IR 05000412/1986002

Insp Rept 50-412/86-02 on 860106-0210.No Violation Noted. Concerns in Area of Flushing Sys Identified.Major Areas Inspected:Previously Identified Unresolved Items & Environ Qualification of Electrical Termination Blocks

ML20141N214
Person / Time
Site:	Beaver Valley
Issue date:	02/24/1986
From:	Prividy L, Lester Tripp, Walton G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141N212	List: IR 05000412/1986002 ML20141N211
References
50-412-86-02, 50-412-86-2, IEIN-85-045, IEIN-85-45, NUDOCS 8603040501
Download: ML20141N214 (19)

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U. S. NUCLEAR REGULATORY COPHISSION

REGION I

R: port N /86-02 Docket N License N CPPR-105 Priority -- Ca te' gory B Licensee: Duquesne Light Company P. O. Box 328 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Station, Unit 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: January 6 - February 10, 1986 Inspectors:

/$ k.' N a d W G. A. Walton,' Senior Resident Inspector

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J. Pr'vidy, Resident Inspector fA . I.9, i 9h date Approved by: h.h M t. E. Tryp, Chief, Reactor Projects MtM

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'date Section 3A Inspection Summary: Inspection on January 6 - February 10, '1986 (Report No. 50-412/86-02).

Areas Inspected: Routine, unannounced inspection by two resident inspectors (253 hours0.00293 days <br />0.0703 hours <br />4.183201e-4 weeks <br />9.62665e-5 months <br />)

of activities pertaining to previously identified unresolved items, environmental qualifi-cation of electrical termination blocks and Raychem splices, installation of flexible conduit, cleanliness controls of equipment during flushing activities, measurement of pipe support clearances, reviews of steam generator shot peening, rework controls, technical reviews of engineering disposition and daily site tour Results: No violations were identified. This inspection did identify several concerns in the area of flushing systems involving control of tools and equipment, test control and i overall reactor vessel cleanliness control (Section 5); installation of unqualified elec-

. trical connectors (Sections 6 and 7); and installation problems with flexible conduits involving disengaged or loose couplings (Section 8). Other areas reviewed were found acceptabl gg ggg ggyg2

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L DETAILS Persons Attending Exit Interview Duquesne Light Company F. A. Arnold, Startup Group L. E. Arch, Senior Project Engineer R. Coupland, Director, Quality Control A. W. Crevasse, Quality Assurance Surveillance C. R. Davis, Director, Quality Assurance, Engineering D. W. Denning, Assistant Director, Quality Control J. J. Dusenberry, Quality Assurance C. E. Ewing, Manager,. Quality Assurance r S. D. Hall, Senior Compliance Engineer E. J. Horvath, Senior. Project Engineer J. A. Hultz, Construction Liasion D. C. Hunkele, Director, Quality Assurance, OPS C. E. Kirschner, Supervisor, Quality Assurance Engineering T. P. Noonan, Station Superintendent D. K. Rohm, Assistant Director, Quality Control R. J. Swiderski, Startup Manager L. P. Williams, Director, Construction Start-Up Stone and Webster Engineering f P. J. Bienick, Assistant Superintendent - Electrical H. W. Durkin, Superintendent of Engineering D. B. Lamson, Assistant Resident Engineer 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 observe The walk-through inspections identified several unresolved items relative to the use of Raychem splices and -terminal blocks in the Containment Building, improper installation of flexible conduit used in electric cable installation, and cleanliness controls of safety related ' equipment due to interaction of

! flushing and construction activities. These unresolved items are discussed

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in Paragraphs 5, 6, 7 and ,

No noncompliances were identifie I I I l

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3. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item'(85-19-01): Review of Part 21 Reports. A review by the inspector of vendor issued Part 21 Reports revealed the licensee had no formal program to review for reportability under the requirements of 10 CFR 50.55(e) those items reported by vendors. The licensee has taken the below listed actions to resolve this item:

- When a 10 CFR 21 report is received by the project from a vendor which identifies Beaver Valley, Unit 2, as an affected facility, the following procedure is established: The Stone and Webster Lead Licensing Engineer, or designee, shall promptly notify the Duquesne Light Company (DLC) Regulatory Affairs Department (RAD) of the 10 CFR 21 repor If the subject 10 CFR 21 report is determined not to be applicable to Beaver Valley or not reportable, then DLC RAD shall be furnished with a copy of the documentation indicating this determinatio These changes will provide the licensee with auditable and retrievable documentation of those Part 21 evaluations that resulted in a negative reportability and assurances that all applicable issues have been adequately evaluate Based on the 50.55(e) applicability reviews being performed by the licensee to resolve tais item, the licensee found a potentially reportable item dealing with K-line circuit breakers and on November 22, 1985, the licensee notified Region I. Several other items were reviewed and determined to be "not

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reportable . "

