operator or other persons in the vicinity of the vent or drain."
Contrary to the above, on January 29, 1985, the ' inspector. identified vent and drain lines from system No. 2CHS*FT110 installed per the drawing but contrary to the specification requirement.
This is a Severity Level V Violation (Supplement II).
Response The requirements quoted above were noted as being reported on pages 1-42 and 1-48 of 2BVS-977 -by the NRC Inspector in Section 4.3 of the inspec-tion report.
The requirements are part of the subsection titled "Instru-ment Valves" in the specification.
This subsect ion relates to vent, drain,. blowdown, crossover, and other valves that are provided in the immediate vicinity of an instrument and are used for routine maintenance and calibration of the instrument.
Due to the relatively frequent usage of such valves, operator and equipment safety cons ideration warrant providing the vent and drain valves at instruments with discharge tubing to adequately direct any possible effluent discharges.
The vent valve with U-shaped discharge tubing identified as a concern by required on a section of the NRC represents a high ~ point vent that was-instrument tubing that could not be continuously sloped towards the sub-ject instrument. This vent valve and its discharge tubing were installed in accordance with applicable isometric drawings.
Because high point vents are generally necessary only in the process of bringing a system to an operational status, the use of high point vent valves is relatively infrequent.
We have reviewed the direction of discharge of ef fluent fr an similarly configured high point vent tubing.
The "U" tube has been rotated, where
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Unitsd States Nuclect Ragulctory Commission
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.Mr. Richard W. Starostecki USNRC IE Inspection Report No. 50-412/85-04 Page 4 necessary, in order to provide more accessibility for the operator and to allow control of the ef fluent discharge.
In addition, administrat ive procedures will be developed to ensure, where necessary, that the appro-priate method:of contaminated effluent control is used to provide protec-
' tion against the ef fluent -contacting personnel and/or equipment during the venting operation of these high point valves wi th
"U" shaped dis-charge. tubing.
Violation 85-04-04: QA Category I Instrument Tubing Mounted on Same Support-10CFR50, Appendix B,
Criterion V,
states in part that:
"Act ivi ties affecting quality shall be prescribed by documented instructions... and shall be. accomplished-in accordance with these instructions."
Specification 2BVS-977,- page 1-40, lines 25-29, states: " Redundant lines shall: - be supported by independent suppo rt s provided speci fically for support of instrument tubing."
Contrary to the above, on January 29, 1985, the inspector ident ified redundant Category I instrument tubing Nos. 2CCP*FT117B2 and 2CCP*FT117A2 mounted on coarnon hanger Nos. TSA-180 and TSA-189.
This is a Severity Level IV Violation (Supplement II).
Response The proper designations for the instruments and supports - referred to above,. as indicated on drawings RK-303-AC-1 and RK-303-A for elevation 728 f t.-6 in.1 of the main. steam and cable vault area, are 2CCP-FT117B2,
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2CCP-FT117A2, TSR-180, and TSR-189.
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Neither these instruments nor their impulse lines are safety-related
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supportsn is acceptable and is not prohibited by 2BVS-977.
common Therefore, the - installations of concern noted in Violation 85-04-04 do not represent a deviation from applicable engineering requirements.
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- To provide further assurance that the requirements of 2BVS-977 regarding common supoorts have been properly implement ed, SWEC initiated-and completed an. engineering review of all BVPS-2 isometric' drawings issued for-QA Category I instrument tubing. This review confirmed that supports
' for - all redundant,. safety-related instrument impulse lines had been properly specified, with one exception. This exception (redundant safety-related tubing on a common support) has been evaluated and determined to clarified by E6DCR be ' acceptable.
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2P-4652B, the acceptability of this installation has been formally iden-
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. lcr t tified as requiring final confirmation by the Hazards Analysis Program.
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Mr. Rfchard W. Starostecki USNRC IE Inspection Report No. 50-412/85-04 Page 5 In order to provide general requirements for supports on safety-related and nonsafety-related instrument impulse lines, E&DCR 2P-4652B was issued on February 27, 1985, against Specification 2BVS-977 and clarifies 2BVS-977 regarding requirements for supports.
DUQUESNE LIGHT COMPANY By
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J.(/(/Carey Vice 7 resident SDH/wjs cc: Mr. R. DeYoung, Director (3)
Mr. B. K. Singh, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF ALLEGHENY
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On this Jgf/ day of W/p/
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Notary Public in and for said Commone alth and County, personally appeared J.
