IR 05000412/1985013
| ML20133G869 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/15/1985 |
| From: | Prividy L, Lester Tripp, Walton G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133G825 | List: |
| References | |
| RTR-REGGD-01.029, RTR-REGGD-1.029 50-412-85-13, IEIN-84-65, NUDOCS 8508090101 | |
| Download: ML20133G869 (9) | |
Text
{{#Wiki_filter:f~ . . U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-412/85-13 Docket No.
50-412 License No.
DPPR-105 Priority -- Category B Licensee: Duquesne Light Company Robinson Plaza Building No. 2 Suite #210, PA Route 60 Pittsburgh, Pennsylvania Facility Name: Beaver Valley Power Station, Unit 2 Inspection at: Shippingport, Pennsylvania Inspection Conducted: May 23 - June 28, 1985 Inspectors: U, 8 */, n //2., ~7-f- [ f G. A.~Walton, Senior Resident Inspector date f $}.f & g 7-8-ts L.
J~. Prividy, R(sident Inspector date , f., ' 7 I'/8r Approved by: F. E. Tr Chief, Reactor Projects / ddte Section cA Inspection Summary: Inspection on May 23 - June 28,1985 (Report No. 50-412/85-13).
Areas Inspected: Routine, unannounced inspection by two resident inspectors (195 hours) of activities pertaining to previously identified unresolved items and violations, 50.55(e) reports, information notices, seismic design of items important to safety, inspection of piping supports, rigid sway struts and associated documentation, rework and/or disassembly control of components, disposition of nonconformance and disposition reports, review of welding and associated weld procedures and procedure qualification, and daily site tours.
Resul ts : One deviation (failure to meet RG 1.29) was identified and one violation (failure to meet procedure requirements) were identified during this inspection.
In addition, an unresolved item discusses a deficiency with locking devices on rigid sway strut supports which appears to be a generic issue. Also, control of rework and/or disassembly of installed components continues to be a concern.
Acceptable results were found in the review of nonconformance and disposition reports, welding of piping and. disposition of an information notice.
8500090101 05071s PDR ADOCK 05000412 O PDR
r - - - . . DETAILS 1.
Persons Attending Exit Interview Duquesne Light Company L. E. Arch, Senior Project Engineer J. A. Bituszik, Construction Engineer C. R. Davis, Director, QA D. W. Denning, Assistant Director, QC C. E. Ewing, Manager, QA S. D. Hall, Sr. Project Engineer J. J. Hayden, SQC E. J. Horvath, Sr. Project Engineer J. A. Hultz, Construction Liaison C. S. Majumdar, Asst. Director, QC A. F. Mosso, QA R. A. Perry, Supervisor, NDE Services D. K. Rohm, SQC Stone and Webster Engineering W. Baranowski, Assistant Project Manager-H. A. Dasenbrock, Sr. Constr. Mgr.
H. W. Durkin, Superintendent, Engineering D. Lessard, Assistant Superintendent, Engineering J. Purcell, Assistant Superintendent, Engineering R. C. Wittschen, Licensing Engineer 2.
Construction Site Walk-Through Inspections Daily tours of the construction site were made to observe work activities in progress, completed work, and plant status of the construction site. The presence of Quality Control inspectors and quality records were observed.
The inspector found safety related piping routed through non-seismic stairs.
This item was identified as a " deviation" to Regulatory Guide 1.29 and discussed in Paragraph 4.
A violation is discussed in Paragraph 5 regarding install-ation of a support which was observed by the inspector. In addition, the inspector observed a problem with the locking feature on sway strut supports which is discussed in Paragraph 6 and missing nuts and bolts were observed on a valve which is discussed in Paragraph 7.
All other areas observed were found acceptabl i . -3- . . 3.
Licensee Action on Previous Inspection Findings (0 pen) 50.55(e) 85-00-03, Eouipment Qualification of Core Exit Thermocouple System Westinghouse reported a 10 CFR Part 21 deficiency by letter dated May 9,1985, with the safety grade core exit thermocouple system supplied by Westinghouse.