In a previous inspection, the inspector no'ted that a Part 21 report had been issued on snubber brackets furnished by Paul-Munroe Hydraulic It was suspected that incorrect bracket material was supplied to Beaver Valley, Unit 2. Stone and Webster issued a stop work order on related work until an evaluation was received from Paul-Munroe Hydraulic During this inspection, Stone and Webster received a copy of Paul-Munroe's final report on snubber bracket materials. Paul-Munroe concluded that incorrect bracket material was supplied to Beaver Valley, Unit 2. Paul-Munroe corrected this error by supplying Beaver Valley, Unit 2, with new pipe snubber brackets made from the specified materials. Stone and Webster and DLC now have the information necessary to determine the proper corrective action and reportability under 10 CFR 50.55(e) requirements. The inspector concluded that this Part 21 report, which affected Beaver Valley, Unit 2, was receiving adequate corrective action Based on the licensee's revised program, this item was .found acceptable arid this item is close /

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(Closed) Unresolved Item (85-13-04): Rework control of valve. The inspector had observed four missing nuts and bolts from a valve installed in a piping assembly. The licensee could not produce any documents for control of the disassembly and reassembly. Also, tl.e missing material could not be located. The item was unresolved pending resolution of this ite The licensee has taken the following actions on this ite Upon identification of this condition, the mechanical contractor performed an investigation of work activities in June,1985, in the area of VGW-015-X-2 to determine the cause of the missing nuts and bolts. This investigation revealed that no authorized work had been performed on that system in 1985 prior to identification of the valve condition by the NRC inspector. However, the investigation did not determine the source of the missing valve hardwar FCP-302, Removal or Disassembly / Reassembly of Permanent Plant Equipment was reviewed and detennined to establish the necessary requirements to cont;ol valve rework. The VGW-015-X-2 condition has been identified on Nonconformance and Disposition 29077 which has been dispositioned by Engineering to replace the missing nuts and bolts. To preclude recurrence of this condition, the mtchanical contractor restressed to his supervisory personnel the need to strictly enforce the rework control program requirements and that disciplinary action would be taken for any future occurrences. Since the time this valve condition was identified, the mechanical contractor supervision has been functioning to preclude recurrence as evidenced by no other valves being identified as having been disassembled witbut proper authorization. This performance has been monitored informall' Jy Site Quality Control concurrent with Inspection Procedure 7.35, SurveilLnce of General Construction Activitie To ensure continued acceptable performance in this area, Site Quality Control revised Inspection Procedure 7.35 to include a formal surveillance of valve disassembly activities for compliance with procedure The inspector reviewed the licensee's and contractor's actions on this item and found the revised actions acceptable. This item is close (Closed) CDR (85-00-05): Insufficient thickness of insulating tape on terminations. An incorrect number of layers of insulating tape was specified on Stone and Webster Drawing 12241-RE28A-4 for 5 KV terminations under Details E-1, F, and G. Forty-six (46) terminations had been made due to the erroneous drawing specification The deficient taping rracedures were used at the electrical connection to various safety-related 4.16 KV motors. The total thickness of insulating tape specified on drawing 12241-RE-28A-4 would be approximately 120 mil as compared to 500 mil specified by the manufacturer (Kerite Company).

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Most of the deficient terminations were located in, or were scheduled to be located in a harsh environment. The significant reduction in insulating tape thickness below the manufacturer's requirements is considered to be sufficient basis for assuming the termination could fail prematurel Failure of the tennination could result in loss of operation of a connected 4.16 KV safety-related motor.

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The inspector reviewed the . licensee's corrective actions on this ite This included a review of the applicable E&DCR (2P-4827) and specification 2BVS-931. The specification revision also included specific instruction for use of bolts, nuts, and washers on connecting splices. The revision states " Field cable terminations at the 4160 volt metal-clad switchgear shall be completed with stainless steel bolts, nuts, flatwashers, and belleville washers regardless of contact surface composition (i.e.,

aluminum or copper)."

In addition, specific instructions are stated in E&DCR Number 2P-4827 to rework terminations at the 4160 V switchgear and install the stainless steel bolts, nuts, and washer All affected terminations are being reworked to comply with the manufacturer's

requirements and all drawings and specifications have been appropriately i revised. This item is close (Closed) Unresolved Item (85-05-04): Manual changes to computerized ticket This unresolved item was identified in a past inspection where the inspector observed manual changes to pull tension values on ' computerized cable pull tickets and it was not clear that proper engineering authorization was being received for these changes. At the time that.this open item was identified, the Stone and Webster Superintendent of Site Engineering (SEG) issued a memo (Site 2BVM-3695 dated February 25,1985) to Construction which included a

verification list of those SEG personnel authorized to approve manual changes to pull tickets. This verification list also contained the signed initials of the authorized individuals. This memo and associated verification list served to clarify the vagueness that existed in obtai7ing proper authorization of manual changes to computerized tickets. During this inspection the inspector determined that additional issues of the SEG authorized personnel verification list have been issued since the initial list was issued on February 25, 198 These additional issues of the verification list were issued to account for changes to personnel. The last issue of the verification list was transmitted to Construction by memo 2BVM-4057 dated January 15, 1986. Separately, the inspector discussed this subject with an SQC inspector in the field as Construction was setting up to do a cable pull in the Service Building. The SQC inspector indicated that he was familiar with the verification list defining the SEG authorized personnel for manual changes to computerized tickets. He had not experienced any problems in verifying the proper authorization of such changes in the past six month Based on these findings, the inspector. found this item acceptable. This item is close _--