J. Carey, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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Notary Public ANITA ELATNE REITER,730TARY PUCUC '
ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986
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2NRC-5-109 (412) 787 5141 (412) 923-1960 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plera, Building 2, Suite 210 Pittsburgh, PA 15205 July 29, 1985 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
' ATTENTION:
Mr. Richard W. Starostecki Division of Project and Resident Programs SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Revised Response to USNRC IE Inspection Report 50-412/85-04 REFERENCE :
2NRC-5-078, dated May 30, 1985 Gentlemen:
The following is a revised response to the Notice of Violation cited in Inspect ion Report 50-412/85-04 for violation 8 5-04-02 and 8 5-04-04.
This is being submitted per NRC request in a telecon with Mr. Ralph Paolino (NRC),
Mr. Glen Walton (NRC), Mr. Les Arch (DLC), and Mr. Stanley Hall (DLC) on June 28, 1985.
l Duquesne Light Company's (DLC) previous response to violation 85-04-02 ( see above reference), relating to the third and fourth specific ac t ions on Page 2, reads as follows:
- The instrument installation speci fic (2BVM-977) for sepa rat ion
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f criteria for instrument tubing was reviewed. This review determined that clarifications were required to distinguish between hazard and
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nonhaza rd areas; these clarifications were issued as E6DCR 2P4652B l
on February 27, 1985.
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- All issued isometric drawings for QA Category I instrument tubing were reviewed.
Some 75 of over 900 reviewed required revisions by
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means of a note to indicate whe re speci fic deviations from the i
E6DCR 2P4652B were allowable pending confirmation by the Hazards Analysis Program.
However, the review in general confirmed that the intended design requirements were being fulfilled.
The information presented above reaffirms the res pons e s provided to Audit SPC-4 regarding SQC verification of adequate instrument tubing separa-tion.
The engineering and design process fo r instrument tubing isometrics, coupled with SQC verification of tubing installation in accordance with the isometrics, provide sufficient controls to ensure compliance with separation criteria.
The following is DLC's revised response providing additional informa-tion regarding action taken:
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Mr. Richard W. Starostecki Revised Respo_nse to USNRC IE Inspection Report No. 50-412/85-04 Page 2 i
- The instrument ins t allat ion speci fic (2BVS-977) for separation criteria for instrument tubing was reviewed. This review determined that clarifications were required to distinguish between hazard and nonh aza rd areas; these clarifications were issued as E6DCR 2P4652B o_n_Feb__rsary ? 7 _ 1985, and sub seque nt ly incorporated it into 2BVS-977, Rev. 2, dated April 29, 1985.
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- In order to ensure compliance with the modified separation require-ments contained in E&DCR 2P4652B, SWEC initiated and comple t ed a review of ali existing isometric drawings for QA Category I instru-ment tubing.
This review determined that noted instances wh e re separation distances were not in accordance with relevant separa-tion criteria were limited to those cases fo r which the le s se r distances were shown on applicable SWEC isometric drawings, p* Over 900 isometric drawings were examined during this rev i ew, and approximately 75 were found to require revision.
These drawings have Teeit TevtTet-try--the7dfytmi or a note that ident ifies the i
s peci fic deviat ion from - the separation criteria for E&DCR 2P4652B and indicates that confirmation of the acceptance of the deviation will be verified and documented under the BVPS-2 llazards Anal ysis Program, in accordance with 2BVM-165.
- Each of these deviations from the separation requirement s of E&DCR 2P4652B were ev aluated and it was determined that, in each case, the noted conditions represented an acceptable instrument tubing configuratior with no rerouting of tubing required. Hazards analy-sis confirmat ion of the acceptance of these conditions will be documented as part of the normal work act ivities and schedules comprising the Hazards Analysis Program.
- During the isometric drawing review, approximatg y 18 c onditions were noted that represented-deviations _ from _ the original separatio_n criferiUF2iiV5977.
Of these 18 deviat ions, 17 instances c o n-c d rned ~ redundant impulse lines separated by less than 4 feet in llELB hazard areas; one deviation represented redundant impulse lines on common supports in a nonhazard area.
Final documentat ion will be developed following hazards analysis of the conditions, as previously discussed.
- Because the original tubing separation criteria of 2BVS-977 had not been properly implemented in certain isolated cases, and in order to strengthen the engineering and design process fo r ins t rume nt tubing isometrics, project procedure 2BVM-228 was revised as of April 24, 1985, to clearly translate the separation requirements of 2BVS-977 into detailed design procedures and design ve rificat ion steps.
Training of appropriate personnel regarding the content and use of revised 2BVM-228 has been complete,
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United Stcteo Nuc12.ar R2gulctory Commission
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Mr. Richard V. Starostecki Revised Response to USNRC IE Inspection.