The problem concerns potential total system errors identified in recent testing of connectors, splices, etc., on the core exit T/C system. These errors appear to be nonconservative and affect the following areas: reactor coolant system subcooling monitors; and the detection of inadequate core cooling (ICC). Additionally, it appears to also affect the density compensation signal for the Westinghouse reactor vessel level indications system. Beaver Valley, Unit 2, is one of the plants identified as having this particular core exit thermocouple system. The licensee reported this item on May 10, 1985, as required by 50.55(e) and submitted an interim report dated June 10, 1985. Analysis and corrective actions are in progress and a final report will follow.
(0 pen) 85-05-03, Resolution of N&D 2350 NRC Inspection Report 50-412/85-05 contained the details of a violation of Criterion XVI of 10 CFR 50, Appendix B, which requires that deficiencies and nonconformances be promptly identified and corrected. Specifically, N&D 2350 had been originally issued on October 8, 1982, and as of March 13, 1985, had not been satisfactorily dispositioned.
The licensee informed the NRC Region I Office via their letter 2NRC-5-073 dated May 17, 1985, of the status of the corrective and preventive actions taken in response to this violation. After review of this letter, the inspector discussed this response with DLC-SQC (R. Coupland) and Stone and Webster Engineering (H. Durkin) and noted it was his understanding that additional corrective action had been taken which was not mentioned in letter 2NRC-5-073. This additional corrective action consisted of a compre-hensive SEG review of non-dispositioned N&Ds where it was concluded that there was no widespread problem in other areas due to untimely dispositioning of N&Ds.
Furthermore, N&Ds over 60 days old are identified monthly to project management with a brief description of the concern. This additional corrective action is documented in Site Memorandum 2BVM-3842 dated June 6, 1985, from Stone and Webster (H. W. Durkin) to DLC-SQC (R. Coupland). The inspector will review the implementation of these corrective actions into the N&D process in subsequent inspections.
s
' -4- . (Closed) Unresolved Item 84-16-02, Construction of Spent Fuel Storage Pool and Refueling Cavity Liners.
Previous NRC Inspection Report 50-412/8a-16 had identifidd an unresolved item concerning the construction of the spent fuel storage pool and refueling cavity liners.
It was noted that Section C.l.1 of Regulatory Guide 1.29, Revision 3, requires that the spent fuel storage pool be designed and designated as Seismic Category 1.
Table 1.8-1, Volume 1 of the FSAR endorses Regulatory Guide 1.29, Revision 3, with no apparent exceptions. However, in reviewing the ordering specification 2BVS-25 for these liners, the inspector noted that they were classified as Category II, which was confirmed verbally with Stone and Webster. Engineering.
Subsequent review of this item was reported in NRC Inspection Report 50-412/ 85-03 wherein the inspector reported that the construction of the liners was performed satisfactorily.
However, Section 9.1.2.3 of the FSAR required modification to clarify the as-built configuration of the spent fuel pool, spent fuel pool liner and all supporting structures regarding their seismic design. Amendment 10 of the FSAR issued in May,1985, includes this clarification by adding the following: "The BVPS-2 spent fuel pool structure and spent -fuel racks are classified, designed and constructed as Seismic Category I items. The spent fuel pool liner and refueling cavity liner are classifiec, designed and constructed as Seismic Category II items." The prior version of this portion of Section 9.1.2.3 stated the following: "The spent fuel pool, spent fuel pool liner and all supporting structures are designed for the SSE seismic loads described in Section 3.8.4."
If this statement had not been modified, it could have been concluded that all listed items were classified as Seismic Category I when, in fact, the liner was Seismic Category II.
With the FSAR modification to Section 9.1.2.3 issued as noted above, the inspector concluded that this item was now acceptable and is now closed.
(Closed) Noncompliance 84-10-01, Warehouse Storage of Electrical Equipment This noncompliance identified that in warehouse storage of electrical components, the sealing cap of one Limitorque valve motor was missing, exposing the motor internals to the environment. The motors required level B storage.