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(Closed) Unresolved Item (84-18-07): Cleanliness controls of reactor vessel internalt During routine inspections of the upper reactor vessel internals, the inspet or had observed foreign material (steel chips, etc.) in internal ledges of the internals. The item was unresolved pending review of the cleaning procedures to assure adequate cleaning would occur. In addition, the inspector requested notification when .the cleaning commence On January 10,1986, the 1.censee commenced cleaning using Westinghouse approved procedures. The inspector was provided a copy of Procedure 2463A54, Revision 8 and Process Specification 292722, Revision 9. The procedure specifies removal of all tape, residue, grease, oil, fingerprints, etc.,

and washing of the entire assembly with high pressure dernineralized water between 100 psi and 1000 psi. Their inspection for cleanliness is specified in the procedur The inspector witnessed the cleaning operation in progress on January 10, 1986, and again on January 13, 1986. The inspector verified the test pressure was adequate (900-950 psi actual) and coverage was sufficient to remove any foreign material present. The inspector found all areas reviewed acceptable and this item is close (0 pen) Unresolved Item (83-02-04): Shimming of electrical baseplate This item is related to the shimming requirements for electrical baseplate installations. The concern was originally identified in cable tray support installations in the Service Building. Based on this concern, Stone and Webster Engineering established a maximum gap criteria of 1/16 inch for plates 1/2 inch thick. This item was discussed in Inspection Reports 50/412-83,12, 84-03 and 84-11. In subsequent meetings and inspections, the licensee advised new criteria were established, specifically allowing a gap up to 1/8 inch between the concrete wall and baseplate without shimming. Inspection Report 50-412/85-24 discussed the additional items needed to support the 1/8 inch criteria. These concerns ir.cluded calculations being made to support this position and revisions of the specification and inspection procedure The licensee has now completed the calculations which show the 1/8 inch gap acceptable. In addition, the inspection procedure has been revised. The inspector found adequate controls are in place for new installed baseplate However, the licensee has to reinspect previously installed baseplates to assure they meet the specification. One area identified by the inspector regarded the previously installed shims which do not appear to provide the necessary support around the concrete anchor bolt. The installed shims are not the cor-rect configuratio This item is unresolved pending a review of the licensee's reinspection program planned to identify and correct shims, or lack of, on previously installed baseplate l

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(0 pen) Unresolved Item (83-05-06): Torquing of concrete expansion anchor bolts on electrical baseplates. This item was related to the lack of a formal procedure for control and documentation of retorquing of concrete expansion anchor bolts as a result of loosening or removing of bolt nuts or baseplates during construction. One concern which remained unresolved was the need to establish those areas (by building) which needed a 100 percent retorquing of concrete expansion anchor bolts. The licensee has completed the sampling program and informed the inspector that comencing February 13, 1986, a 100 percent retorquing program will start in the Main Steam Cable Vault, Auxiliary and Auxiliary Cable Tunnel Building The licensee has determined that based on a sampling program, all other buildings are acceptable and no further torquing of anchor bolts is necessary. This item continues unresolved pending further review of the licensee's retorquing progra (0 pen) Unresolved Item (84-14-03): Engineering Confirmation Progra The inspector reviewed recent efforts and developments concerning the various technical items identified by Duquesne Light Company (DLC) in the Design Bases Endorsement Follow On Program. The main purpose of the DBE Follow On Program was to follow through completion those unresolved issues that DLC had identified during the initial DLC effort of the Engineering Confir-mation Progra The inspector reviewed the DLC December,1985 and January,1986 status reports of the DBE Follow On Program. Also, the inspector met with DLC ersonnel to discuss the effort being devoted to the recheck of various electrical calculations. Two significant items occurred as evidenced by the following comments extracted from the December, 1985 report (2ASR-02167,12/20/85) and January, 1986 report (2ASR-02206, 1/30/86) respectively:

- In December 1985, DLC completed their review of E-72, Revision 1, 4.16 KV Cable Sizing. DLC's coments documented in 2DLC-8537 indicate 3 cables under 70 feet of length will experience temperatures greater than 5500C (see 2BVM-42) for a 3 phase fault at the transfer switc To alleviate the problem with least impact on construction, both DLC and SWEC agree (see 2ASR-02155) that ,using .

another 1/0 parallel cable per phase will be the resolution for two cases. The third case will involve pulling out the existing cable and using a larger conducto Based on the weakness identified in SWEC calculation -E-72, Re "4.16KV Cable Sizing", which also affected E-20; SWEC calculation E-80 Rev. O entitled "600 Volt Cable Sizing for Motors Fed from 480 Volt Loaded Centers" will be added under the DBE Progra .

