IR 05000412/1986047

Insp Rept 50-412/86-47 on 861215-19 & 870105-09.Violations Noted:Failure to Follow Procedures,Improper Storage of Cables & QC Program Did Not Detect Failure to Follow Procedures Over Extended Period of Time

ML20211E959
Person / Time
Site:	Beaver Valley
Issue date:	02/05/1987
From:	Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211E915	List: IR 05000412/1986047 ML20211E912 ML20211E929
References
50-412-86-47, NUDOCS 8702240455
Download: ML20211E959 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-47 Docket N License N CPPR-105 Priority Category B Licensee: Duquesne Light Company i Robinson Plaza Building No. 2 Suite No. 210 Pittsburgh, Pennsylvania Facility Name: Beaver Valley Unit No. 2 Inspection At: Shippingport, Pennsylvania

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Inspection Conducted: DAcember 15-19, 1986; January 5-9, 1987

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Inspectors: 1 17 C. ly/ W odar , actor 0 Engineer date~

Approved by: b L 9 C. f. Anderson, Chief Plant Systems Section date Inspection Summary: Inspection on December 15-19, 1986 and January 5-9, 1987 Report No. 50-412/86-47 Areas Inspected: A routine announced inspection by one region based inspector consisting of reviews of outstanding open items which had been presented by the licensee for closure. Additionally, the inspector conducted independent in-spections in the areas of the licensee's rework to achieve proper electrical separation and of the licensee's storage and protection of safety related electrical cable Results: Two violations were identified in the storage of electrical cable One of the violations resulted from failure to follow procedures. Another resulted from deficiencies in the licensees QC Program which did not detect the failure to follow procedures over an extended period of time. Five previously identified outstanding open items were close '

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DETAILS 1.0 Persons Contacted 1.1 Duquesne Light Company (DLC)

J. Carey, Vice President, Nuclear Group C. Ewing, Manager, Quality Assurance

• R. Swiderski, Start-Up Manager T. Noonan, Supervisor of Operations and Maintenance S. Fenner, Director, Quality Control

• C. Majumdar, Assistant Director Quality Control E. Horvath, Senior Project Engineer J. Godleski, Senior Test Engineer

• L. Rabenau, Compliance Engineer D. Butor, Maintenance Engineer B. Mills, Supervisor, Procedures Engineering

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• G. Wargo, Assistant Director Site Quality Control j l W. Haysman, Supervisor Receiving and Storage l R. Lawricella, Engineer B. Mills, Engineer B. Goff, Engineer l *J. Kasunick, Maintenance Director

• A. Lerczak, Operations Procedures Supervisor 1.2 Stone and Webster Engineering Corporation (S&W)

• Foley, Site Project Manager

• Bienick, Assistant Engineering Superintendent

• R. Wittchen, Licensing Engineer

• Byrnes, Assistant Project Manager 1.3 Sargent Electric Company (SECO)

T. Rosotone, Materials Supervisor F. Stark, Cable Yard Foreman E. Varsel, Quality Control Inspector C. Magby, Construction Worker U.S. Nuclear Regulatory Commission (NRC)

• C. Woodard, Reactor Engineer, Region I Headquarters

• J. Beall, Senior Resident Inspector Beaver Valley, Unit No. 2

• A. Asars, Resident Inspector, Beaver Valley Unit No. 2 W. Troskoski, Senior Resident Inspector, Beaver Valley Unit No. 1

Denotes those present at the exit intervie _ _ _ _ _ _ . _ _ _ _ _ _

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2.0 Licensee Action on Previously Identified Items 2.1 (Closed) Unresolved Item No.83-05-06 Inadequate licensee inspection requirements for verifying the final bolt tightness (torque) in the in-stallation of Hilti bolt The inspector reviewed licensee Inspection Plan IP-7.39 " Surveillance Inspection of The Retorque Testing of Hilti Concrete Expansion Anchors" dated July 11, 1983 which was implemented to cover the inspection of the torquing of all new installation The inspector also reviewed the licensee backfit program which was imple-mented to cover the retorque and retorque inspections of Hilti bolts installed prior to the implementation of Inspection Plan IP-7.3 The backfit program consisted first of a sampling plan inspection of the various plant. areas. The sampling inspection was found to be satisfactory for all plant areas except for the Auxiliary Building, Main Steam Cable Vault and the Cable Tunnel where 100 percent re-inspection was used In order to verify the effectiveness of the licensee Hilti Inspection program, the inspector randomly selected Hilti bolt installations in three plant areas and verified that these bolts were properly torque The inspector witnessed Sargent Electric Corporation personnel retorquing of the selected bolts using torque wrenches E22-1540 and L-11, both of which were calibrated on the day of use, January 8, 1987. Hilti installations inspected were the following:

No. Bolts Area Anchor Location Bolt size Tested EDG 2-1 11000-WTCX-6 1/2" 4 11035-AP-2 1/4" 2 11096-AP-2 1/4" 2 2HVD-THUH-236 3/8" 2 Conduits 2CK850B 2CC8540A,2CK9830A 1/2" 2 Service Building 35007-WTEX-6 3/4" 4 Cable Vault (Elev 735) 37018-QSX-1 5/8" 4 Cable Tunnel (ilev 735) 4034-BR-2 3/4" 4 34105-AP 3/8" 2 34106-AP 3/6" 2

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All of the above Hilti bolts were found to meet the inspection acceptance criteria of Inspection Plan IP 7. Based upon the licensee implementation and completion of a comprehensive backfit Hilti reinspection / torquing plan, the implementation of the ongoing Inspection Plan 7.39, and the sample inspection of Hilti's con-ducted by the inspector, this item is close .2 (Closed) Unresolved Item No. 85-21-02 pertaining to loose condulets installed in Class 1E instrument system The licensee evaluation of the cause was that in certain installations that required rotation of the condulet fitting to align with flexible conduit, the rotation for match-up sometimes resulted in loose fittin The inspector confirmed by review that the licensee had revised instal-lation procedure RE-529 to permit the use of locknuts to lock the con-dulet in place if adjustments loosen the condule The licensee per-formed 100 percent inspection and rework of all instrumentation condulet installations for proper size, type and tightness under E&DCR 2PQ-2086 The inspector confirmed by review that licensee inspection procedures IP8.5.2.2 and 8.1.9 have been revised to verify tightness of conduit fitting The inspectors confirmed by field inspection that the loose condulets found on the previous inspection had been corrected. Further, in random independent' inspection in the Diesel Generator Building, the Cable tunnel and in the service building, the inspector checked approximately 25 simi-lar condulet installations for tightness and found none loos This item is closed 2.3 (Closed) Unresolved Item 86-03-01 pertaining to the backpanels of the Diesel Generator (DG) control cubicles being removed, rendering the I & C equipment inside the cubicles exposed to the construction environment in the are The inspector had found that the DG System had been turned over from construction to the startup group; however, the DG Building had not yet been turned over and construction activity was still underway. The licensee did not have a program / procedure in place to control this type of situation This inspection revealed that in this specific case, the DG Panels had been returned from start-up to construction for rework and that was the reason for the removal of the back panels. Ongoing construction activity in the panels and in the area at the time did cause some dust and dirt to accumulate within the panel . . , --- , . - . - - .. . . - - . . -- - - _ _ - - . - - . - - - - ---- -.

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l The inspector reviewed the current DLC0 procedures for handling construc-tion rework and then turn over to startup/ operations. Procedures reviewed include the following:

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Start-up Manual Chapter 7.2.1 which describes the re-work program including section VI A 7 which requires cleanliness verification

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Start-up Manual Chapter 4.5 which describes the housekeeping program

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Start-up Manual Chapter 4.2 which describes scheduled equipment maintenanc (

An inspection was made of the inside of the EDG PNL*2DIGeni diesel gener-ator control panels. The in place procedures and the current condition of these panels was satisfactory. This item is close .4 (Closed) Unresolved Item No. 85-07-03 pertaining to the lack of formal -