The licensee conducted a survey to identify motors in warehouse storage which r quire Level B storage requirements. Eighty-four motors were determined to Fi in this category. The storage of sixty-four of these motors had been r&Jified to facilitate megger testing.
As a result, the caps were not replaced.
The licensee has taken the following corrective actions:
E ' -5- . - All sixty-four motors were restored to Level B storage requirements.
- The meggering test requirements have been changed for motors ia storage and only requires meggering upon receipt and again at time of system turnover. Therefore, it is unnecessary to remove the covers from the motors during storage.
- Specifications 2BVS-931 and 2BVS-981 were revised to reflect the meggering test requirements.
Job site training meetings were conducted to ensure that the field - craftsmen, foremen and supervisors understand the storage level maintenance requirements.
The inspector toured Warehouses B and C, the warehouses that store electrical motors, and visually observed the stored condition of several motors. All items observed were adequately sealed and protected and were found consistent with Regulatory Guide 1.38 and ANSI-N45.2.2 storage requirements. This item is closed.
4.
Seismic Design of Structures During a site tour, the inspector observed four safety related pipe runs installed in the Main Steam and Cable Vault area which penetrated the stair enclosure wall at Elevation 781'..The piping is routed up through two stair landings and leaves the enclosure at Elevation 805'. The inspector performed
a detailed review of the licensee's commitments to ascertain compliance with
Regulatory Guide 1.29 for piping routed in stair enclosures. As stated in the regulatory guide, structures whose failure could reduce the functioning of any plant safety feature to an unacceptable level, must be designed and constructed to seismic requirements. The piping is required to perform a safety related function and is designed and constructed to Category 1 require-ments which include seismic analysis. The piping is identified as 2-SWS-004-762-3, 2-SUS-004-773-3, 2-SWS-004-768-3, and 2-SWS-004-763-3 as shown on isometric drawings 101937,101-939,101942, and 101944.
As required by the Regulatory Guide, since the piping is routed under and through the stairs and landings, the stairs must also be designed and constructed to seismic requirements.
Contrary to this requirement, the inspector found the stairs were not seismically analyzed. Stone and Webster Engineering Document 2BVM-116, Revision 5, entitled " Seismic Classification for Structures, Systems and Components", Paragraph 6, states "All structural members and supports within the stair enclosures throughout the plant area are nonseismic." On May 29, 1985, the inspector advised the licensee that this was a " Deviation" from the commitments contained in Regulatory Guide 1.29 The following corrective actions were taken on this issue prior to the completion of this inspection period: .
' -6- . Stone and Webster Engineering and Duquesne Light Company Quality - Control performed walkdowns of all stair enclosures throughout the site and identified each item, other than stairs, routed into the non-seismic stairs area.
- Stone ano Webster Engineering performed an engineering review of the walkdown data and determined the piping discussed above is the only safety related item in the stair enclosures.
Stone and Webster Engineering, Boston Office, performed calculations - on the existing stairs at the service water piping location and determined they would withstand a seismic event and would not affect the service water piping.
- The Stone and Webster Project Engineering Manager issued a directive on June 26, 1985 to all Beaver Valley, Unit 2 Engineering and Design personnel at Boston and Site Engineering Group advising them of the requirements contained in 2BVM-ll6. The letter further advises that when making field modifications, be aware that the structural members and supports within stair enclosures are not seismically designed even though the stairwell walls within seismic buildings are seismically designed.
Based on the walkdown inspections performed, analysis of the existing stairs, and notifying Engineering and Design personnel of the requirements, the inspector advised the licensee that adequate corrective actions were taken and no further action was required. Therefore, the " Deviation" did occur; however, no written response is required of the licensee (85-13-01).
5.
Review of Pipe Support ~ Installation The inspector performed a detailed review of pipe support 25WS-PSST 625 to ascertain compliance with the installation isometric drawing 12241-BZ-19A-48-0C. The inspector used the aid of weld gauges and measuring devices to perform the inspection. The installed support was " final inspected" and accepted by Site Quality Control on April 12, 1984.