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The three affected cables are 2CCPC0H301, 2CHSCPH301, and 2CHSC0H301 which are 4160 volt cables associated with the charging pump and the component cooling water pump that are powered from the swing bus. With respect to the electrical calculati'on review, this is the first instance where safety related hardware required modification as a result of coments gcnerated by DLC to Stone and Webster during the Engineering Confirmation Program. As noted above, DLC has selected another electr.ical calculation E-80, Rev. 0

"600 Volt Cable Sizing for Motors Fed from 480 Volt Load Centers."

The inspector will continue to monitor and report this item in future inspection (0 pen) Unresolved. Item (83-05-01) (External) Wraps and Covers. Install.ation of wraps on cable and covers on trays is an acceptable method of complying with electrical separation requirements of R.G.1.75 when enough physical separation is not obtainabl During this inspection. period, the licensee issued an updated version of the Project Electrical Plan which included the current status and projected work required to resolve this item. Also, the inspector met with DLC Engineering personnel and discussed this item. Pertinent points discussed which describe the recent activity on this item are as follows: Engineering documents have been and are being. changed to reflect the current requirements for cable tray covers and. cable tra The FSAR was changed and the revisions were reflected in Amendment 11 issued in January 1986. 2BVM-41, " Criteria for Design and Identification of Electrical- Cable and Raceway Systems", and 2BVM-173, " Procedure for Implementation of Electrical Separation (R.G.1.75 Requirements)",

still need to be revised to refl.ect current requirements. Engineering has reviewed and revised all the RE-30 series drawings to reflect required covers - top and bottom, raised, ventilated and flat. The attachment details for the covers are provided by drawing RE-398 . It is estimated that approximately a total of 40,000 feet of tray cover of all types will be required to complete this item which

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translates into approximately 40,000 manhour . Engineering walkdowns are being conducted to identify and tag all transitions requiring wrap. There are approximately 11,500 "ansitions and it is estimated that approximately 6,000 transitions are expected to require wrap which translates into approximately 18,000 manhour In the buildings where walkdowns have been completed, a total of 600 wraps have been identified. The following buildings require Engineering walkdown:

Cable Tunnel Control Building Cooling Tower Condensate Polishing Building Health Physics Main Steam and Cable Vault Reactor Containment Service Building These walkdowns are planned for completion by June 30, 198 , . - . .. - - -

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. .The actual work to install any cable tray cover or cable wrap has not yet started. DLC indicated that this work is planned to start by -

March 1, 198 This item continues open pending review of the entire R.G. 1.75 issue and its implementatio (0 pen) Weakness (85-07-01): Project Management Weakness. This weakness

, was identified in the Construction Team Inspection conducted by Region I inspectors in March, 1985. A particular observation made during that inspection was that the DLC Nuclear Construction Division Procedures Manual required substantial revisions in the areas of Section 1.0, Management; Section 5.0, Construction; and Section 7.0, Project Contro During this inspection the inspector reviewed the status of the DLC Nuclear Construction Division Procedures ibnual. The inspector determined that various procedures in Sections 1.0, 5.0 and 7.0 had been revised by October,1985 to reflect the current status and management of the projec In particular, Section 5.0, Construction, was deleted as 'the majority of its duties were transferred to the Startup Group which is defined in the Startup Manual . The inspector. observed- that Procedure No.1.2 " Functional Organization and Responsibilities" had not yet.been revised to reflect the project management reorganization which included the assignment of M Jack A. Kline to the position of thnager of Engineering and Constructio The inspector was informed that a preliminary issue of Nuclear Construction Division Procedure No.1.2 had been compiled to reflect this recent project personnel change and it was being circulated for review and commen .

The revised Procedure No. 1.2 was expected,to be-issued in March, 198 As a separate matter not particularly related to revision of the DLC Nuclear Division Procedures Manual, the inspector noted that Mr. Kline had conducted

the past several weekly Site Manager Meetings. Previously, this key meeting, t

which is held to discuss the status of significant problems and determine their impact on construction, had been conducted _ by the DLC Vice-President,

Nuclear Grou This item continues open pending additional review of the project management ,

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(0 pen) Unresolved Item (85-16-02): Clearance of electric cable from hot pip This item is unresolved pending implementation of the licensee's program to determine if electric cable in close proximity to hot pipe could affect the service duty of the cable. Stone and Webster Engineering had advised the inspector that comments received at another site suggesting that cable installation was performed with inadequate consideration given to the impact on cable due to temperature effects from nearby hot piping or surface The current electrical installation specification 2BVS-931, has a 6 inch clearance requirement to prevent physical cable damage for seismic consideration Specifically, the comments received indicated that cables should be physically separated from hot piping a sufficient distance consistent with rated current capacity of the cable and consistent with qualification data of the cable itsel If such requirements are not taken into consideration, then possibly cables would operate at higher environmental temperatures than allowabl .