Report No. 50-412/85-04 Page 3
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In addition, DLC has re-evaluated the need for an SQC inspection for spatial separation of redundant safety-related instrument lines.
The following act ions will be/have been taken to ensure SQC involve-ment in the verification of separation criteria.
1) SEG has furnished SQC with a list of safety-related instruments which identifies the redundant groups.
2) SQC is in the process of revising IP-7.2.9 to require ins pect ion for redundancy of such instruments. This inspect ion will be done at the time - of the tubing configuration ins pect ion fo r future installations. SQC will issue the requi red revision to IP-7.2.9 by July 19, 1985.
Those instruments which have previously been subject to a tubing configuration walkdown will be reins pect ed to ens ure the red un-dancy requirements have been met.
SQC estimates that it will be able to complete the reinspection by August 15, 1985.
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Violations to the redundancy criteria will be processed as indicated below:
a) Those which violate the redundancy criteria and ins talla t ion
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drawing. These will be identified on N&D's.
b) Those which violate the redundancy criteria but which are installed in accordance with the installation drawing.
If they are not ident ified on the drawing as being reviewed by the Engineers, then they will be reported on a " Redundant Separat ion Evaluat ion Request."
This " Request" will identify such violations to SEG.
SEG will evaluate these conditions-and in the space prov ided, justify them if they meet the reduced separat ion criteria.
If the conditions do not meet the reduc ed separation criteria, or if the reduced separation criteria does not apply, SEG will indicate which drawings need to be revised to rework the condition.
The SQC inspection plan will be revised by July 26, 1985, to address the use of the Redundant Separation Evaluation Request.
c) Those which violate the redundancy criteria but which are installed in accordance with the installation drawing.
If they are identified on the drawing as being reviewed by the Engineers, no corrective action will be required.
In regards to Violation 85-04-04, the following revised res ponse is provided. The revisions are identified by an underscor. _ - _.
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.. Un'i*tod Stctes,Nuciocr Reguletory Connaission l
Mr. Richard W. Starostecki Revised Response to USNRC IE Inspection
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' Repo rt No.' 50-412/85-04
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Response
The proper designations fo r the instruments and suppo rt s referred to above, as indicated on drawings RK-303-AC-1 and RK-303-AA for elevation 728 f t.-6 in, of the main steam and cable vault area, a3 2CCP-FT117B2, 2CCP-FT117A2, TSR-180, and TSR-189.
Neither these instruments nor their impulse lines are redundant s afe ty-related components.
For nonsafety-related instruments and bapulse lines, the use of common support s is acceptable and is not prohibited by 2BVS-977.
Therefore, the installations of concern noted in Violation 85-04-04 do not represent a deviation from applicable engineering requirements.
To provide further assurance that the requirements of 2BVS-977 regarding common supports have been properly implemented, SWEC initiated and com-pleted an engineering review of all BVPS-2 isometric drawings issued fo r
. QA Category I instrument tubing.
This review confirmed that suppo rt s fo r all redundant, safety-related instrument impulse lines had been properly s peci fied, with one exception.
This exception (redundant safe ty-rela t ed
. tubing on a comman suppo rt) has been evaluated and de termined to be accept ab le.
In accordance with 2BVS-977, and as clarified by E&DCR 2P4652B, the acceptability of this installation has been formally identi-fled as requiring final confirmation by the Hazards Analysis Program.
In order to provide general requirements for supparts on safety-related and nonsafety-related instrument impuls e lines, E&DCR 2P4652B was issued on February 27, 1985, against Specification.2BVS-977 and clarifies 2BVS-977 regarding requirements for supports.
DUQUESNE LIGHT COMPANY
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. Carey 7'
'ce President SDH/wjs cc: Mr. J. M. Taylor, Director (3)
Mr. B. K. Singh, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk SUBSCRIBED AND,4) WORN TO BEFORE ME THIS g, DAY OF L Al g / C _ _ _, 1985.
dd_%sd6 h_Nes Notary Public
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Swte u IAffcat notAPy rustic 1*M8*lt:801f 1060 traviP COUn!1 hv Comutssion infiell SIPI.16.1985 18amht. PemyWee Asuciation of notereen
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Mr. Richard hI. Starostecki Revised Response.to USNRC IE Inspection Report No. 50-412/85-04 Page 5 COMMONWEALTil 0F PENNSYLVANIA )
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COUNTY OF BEAVER
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On this mmh [dayof
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before e, a
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Notary Public in and for said Codnweadh and County, personally appeared J.
J.
Carey, who being duly sworn, deposed and said that (1) he is Vice Pres ident of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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