procedures for treating existing installations when the engineering (

and/or acceptance criteria become more restrictiv The licensee has performed a review of the Engineering documents in their Change Control Document Reporting System (E&DCR Report) and has identified documents that contain generic design and/or acceptance criteria whose change may affect construction and QC inspection activities. Based upon the review, the project procedures for dispositioning of E&DCRs project procedures 2BVM-203, 2BVM-204 and 2BVM-94 relating to specifications and drawings revisions were revised to include specific instructions to the engineers to evaluate changes and identify any backfit inspection require-ments for existing installation In order to provide confidence that existing installations affected by changes in criteria had been reinspected, when required, prior to the revisions of the procedures, the licensee performed a sample review of the E&DCRS under a sampling plan developed to provide a confidence level of 95% with zero deficiencies allowed in the sample. The review of E&DCRs for affected drawings containing installation details identified no cri-teria changes which required reinspection of completed installations. The review of E&DCRs for installation specifications revealed that three required reinspection of completed installation The inspector reviewed the revised licensee procedues and verification and finds that the licensee has developed and implemented a formal program for treating existing installations when the engineering and/or acceptance criteria become more restrictiv This item is close .5 (Closed) Unresolved Item 86-04-02 pertaining to the preventative mainten-ance, surveillance and test programs for the emergency diesel generator The inspector noted that the 18 month, 3,6,and 9 year intervals for sur-veillance maintenance, (as are found in BV-Unit #1 instructions) appear to be lacking in the Unit #2 licensee surveillance instructio _ - .

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The inspector reviewed the licensee's surveillance / maintenance instruc-tions in detail. Findings are the following: For routine daily, weekly, bi-weekly, quarterly, annual / refuel the surveillance / maintenance instructions appear to provide coverag For other than routine surveillance / maintenance, the instructions refer to the Colt operations / maintenance manuals and to factory service personne The approach used by the licensee avoids translating what could be criti-cal manufacturers'/ factory maintenance / overhaul instructions including such things as removal / installation of such items as pistons, rods, et with the possibility of omitting or making errors in the translation of critical values (such as proper torquing of bolts). This inspector did not identify any deficiencies in the licensee's surveillance /maii.te-nance instructions and the approach to referencing the factory manual for major items. This item is close Electrical Cable Installation 3.1 Electrical Cable Separation The inspector reviewed the licensee's current program status to achieve electrical separation of cables as required in the licensee's Electrical Installation Specification 2BVS-931 by a review of the December 26, 1986 Electrical QC Performance Evaluation Report for UNR 82-05-01 and by a walkdown inspection in the emergency diesel generator building, the cable tunnel (elevation 735) and the cable spreading room (elevation 752).

During the walkdown inspection five cable separation discrepancies were identified which were not tagged for rework to correct the separation problem. These discrepancies were at the following cable transition points:

2CC1350H to 2TC1350 2CC1350K to 2TC1350 2CC1350L to 2TC1350 2TX130N to 2TX156N 2CC185NA to 2TC185N 2TC1360 to 2TC1390 2TC1360 to 2TC3260 2CC950PA to 2FC6640L 2CK600PB to 2TK600P Upon conclusion of the inspection, a review of the DLCO Color Separation Status Report with a sort by transition points was made. All of the above transition points are included in the report for rework to correct sepa-ration problems. Therefore the inspector had no further questions in this are .

3.2 Electrical Cable Storage Since the licensee still had additional cable to be pulled, the inspector conducted a walkdown-inspection of the Cable Storage Yard Location "P" and the Cable Staging Area (just inside Gate #9)

to assess licensee's compliance with electrical installation and construc-tion specifications in regards to storage, protection, and preventative maintenance as required by licensee specifications 2BVS-981 " Storage and Maintenance During Storage of Permanent Plant Equipment During the Con-struction Phase" and FCP-430 " Permanent Plant Cable Receiving, Storage, and Handling".(Cable raceipt, storage, handling and installation are by Sargent Electric Company under subcontract from DLCO).

The inspector found that the cable yard is within a secure fenced enclo-sure with access controlled by a guard gate. The cable reels are stored off the ground on railroad crosstie type lumber. Each cable reel is identified by a painted on code which identifies the cable within the Duquesne Light Company System. The reel is further identified by embossed metal tags secured to the reel by the cable manufacturer which provide detailed cable identification and purchasing details. Each cable reel is protected from the elements by a reinforced plastic cover secured to the top and sides of the cable ree The cable yard office, located within the cable yard maintains accounta-bility for all cable reels received with documentation of the cable type, reel number and numt,er of feet on the reel. When cable is requisitioned from the yard either by a complete reel or partial reel, yard records account for this withdrawal and reflect current status (location of the reel and number of feet of cable remaining on the reel). The record card for each reel reflects all partial withdrawals from the ree A review of these records and a spot check of six cable reels was made by

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the inspector. No discrepancies were observe Inspection of a sample lot of 50 cable reels in the storage yard area disclosed the following 18 cable reels which did not have satisfactory cable end seal NKA-66, Reels 10, 18, 42, 186, 189 NKA-67, Reels 5, 50, 56 NKA-68, Reels 7,27 NKA-31, Reel 13 NKZ-36, Reel 11 NKZ-52, Reel 3 NKZ-57, Reel 12 NKZ-29, Reel 3,4 NKZ-12, Reel 35 NKZ-68, Reel 9