Stone and Webster Engineering has now completed the electrical and heat balance calculations and issued BVM 237 which defines pipe temperatures,

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sizes and minimum cable separation requirements for each pipe size and location. Stone and Webster Engineering has performed walkdown of 460 raceways and identified 65 conditions which fails to meet the criteria established in BVM-237. Engineering will disposition each specific deficiency based on appropriate criteria. For example, some cable may require rework (reroute), cable insulation, or cable derating. At present, engineering disposition has not comenced. The inspector met with Stone and Webster Engineering personnel from Boston and discussed the program and status. Based on the inspector's limited review, all items were found acceptable. However, this item will remain open pending further reviews of the walkdown inspection and disposition of the deficiencie . Flux Mapping System Interaction with Seal Table - IE Information Notice 85-45 This information notice was sent to power reactor facilities to alert these facilities of a potentially generic problem involving seismic interactions within the movable flux mapping system at Westinghouse designed plant Specifically, on June 22, 1984, Carolina Power and Light Company informed the Nuclear Regulatory Commission of a potentially reportable item per the provisions of 10 CFR 50.55(e) and 10 CFR 21 at their Shearon Harris Nuclear Power Plant, Unit The potential interactions exist because portions of the flux mapping system that have not been seismically analyzed are located directly above the in-core instrumentation tubing / seal table. Failure during a seismic event could possibly cause multiple failures in the flux mapping tubing or fittings that would produce a small break loss of coolant acciden Recent discussions with Westinghouse had revealed that the potential seismic interactions could exist at other Westinghouse plants including operating plants. Furthermore, multiple failures of flux mapping tubing and/or fittings constitute an unanalyzed small break loss of coolant accident because the break flow would effectively be from the bottom of the reactor. vessel . Thus, the consequences could be beyond the licensing design bases for loss of coolant accident .

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Stone and Webster (S&W) and DLC have reviewed this item for apolicability to Beaver Valley, Unit 2. This review noted that the safety-related thimble seal table, mounted horizontally at Elevation 738 f t.10 in, of the Contain-- -

ment Building can be potentially impacted by the_following non-safety-related equipment: The thimble withdrawal support structure located directly -

over the seal table,

' The ten-path rotary transfer mounted on a movable frame next to the seal table, The five-path rotary transfer mounted on a fixed frame'and located behind the ten-path rotary transfe Stone and Webster and DLC made the following determinations: The supports for the thimble withdrawal structure are Seismic Category II, and thus are designed and constructed to maintain structural integrity under a seismic even . Under the Hazard Analysis Program,'it has been determined that the configuration of the ten-path and five-path rotary transfer devices with their associated frames are such that no adverse interactions are possible with the seal tabl Based on these determinations, S&W and DLC have concluded that no adverse conditions exist for interaction between the flux mapping system and the seal table at Beaver Valley, Unit The inspector found the review of this item acceptabl . Control of Safety Related Equipment in Areas of Interaction ~of Flushing and Construction Activitie The inspector reviewed some of the activities of DLC.Startup Group (SVG)

personnel as they made various preparations to conduct Test Procedure N T-SIS-11-1.03, " Safety Injection System Flush". Specifically, the inspector reviewed the following: Communications established to monitor the flush path . Briefing of test personnel to ensure that they were familiar with the needs for the tes . Procedures used to install temporary test equipmen . Precautions implemented in conducting the flush activities and the test preparation .

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The inspector reviewed these items by reviewing the procedure, discussing the procedure and flush activities with several DLC-SUG personnel, and walking down portions of the Safety Injection System piping involved in the flush paths. At the time of this inspection, DLC-SUG personnel were still making preparations for Test Procedure No. 2T-SIS-11-1.03. Several leaks had occurred at temporary test equipment while making preparations and the first flush path had not yet been satisfactorily establishe The inspector determined that the test personnel were well acquainted with the procedures established in the DLC Startup Manual which defines the requirements for the flushing activities. The DLC Flush Engineer responsible for conducting Test Procedure 2T-SIS-11-1.03 had the official copy of this procedure executed properly to the point in the procedure where activities had been conducte The pretest briefing of the test personnel had been properly conducted and the valve lineup had been completed. Grade A water was required as the flushing medium for this test and the DLC Flush Engineer had verified that the flush water met these requirements. In walking down a portion of the safety injection system piping, the inspector concluded that adequate comunications were being utilized by the test personnel. While normal Gai-Tronics phones were available at several locations to test personnel, the test personnel relied predominantly on portable radio communications since this provided a fast response. The inspector observed test personnel with such comunication equipment in the charging pump cubicles in the Auxiliary Building, at' the reactor vessel flange area in Containment and at the flush water pumping sourc Other inspection aspects were noted by the inspector during the walkdown of the Safety Injection System piping. These aspects caused concerns to the inspector in that certain items found lied the potential for creating wide-spread, bad work practices with associated safety and quality implications to safety-related equipment. The items included in this category were tool control and general cleanliness control in the reactor vessel flange area, definition and control of temporary test equipment being used inside reactor coolant loop piping, and temporary test equipment installed in the charging pump cubicle The inspector observed the temporary flush equipment installed in the refueling water cavity in the vicinity of the reactor vessel flange are At this elevation, a temporary walkway and lay down area was installed to facilitate testing with access provided to the inside of the reactor vessel. No internals were installed in the vessel at this time. The flush paths for Test Procedure No. 2T-SIS-11-I.03 direct flush water through the Safety Injection System and then the flush water exits the 6-inch Safety Injection System loop penetrations via temporary hoses installed at these penetrations. These hoses exit the reactor coolant piping nozzles at the reactor vessel. At this point, the temporary hoses attach to a temporary piping manifold utilized for this flush with this manifold located at the reactor vessel flange area. Makir.g these temporary connections and filling the Safety Injection System piping with water resulted in flush