The inspector verified the weld location, size and type and material type, size and location.
In addition, the inspector measured the support center-line location in relation to the pipe centerline. The inspector found the piping centerline dimensions were not on location (within the tolerances given of t 1 inch) as spec 1 tied in the isometric drawing and Engineering and Design Coordination Report (E&DCR) Number 2PA-4883. The dimension of 4'5-1/2" 11" is met at the support centerline location (measured 4'5-1/4"); however, the specified 4'5-l/2" 1" dimension at the pipe centerline location measures 4'7", 1-1/2" greater than the specified dimension and 1/2" greater than the tolerances allow. The dimension controls are necessary to provide a 5 degree movement for the rigid sway strut installed in the suppor ' -7- - . l On June 27, 1985, the inspector requested QC to reinspect the support. They l concurred with the inspector that the relative piping / support location was not as specified.
On June 28, 1985, the licensee had performed a preliminary review of the condition and advised the inspector they believed no Q.C. inspector error had occurred because the line at another location had been cut and a new valve installed.
They believed this operation had moved the piping off location. Quality Control had also inspected and accepted the installation of the new valve.
This portion of the service water line had also received a walkdown inspection in preparation for system turnover. As of June 28, 1985, the licensee was unable to demonstrate to the inspector that the walkdown inspection had identified this out-of-tolerance condition.
The inspector advised the licensee the condition was a violation of 10 CFR 50, Appendix B, Criterion V in that the installed, accepted condition failed to meet drawing dimensions (85-13-02).
6.
Inspection of Power Piping Rigid Sway Strut Supports While performing the inspection of pipe support 2-SWS-PSST-625 described in paragraph 5 above, the inspector found a problem with the locking feature on rigid sway strut supports (strut) which appears to be a generic problem on all supports using this locking feature. The struts are manufactured by Power Piping Company. The length dimension between pins is adjustable by rotating a threaded sleeve which has a right hand thread on one end and a left hand thread on the other end.
Rotating the collar extends or retracts the pin to pin dimension. As specified in the manufacturer's ordering catalog and Quality Control Inspection Procedure IP-7.3.1, the strut is installed with a right hand threaded locking nut. Quality Control verifies the locking nut is installed finger tight. The inspector found the strut was installed as specified; i.e., a locking nut finger tight was installed. However, the inspector found the sleeve could be rotated by hand with a resulting dimensional change. The inspector then rotated two other struts located in the innediate area and found the locking feature failed to prevent the struts from ' changing dimensions.
The inspector advised the licensee that the locking devices do not perform their intended function and it appears to be a design problem and generic on all like supports.
In addition, the inspector observed the clamping device which connects to the 4 inch pipe, would rotate about the axis of the pipe when bumped by hand.
The clamp is part of the pipe support and sFould be securely fastened to the pipe to prevent movement. The inspector questioned the licensee regarding the clamps capability to perform its function of holding the pipe on location.
The licer.see is performing an investigation of the two items discussed above.
This item will remain unresolved pending the licensee's completion of this investigation and rework, if required and further review by the inspector (85-13-03).
' -8- . 7.
Control of Components When Disassembled On May 30,1985, the inspector observed four missing nuts and bolts from a valve, (VGW-015-X-2) in the Safeguards Building.
The valve was installed in line number 2-RSS-004-11-2, shown on isometric drawing 107975-3B.
Further investigation found that no disassembly documents were generated for control of the disassembly and reassembly. Upon further investigation performed by the contractor, it was found that no basis or need existed for rcroving the nuts and bolts. The contractor is performing an investigation to determine the reason for the hardware removal.
In addition, on May 31, 1985, the Senior Construction Manager issued a memorandum to all Contractor Senior Site Representatives regarding the unauthorized disassembly of components and the necessity to adhere to established site procedures.
This is an unresolved item pending review of the licensee's actions taken to control the inadvertent disassembly of installed components (85-13-04).
8.
Nonconformance and Disposition Reports The inspector reviewed six nonconformance and disposition (N&D's) reports to ascertain the technical adequacy of the disposition. The N&Ds selected for review covered the mechanical installation of piping and supports.