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• 8 On the above reels, either the end seal was completely missing or the tape on the end was frayed to expose the cable end. The inspector also noted-an inconsistent use of taping material between a plastic tape and a cloth

- tape (which may not have been waterproof). Other end seals are also suspect since the inspector learned from the Sargent Yard Foreman, that the use of "Glyptal" spray sealer had been discontinued at least a year earlie Further inspection of cable storage practices were observed by the inspector in the open yard cable staging area just inside Gate #9 where cables are cut to length prior to taking them into the plant. The inspec-tor observed the following:

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Approximately a dozen coils of pre-cut cables of Rockbestos type RSS-6-207A material were laying on a plastic sheet in water with open unsealed cable end Cable NKZ-59, Reel 12 was uncovered and the cable cut end had no end protectio Failure to protect cable against water and moisture intrusion damage is a violation of licensee specifications as follows:

--2BVS-931, Section 1.16.6 which states in part that "All covers, caps plugs or other closures shall be intact. Covers or closures removed shall be promptly replace Preservatives and coatings shall be in place and intac If reapplication is required, only pre-viously approved preservative material shall be used."

--FCP-430, Section 5.4.1 states in part that "All ends of insulated cable in storage shall be scaled to exclude moisture and cut ends shall be immediately resealed. Cable sealing shall be by taping with waterproof tapes and painting taped seal with insulating varnish, General Electric Company "Glyptal, Scotch IV Spray Sealer". Heat shrinkable caps or tubing of proper size may also be used for sealing."

. This item is a violation of 10 CFR 50, Appendix B, Criterion XIII which states in part that " Measures shall be established to control the hand-ling, storage, shipping, cleaning and preservation of material and equip-ment in accordance with work and inspection instructions to prevent damage or deterioration." (50-412/86-47-01)

Duquesne Light Company conducts surveillance inspections of cable yard "P" in accordance with procedure SQC-5.2 " Storage Inspection Program-Desig-nated Storage Areas". Examinations of this procedure disclosed that it covers inspection of 22 storage areas with 20 groups of inspection item The procedure requiras that one storage area and one item from that area shall be assigned for inspection each day of the month. A review of sev-eral recent inspection reports for Cable Yard "P" disclosed

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that the inspector inspected only one type of cable in the yard during each one of the inspections. Since there are more than 100 different cables and wire types identified by licensee Cable Mark Number E-5 desig-nations, it could take the inspector several years to get around to in-specting all cable reels in the storage area. The inspection procedure did not have any criteria which would provide an overview of the entire storage area to detect such significant deficiencies as unprotected Cable ends on a substantial number of the cable reels. It was also noted that the QA inspection checklist implementing the engineering specification omitted the cable end seal requirement. The DLCO inspection procedure applies to 21 inspection areas other than the Area "P" Cable Yard and possibly to other types of items in each area. Other deficiencies of identical cable storage deficiencies of other locations on site were identified by QA inspectors without root cause followup, the licensee's trending program did not capture the repeated identified deficiencies, and the QA audits did not confirm the technical adequacy of the QC checklist The failure of the inspection procedure to identify the foregoing cable capping deficiencies is a violation of 10 CFR 50, Appendix B, Criterion X Additional details of this deficiency in the DLC0 Quality Assurance program are discussed in Inspection Reports 86-44 and 87-0 (86-412/86-47-02)

4.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items disclosed during this inspection are dis-cussed in detail in paragraph .0 Meetings with the Licensee An entrance meeting was held with members of licensee management on December 15, 1986 to explain the scope and purpose of this inspectio During the course of the inspection, upon uncovering the violations cited therein, a meeting was called with DLCO management personnel to discuss the findings. Attendees to this meeting included a senior vice president and corporate officer of Duquesne Light Company; the managers of QA, QC start-up, operations and maintenance and their support personne An exit meeting was held with licensee representatives (denoted in Details, paragraph 1.0) at the conclusion of the inspection on January 9, 1987. The inspector summarized the scope and the inspection finding In addition, the licensee was informed that the cover letter paragraph pertaining to proprietary information is no longer in use and that if this inspection resulted in proprietary disclosures, it should be made known at that time. There were none. At no time during this inspection was written material given to the licensee or his representatives.