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water entering the reactor vessel. At the time of this inspection, the inspector observed the reactor vessel to be approximately half fille At the temporary walkway and laydown area at the reactor vessel flange area the inspector observed various hand tools, wood staging and other loose articles which had the potential for falling into the reactor vessel and causing contaminatio Associated with the item above, the inspector determined in discussions with DLC-SUG personnel that a special adapter was necessary to adapt the flush hose to each 6-inch safety injection loop penetration. This special adapter consisted of a 90 degree elbow which fit into the Safety Injection System piping at the loop penetration.. The other end of this elbow protruded into the run of the loop piping where it was connected to the flush hos The outer radius of the 90 degree elbow was fit to a brace which was contoured to the I.D. of the reactor coolant piping. The brace was designed to hold the elbow in place in the penetration during the flush. The inspector questioned how these special parts were made and installed. DLC-SUG personnel indicated that field sketches were made to define what was necessary and these parts were fabricated on site by the mechanical contractor. DLC-SUG personnel indicated that most of the parts were made of stainless stee The inspector requested a copy of the field sketches defining these special adapter The last item that the inspector found which had the potential for creating less than desirable work practices concerned the use of temporary fire hoses used in the charging pump cubicles. These fire hoses were installed to bypass the charging pumps during the flush. This was done for two charging pumps and in each case, the temporary fire hose was resting on a detector element for instrumentation associated with the charging pump motor with the resultant potential of damaging the detecto The inspector discussed these concerns with the DLC-SVG Flushing Superviso The inspector advised the licensee that this item remains open pending resolution by the licensee of these concerns. (86-02-04).

6. Environmental Qualification of Electrical Equipment During walk-thru inspections in the lower elevation of the reactor containment building, the inspector took note of electrical junction boxes installed at elevation 701'11". Subsequent drawing reviews (Dwg. 1-110-C130, and other associated drawings) found the junction boxes 0883, 0884, 0886 are used to make connections for instruments 2 DAS LE220, 2 DAS LE222 and 2 RSS LE151 These devices are used to monitor water level in the containment and provide level signals to (2 RSS-LYH 151A) to activate the computer (L0708D) and annunciator Al-3 The FSAR Section 6.2.2 states the maximum water level in containment during a LOCA is at elevation 708'2". Therefore, during a LOCA, the above described junction boxes could be submerged 6'3" in hot water. Further, Section 8.3.3.1.1 of the Safety Evaluation Report (SER) states "By letter dated October 10, 1984, the applicant indicated that all Class 1E equipment with the potential for being submerged as a result of a LOCA is electrically tripped by a high level indication. The sensors for this level indication are to be qualified for submergence . . . ".

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As shown on Drawings RE 4-HA, RE 4-HB, RE - 28E and RE 57V, the junction boxes listed above are to be spliced in vented junction boxes using Raychem splicing kit NPKV. Also, as stated in Volume 1 of the FSAR, " Equipment Qualification Report" under title "IEEE 323-1974 Status of Equipment Whose Qualification Is Complete", Purchase Order 2BV-931;Raychem Splice Kits is listed as complet The inspector performed a review of Environmental Report 58442-1.2.3 and Supplement which was performed to qualify the Raychem splice NPKV ki The review of this document found the Raychem NPKV kit was not qualified for submergence. No further qualifications were scheduled. In a meeting on February 4,1986, with Stone and Webster Engineering, they agreed the subject splices were not qualified for submergence and therefore, the junction boxes would be required to be moved above the anticipated flood plane. This item is unresolved pending further reviews. The basis for not issuing a violation at this time on this item is twofold. First, the cable and splices were not completed in the subject junction boxes and second, Duquesne Light Engineering is scheduled to review the E.Q. program. This particular qualification report had not been reviewed by DLC Engineering. Therefore, this item is unresolved (86-02-01).