The inspector found all areas reviewed acceptable with adequate safety margins considered in each disposition.
No violations were identified.
9.
Review of Welding on Safety-Related Piping The inspector audited welding records for three safety-related pipe welds to verify compliance with the licensee commitments. Weld surface contour and finish was observed on each weld as well as a record review. The following welds were inspected: 2 FWE-ll6-F09 2 FWE-ll6-F502 2 FWE-116-F10 The inspector verified the weld finish was acceptable, welders were qualified, weld procedure was qualified in accordance with each essential variable, repairs were identified, repaired and reinspected with the correct non-destructive examination methods. Weld 2 FWE-116-F10 is scheduled for rework and entered on a Construction Revision Notice (CRN) Number 101619-7. All areas reviewed were found acceptable.
.
, - _. _
_9 . 10.
IE Information Notice 84-65 Underrated Fuses which may Adversely affect Operation of Essential Electrical Equipment The inspector reviewed the licensee's actions taken to assure the problem described in the information notice will not affect the operations of Beaver Valley, Unit 2.
The information notice describes a possible generic problem involving the use of FRN and TR-R 250 Volt DC rated fuses manufactured by Bussman and Gould-Snowmat having improper voltage ratings in the current ranges of 15-30 and 70-100 amperes. The fuses were installed to isolate a vital.250 Volt DC buss from a nonvital electrical system under fault conditions. The licensee investigated this matter and determined that Beaver Valley, Unit 2 utilizes a 125 Volt DC system and fuses are not used as isolation devices. Therefore, no action is required.
The inspector reviewed the licensee's disposition of the information notice and found the licensee's actions acceptable.
11.
Exit Interview A meeting was held with the licensee's representatives indicated in Paragraph 1 on June 28, 1985, to discuss the inspection scope and findings.
.
- - - - ---- - -... - - - ... . . . ,
. . 'Af Ducluesne Udit 2;;R;,y,773 . Nuclear Construction Division 2)92 960 Robmson Plaza. Bu;lding 2, Suite 210 Telecopy (412) 787-2629 Pittsburgh, PA 15205 May 17, 1985 United States Nuclear Regulatory Commission Region I 631 Park Aventie 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. 50-412/85-05 Centlemen: This is in response to the concerns ide nt ified in your letter and to the Notice of Violtation cited in Inspection No. 50-412/85-05 and listed in Appendix A (Not ice of Violation) attached to your letter to Mr.
E.
J.
Woolever, dated April 9, 1985.
An extension for responding was granted on May 9, 1985, to May 17,.1985, by the Sr. Resident Inspector to incorporate additional information as a result of a meeting held at the Region 1 Offices in King of Prussia, PA, on May 7,1985.
VIOLATION 85-05-01 " Removal of Hold / Reject Tags" Notice of Violation: 10CFR50, Appendix B, Critrion XV, states, " Measures shall be es t ab-lished to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation."
Contrary to the above, Hold or Reject t ags were not removed fr om various components as required by Site Quality Control (SQC) proce-dures after such components had been satisfactorily reworked to resolve the nonconforming condition that prompted the Hold or Reject tag.
Additionally, despite the t ag 's instruction, "Do not use this equipment," the inspector observed work in progress on February 12, 1985, on a component tagged with Hold Tag 7895, which was closed by Nonconformance and Disposition (N&D) Report 7076.
This is a Severity Level IV Violation (Supplement II).
Response Immediate Action Taken: Upon notification of the Inspector's concern, an investigation was 66eSa % M 7ff g.a
. . . United Stctse Nuclocr R2gulctcry Commissicn Mr. Richcrd W. Stcrectacki ' USNR IE Insp2ction Rap rt No. 50-412/85-05 Page 2 initiated.
This investigation included a review of applicable logs to ident ify those situat ions where Hold / Reject tags had been listed as missing or where no disposition of the tag was entered.