7. Installation of Electrical Termination Blocks In Containment During walk-thru inspections in the containment building (elevation 698'),

the inspector opened junction box 0096 and noted termination blocks were used to terminate wiring to system 2 CCP*A0V170 and 2 CCP*S0V170. A subsequent review of the drawing (RE 10 AB) found a splice was required in lieu of termination blocks. An earlier revision (Revision 4) of the drawing had specified a termination block. Further reviews by the' inspector found the original computer issued termination tickets re. quire a termination block. After installation, the termination ticket was manually changed to read " Splice". The change was made to comply witn the new drawing revision that now required a splice. From all indications, the manually changed termination ticket was never issued to the field to perform the wor Subsequent to the manual change, a new computer issued termination ticket was received from Boston which specified the correct drawing revision and the correct splicing. It appears the receiver' (reviewer) noted the previously manually changed termination ticket in the files and assumed the work had been completed and also filed the new ticket. As a result, the termination block was never replaced.with a splic The licensees basis for changing to a splice is the termination block is not environmentally qualified for installation in containment. After the inspector advised the licensee of the install d termination block, they'then issued the splice ticket and changed the termination block to a Raychem splice. The inspector further advised this splice was also unacceptable because it is

.below the flood plane .in containment and splices are ~not qualified-for submergenc .

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Final Quality Control inspection to the latest revision of the issued drawing had not yet been performed. Therefore, this condition should have subsequently been found by Quality Control. Therefore, this item is unresolved based on the need for the contractor to establish a method to assure issued tickets are sent to the field for proper work. The licensee advised they are in the process of reviewing all previously issued termination tickets (approximately 40,000) to determine if other mistakes were made. This review will take approximately 3 - 4 months. (86-02-02).

8. Flexible Conduit Connection During a walk-thru inspection in the Main Steam ar.d Cable Vault area (MSCV),

the inspector observed a flexible conduit (2CC9370H) disengaged from its coupling. Further reviews of the installation found there is a split lock-nut which is supposed to screw onto the exterior ridges of the flexible conduit to hold the conduit to the couple In this case, the split lock-nut was not screwed on the flexible conduit and had dropped away from the couplin To determine if this condition was an isolated case, the licensee implemented a sample inspection program in various buildings. The sample, performed on 532 flexible conduit connections found 29 conduits had the flex disengaged fron the coupling. In addition, the licensee found 195 connections had loose couplings. The deficient conditions were reported on Nonconformance and Disposition Reports (N&Ds) 16600 and 16602. The N&Ds were dispositioned by Engineering as rework. In addition, the N&Ds included instructions for proper installation of the couplin The vendors installation instruction apparently were never issued to the fiel The licensee has revised the Q.C. Inspection Plan 8.5.2.2, 8.3.3 and 8.1.9 to include inspection criteria for these coupling The licensee has commenced an inspection and rework program of all flex conduit couplings. The plans are as follows:

- One crew will perform the rework for the conduits, which have been identified on N&Ds 16600 and 1660 One crew will check and rework, as necessary, the conduits in those buildings which have not been inspected by QC. On completion of an area, QC will perform an inspectio This item is unresolved pending further review of the licensee's planned rework progra (86-02-03).

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9. Measurenent For Pipe Support Clearances During routine discussions with Quality Control Inspectors, the inspector was advised of a concern they had with the methods used to measure minimum clearances betwera the pipe support and the pipe. The inspector pursued this issue to determine if adequate instructions existed. The governing specification - 2 BVS-920 stated that a minimum gap of " visible daylight" was required between the support and the pipe. Subsequently, an "RI" (request for information) was written by Engineering, which stated the dimension should be taken at the center of the support; i.e., on a 4 inch wide tube steel support, the reading v;ould be taken 2 inches from the edg This indicated contact at the edges is acceptable. The Q.C. inspectors were concerned about the correctness of this R Subsequent meetings held with Engineering resulted in issuance of an E&DCR (4189) which clarifies the requirements. The issuance of the E&DCR requires a change to specification 2 BVS-920 to read:

The minimum total clearance shall be maintained as opposite points along the entire restraining surfaces of restraining members (see example). The total maximum clearance shall be maintained at any one or more opposite points along the restraining surfaces. The construction contractor shall make every effort to install restraining surfaces paralle Point contact between pipe and restraining members on opposite sides of restraining surfaces (as depicted on the example) is acceptable provided the minimum / maximum requirements are opposite points, as stated above, are maintaine The E&DCR further stated no backfit rework or Quality Control inspection of previously installed hardware was necessary. Subsequent to the issuance of the E&DCR, Q.C. revised and issued Inspection Procedure 7.3.1 and training handout TCO-VIIL. The inspector discussed the above changes with the concerned inspectors and they advised they were now satisfied with the instructions. Based on the changes made by Engineering and revisions made to the IPs and training handouts, this item is acceptabl . Electrical Symbol Designation for Power to 2 MSS-S0V105B During a review of the FSAR concerning the steam supply components to the turbine driven auxiliary feed pump, the inspector noted a discrepancy in the electrical symbol designation for 2 MSS-S0V105B when comparing FSAR Figures 10.3-2 anz:1 7.3-54. 2 MSS-S0V105B is one of the two in-line solenoid '

valves for the steam supply to the turbine driven auxiliary feed pump from the "B" steam generato FSAR Figure 10.3-2 had an electrical symbol designation of "B0" and FSAR Figure 7.3-54 had an electrical symbol designation of "BP". The "B0" designation means that the "B" mechanical flow

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path is powered from the arange ("0") cable color while the "BP" designation

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means the "B" mechanical flow path is powered from the purple ("P") cable color. The inspector suspected that the proper electrical symbol designation for 2 MSS-S0V105B was "BP" as shown on FSAR Figure 7.3-5 The inspector discussed this discrepancy with Stone and Webster Engineering Corporation personnel. The inspector. was advised that this discrepancy was a corrected in a recent_ amendment to the FSAR. The discrepancy was discovered

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by the inspector as he reviewed Figure 10.3-2.which was part of Amendment 7 (July,1984) to the FSAR. Amendment 11 (January,1986) to the FSAR corrected the electrical symbol designation for 2 MSS-50V105B from "B0" to "BP".

The inspector found the review of_ this item acceptabl . Corrosion in Snubbers Supplied by Paul-Munroe Company The inspector had expressed a concern which was prompted by a report of a potentially generic issue concerning corrosion between phenolic seals and metallic components in snubbers supplied by Paul-Munroe Company. This problem had been experienced at Arkansas Nuclear One - Unit 1 on reactor coolant pump snubbers. The licensee corrected the problem by replacing all phenolic - type seals with seals made of tefze ]

Stone and Webster and DLC have reviewed this concern for Beaver Valley, Unit 2.

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Paul-Munroe Company is not supplying large equipment snubbers such as the problem ones for the reactor coolant pumps encountered at Arkansas Nuclear One - Unit 1. At Beaver Valley, Unit 2, Paul-Munroe is supplying only the smaller pipe snubbers and these utilize tefzel seals. Also, Stone and Webster and DLC noted that the large equipment snubbers are manufactured by Bergen-Patterson and they will use tefzel seals.

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The inspector found the review of this item acceptable.

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1 Pipe Support Installation The inspector selected pipe support number 2FWS-PSST 017 and performed a detailed inspection to ascertain compliance with specification and drawin The drawing 12241-BZ-178-9-2C was modified by E&DCR 2 PA 20103. The inspector verified the welds were completed in accordance with the drawing, support s was on location, support configuration and load distribution was correct and threaded connections were properly installed per drawing requirement The inspector also verified Quality Control had performed adequate inspections and documentation was complete. The inspector verified the support was seismically designed and constructed. All areas reviewed by the inspector were found acceptable.

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13. Shot Peening'of Steam Generator Tubes The licensee has contracted Babcock and Wilcox Company to perform " shot peening" on the inside surface of the steam generator tubes. The area covered commences at the tube to tubesheet weld and extends up through the tube for a distance equal to the tube sheet thickness. The shot peening is to relieve stresses in the tubes and extend their operating life. The inspector had several discussions with Duquesne Light Engineering personnel regarding the shot peening. In addition, the inspector reviewed Babcock and Wilcox Company procedures applicable for the program. The inspector witnessed portions of the shot peening being dont on "C" steam generato All areas reviewed by the inspector were found acceptabl .

14. Installation of Bolting on Fuel Pool Heat Exchangers -

The inspector reviewed the installation controls for connecting the fuel pool heat exchangers to the concrete pedestals. The review included a visual insp-ect. ion of the heat exchangers, and reviews of specifications 2 BVS-3 and 2 BVS-92 The inspector found adequate controls were shown to assure the fixed support bolting would be properly torqued and the slotted supports would be installed to allow for thermal growth. All areas reviewed were found acceptabl . Rework Controls on Feedwater Valve Operators The feedwater isolation valves operations were disassembled by Duquesne Light Company Start-Up Group due to erratic operatio The inspector audited the licensee's controls in this area to assure controls for disassembly were being implemented.

i The review found proper issuance and controls were inplace. Start-Up Work Requests (SWR) were issued for each of the three operator All areas reviewed by the inspector were found acceptabl l

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16. Review of Nonconformance and Dispositicg Reports The. inspector performed technical reviews of 15 Nonconformance and Disposition

. Reports (N&Ds) to ascertain compliance with applicable requirements and to assure good engineering practices were applied. The below listed N&Ds were reviewed:

8405, 8406, 8407, 8408, 8410, 8412, 8413, 8414, 8415, 8416, 8417, 8418, 8420, 8421 and 8424.

The inspector found good engineering decisions on each listed N&D. All i areas reviewed by the inspector were found acceptabl ,

17. Exit Interview t

A meeting was held with the licensee's representatives indicated in Paragraph 1 on February 10, 1986, to discuss the inspection scope and findings.

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