A total of 418 tags met one or the other of these conditions. A site inspec-tion was initiated by the Mechanical, Electrical, Structural, Receiv-ing, Surveillance, and System Release SQC Groups resulting in 65 expired tags being removed and destroyed.
Three hundred fifty-three (353) tags could not be found and are presumed lost or destroyed.
The main problem areas we re in the SQC Mechanical and Receiving discipline. The SQC Surveillance activity has a possible outstanding problem as this group rejected items because they were improperly protected or stored. Subsequently, these items have been cleaned and wrapped wir5 alastic.
It is probable that a few of the tags, recorded as missing by this group, are, in fact, wrapped up with the item.
It has been decided to leave tt: protective wrapping intact and look for expired tags when the protection is removed.
This will be an on-going activity.
Long-Term Corrective Action: The following actions have been taken to prevent recurrence of this problem: 1) SQC-4.4, "Nonconfo rmance and Disposition Reports," and SQC-4.6, " Construction Deficiency Reports," have been revised to require that written or physical evidence that the tags have been removed be presented prior to the close of the document.
2) SQC-4.4, "Nonconfo rmance and Disposition Report," has been revised to require the removal or revision of related tags prior to stamping "Not Issued" on the document when the N&D Report is , ~ not issued following a review by SQC.
3) A training program for SQC personnel reflecting the revised requirements has been completed.
4) Construction Management has reiterated the importance of SQC Hold / Reject tags to the contractors as it affects their activities.
VIOLATION 85-05-02 " Performing Inspections Outside of the QA Function" First Item of Concern: Extract from Cover Letter: Additionally, we are concerned about the apparent lack of compli-with your Quality Assurance (QA) program in that activities ance were pe rfo rmed without involvement of your QA program as described in Section 5 of the enclosed report.
It appears that
-~~ ^ . UnitGd Stctss Nuc1scr Rigulctory Commission ' Mr. Richcrd W. Stcrestecki
USNR IE Inspection R2 port No. 50-412/85-05 Page 3 Stone & Webster Engineering Corporation (SWEC) Engineering and Duquesne Light Company (DLC) Engineering made manageme nt deci-sions regarding ins pect ions which are currently assigned in your program as the responsibilities of the QA Manager or his subordi-nates, to direct the compliance and extent of inspections on all quality related matters of this nature.
In your res pons e, you should add res s your plans to assure that quality decisions and inspections are performed in accordance with your approved QA program.
Notice of Violation: 10CFR50, Appendix B, Criterion I, requires the applicant to establish and implement a QA program. The DLC QA program was established pursu-ant to the above and requires the following: " Quality assurance functions shall be performed by persons and organizations with clearly defined authority and responsibilities which are delineated in writing.
Persons performing quality assurance functions shall have sufficient authority and organiza-tional freedom to identify quality problems; to initiate solu-tions through designated channels and to verify implementation of solutions; and to control further work on a nonconforming item until a proper disposition has been made.
. The individual or group assigned the responsibility for inspect-ing or otherwise verifying that an activity has been correctly performed shall be independent of the group directly responsible fo'r the pe rf o rmance of that speci fic activity.
Act ivities affecting quality shall be de fined and documented in applicable procedures, instructions, drawings, s pe ci fic a t ions, direct ive s, policies, and similar documents."
. The QA Manual establishes controls for items which fail to meet the requirements and provides for the use of Hold or Reject t ag s to identify deficient items that shall be affixed to the item to identify its status.
Contrary to the above, prior to February 27, 1985, inspect ion, dispo-sition, and rework of electrical panel wiring was in process to verify compliance with Regulatory Guide 1.75, without impleme nt ing the approved QA program.
Specifically, personnel performing ins pec-tions were not part of the QA function, were not certified to perform i ns pect ions, and were not independent, i.e., separated from the organization directly responsible for performing the specific activ-found and dispositioned without ity.
Nonconformance conditions were following the program requirements for tagging, trending, and report-ing.
Procedure FPC-422.1, used for the inspection activity, had not been approved or issued for field use by either the applicant or the engineering organization responsible for the internal wiring.
- _ -_ _ _.. _ _ ___ _ _ __ ___ _ __ _. _. _ _ _ __ __ _-- _.. _ -
Unitsd Statec Nuciscr R2gulctory Conusission ' Mr. Richcrd W. Starostscki
USNR IE Inapsetion Raport No. 50-412/85-05 Page 4 This is a Severity Level IV Violation (Supplement II).
i Response The details supporting this violation state that, "... the above rework program is being pe rfo rmed 'outside' of the approved Duquesne Light Quality Assurance (QA) program although the equipment being reviewed is included in the QA program...." The work referred to is the ef fort of SWEC to review the status of electrical panel internal wiring with respect to separation criteria. The engineers were using detailed vendor wiring diagrams to ident ify and tag electrical panels which contained wiring that did not meet Regulatory Guile 1.75 requirements; however, the wiring in these panels had not been inspected and accepted by SQC, SQC will perform a formal inspection of these panels to ensure compliance to - our commitments with respect to Regulatory Guide 1.75.
Any future reviews of this type performed by SWEC or DLC engineers will include an inspector to eliminate duplication of effort and to ensure prope r documentation of any nonconforming conditions.
In response to the statement, "... inspections, disposition, and rework was in progress for the separation of internal wiring of electrical panels without implementing the approved Quality Assurance Program," DLC 1A does not consider the engineering activities (identifying and tagg ng of electrical panels) to be a formal inspection as described in the approved QA progr am.
The final inspection to ensure compl iance to our commitments to Regulatory Guide 1.75 requirements will be pe rfo rmed by SQC personnel who are certified in accordance with ANSI N45.2.6.
DLC has determined that the draft of FCP 422.1 should have been formally issued prior to any field reviews being conducted.
This requirement has been discussed by project management with the personnel involved, stress-ing the need to preclude similar occurrences in the future.
In addition, SWEC has verified that the completed engineering reviews of the subject panels were conducted by appropriate engineering personnel and documented in accordance with FCP 422.1, as formally issued. Thus, no re-evaluations appear necessary of the separation configurations for field and vendor internal wiring.
VIOLATION 85-05-03 " Resolution of N&D 2350 and Associated Matters" Notice of Violation: 10CFR50, Appendix B, Criterion XVI, requires that deficiencies and nonconformances be promptly identified and corrected.
Contrary to the above, as of March 13, 1985, N&D Report 2350, issued by SQC on October 8,1982, has not been satisfactorily dispositioned.
The disposition response only addressed the 19 examples cited in N6D Report 2350 and failed to address the generic problem of electrical potentially significant cable pull tensions and bend radius for a j quantity of cable installed prior to issuance of the N&D Report.
, e- -n-- - ,-,,.m _a- - - - - -, - -
r--
-,,,-. , ~,, -,, - --m
,-m,.~
.----~,---m-n-- ---n - - - - - - - - - - - - - + - +
. _ _ _. , - . United States Nuciser Rsgulctory Commission Mr. Rich rd W. Sterostecki
USNR IE Inspection Rapsrt No. 50-412/85-05 Page 5 This is a Severity Level IV Violation (Supplement II).
Response . ] N6D Report 2350 was issued by SQC on October 8,1982, to document con- ' flicting engineering criteria for cable installation regarding pull tensions and bend radii. On July 14, 1983, SWEC dispositioned N&D Report 2350 indicating that the 19 listed cables were acceptable "as-is" based ' on engineering analysis, and that measures were being taken to ens ure consistency regarding the criteria for the pulling of any future cables i (the effort regarding future cables was completed in September 1983).
In addition, although the N&D Report did not explicitly state this, SWEC' s initial review of the problem indicated that there would be no signifi- < cant impact for other cables already installed. Af ter being dispositioned . by SWEC, N6D Report 2350 was submitted for SQC review and approval, in accordance with applicable project procedures. SQC requested a redisposi-tion of N&D Report 2350 because the original disposition did not explic-itly extend beyond the 19 identified cables.
On July 28, 1983, in accordance with SQC's request, SWEC initiated efforts to provide a docume nt ed response to the ove rall issue under N&D Report 2350A.
N6D
' Report 2350A was dispositioned on March 25, 1985, and reaf firmed that the 19 listed cables were acceptable as-is.
It indicated that changes had been made to preclude future conflicts regarding pull tension values and bend radius values, and confirmed that all previously installed cables justified by appropriate i were acceptable as-is.
These conclusions were i electrical calculations referenced in the dispos it ion of N&D Report 2350A.
SWEC's oversight in failing to formally dis pos it ion N&D Report 2350 regarding previously ins t alled cables, as ident ified by SQC, is con-s ide red to be an isolated condition; there were no adverse impact s associated with this oversight, as confirmed by N&D Report 2350A.
On May 7,1985, a meeting was held between the NRC, SWEC, and DLC at the NRC Region 1 Of fices in King of Prussia, PA.
The subject of the meeting was the electrical cable installation process at BVPS-2, including a discussion of the engineering limits established for cable pull tensions, cable sidewall pressures, and cable bend radii.
At this meeting, SWEC and DLC committed to review the technical bases for engineering criteria contained in the BVPS-2 electrical installation specification (2BVS-931).
This review, scheduled fo r completion by July 1, 1985, will provide further assurance that consistent criteria are in place regarding cable installation, thereby minimizing discrepancies such as those originally identified under N&D Report 2350.
SECOND ITEM OF CONCERN - DLC Commitment to Regulatory Guide 1.75 and IEEE Standard 384 l Extract from Cover Letter: Also, we are concerned that your commitments to Regulatory Guide 1.75 I t .. -, ~ - - - -.. + -. _,. - - - -. _. - __ _ _ _ _, , -, _ _ --_. -. _,,. -, _ -. -
..
United States Nuclear Regulatory Commission Mr. Richard W. Starostecki USNR IE Inspection Report No. 50-412/85-05 Page 6 and IEEE Standard 384 are presently not being met for wiring of the electrical panels as described in Section 6 of the enclosed report.
Specifically, it appears that you are not assuring proper electrical separation when both vendor-installed and field-installed wiring are considered.
We request that you provide, in writing, your basis for not applying the separation provisions of Regulatory Guide 1.75 and IEEE Standard 334 in internal panel wiring.
Response Based upon the results of electrical conductor separation testing conducted at Wyle Labs for BVPS-2, it has been determined that the minimum spacing of wiring within panels may be reduced to one inch for certain applications.
This applies to both vendor installed and field installed wiring and includes the inter-relationship between both.
Detailed information is included in the Wyle Labs document entitled " Test Report on Electrical Spectrum Verification Testing". We are currently completing our evaluation of the report and will submit this information to NRR along with the DLC conclusions by June 15, 1985. We are currently revising the appropriate field construction procedures in order to implement this reduced separation criteria as verified by the test results.
DUQUESNE LIGHT COMPANY By f J.'M Vrey (/ Vice President 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 SUBSCRIBED AND SWOR'i TO BEFORE ME THIS ' M DAY Or t3/ , 1985.
/ b4ll W - ' Notary Public >#tstA s. FAlleet. setAtt Putti: SMiPPl#GPoel test SEAuf e CBust? df COSel56404 HPsell SIPI.16,1985 meaner, Peeneyeveen Aseeessease of noteres
- _ _ _ _ _ _ _ _ _ _ _ _ _ _
- Unitcd Stctos Nuclocr RJgulctory Comnission
. Mr. Richcrd W. Sterostccki USNR IE Inspection Report No. 50-412/85-05 Page 7 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF BEAVER ) On this / [ day of [[tft/ [D before me, a , Notary Public in and for said Commonw[alth and County, personally appe ared 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.
4.<//1 YM-M@ Notary Public ' antiLA 5. FAff001. NOTABY P90LIC 5#6PPl8GP0010000. SEAvts CDusff NT COGN68&80# ERPetil MPT.14.1985 h. Pennsylvanie Asesuehen of notenes - .. _. }}