ML19327B417
| ML19327B417 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/18/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910310139 | |
| Download: ML19327B417 (4) | |
Text
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Shggungrat. PA 1b077004 o
55% o.m se m ums.
October 18, 1989 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket Nr. 50-412, License No. NPF-73 Combined I,nspection Report 50-334/89-12 and C0-412/89-13' Gentleme.h:
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'an September 11, 1989 we submitted a'
reply to the Notice of violation whfch was included with the referenced inspection report.
Our reply co Violation A steted that a status of actio.7s taken and a schedule for remaining actiw:.s ws aid be submitted at a later date.
Encl.scd. is our updated response.
If there are any questions concerning this response, please contact my office.
Very truly yours, bk D. Sieber ice Presider.c iuclear Group Attachment cc:
Mr. J.
Beall, Sr. Resident Inspector Mr.
W. T.
Russell, NRC Region I Administrrtor Mr. Edward C. Wenzinger, Chief Reactor Projects Branch No.
4, Division of Reactor Projects, Region I Director, Safety Evaluation & Control (VEPCO) l L
l 8910310139 891010 PDR ADOCK 05000334 7/fol i
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DUQUESNE LIGHT COMPANY f*
Nuclear Group i
Beaver Valley power Station Units 1 &2 y
'1 Status of Actions cable Seoaration Violation
]
initial Reolv to Violation!
Descrip*,1on of Violation (50-334/89-12"01) 10 CFR part 50, Appendix B,
Criterion XVI requires that measuts; i
shall be established to assure that for conditions advarse to s
- quality, the cause of the condition is determined and corrective action la taken to preclude repetition.
T Contrary to the above, the licensee)s corrective actiors in response to findings identified by NRC in Inspection Report 88-22, Detail 10, regarding inadequate separation of safety related electrical cable were not adequate.
Severt,1 similar discrepancies were identified by HRC 7n July 7, 1989.
Adequate cable separation still does not exist in t' e Unit 1 Cable Mezzanine.
p',cussion of violation As a
result of the instances of inadequate separation of safety related c6bles identified by the NRC in Inspection Report 50-334/88-22, Duquesne Light conducted inspections of all accessible BV-1 areas-for cable separation deficiencies.
These inspections were broad in scope and were conducted on an area basis, t
i Following the recently identified discrepancies, we conducted a root
[
cause analysis of the cable separation problem.
This review of our inspection plan indicated that the inspection by area rather than by component was not adequate to identify all potential deficiencies.
In order to correct
- this, a
more systematic inspection plan to i
resolving this problem was recommended.
(grrective Action Taken A
comprehensive plan was developed and implemented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of l
the NRC identification of the discrepancies.
This plan provides for a
systematic approach for inspecting Category lE cables and raceways in Unit 1
to assuru that installations will meet the original installation criteria and that identified deficiencies wil]
be appropriately resolved.
The four color separation concerns identified by the NRC on July 7, 1989 were resolved.
At present.
i.
walkdown teams continue to perform color separation inspections while i
a vosolution team is concurrently determining the appropriate corrective action to be taken for cach deficiency.
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SthtuJ Cf ActiCn3 Combined Inspection Report 50-334/89-12 ond 50-452/89-13 i
j Page '2 j
Action Taken to Prevent Recurrence j
The cable color separation deficiencies identified au the result of-i the new inspection program are associated with cables which appear to have been installed during the construction phase of Unit 1 or during er.rly design change installations.
The present day practice of 100%
Quality control (QC) inspection for Category 1E cables provides-j assurance that all new 1E installations will meet the installation criteria.
In
- addition, we will incorporate into our process installation Jtandards the requirement for all future non-1E cable installations to be inspected by QC to confirm installation separation criteria are met.
pgg of Full Comollance Walkdowns' and evaluations are still continuing, therefore, we have not determined a completion schedule at this time for inspections and co:rective actions in all areas.
Since Unit 1 is carrently shut down for refueling, we will complete the inspections and correction of any 1
deficiencies within the Unit 1 containment prior to startup.
The process installation standard for inspection of non-1E cable installations will be revised by October 2, 1989.
We will provide a status and schedule for completion of the remaining corrective actions by October 18, 1989.
October 18. 1989 Status of Actions I
Implementation of the comprehensive plan for inspecting Category 1E cables and raceways at Unit 1, as described in our original response, is continuing at this time.
To date, in excess of 15,000 man-hours have been expended in this effort.
l For Unit a
containment inspections, approximately 98 percent of the walkdowns and evaluations have been completed in accordance with the plan.
We intend to complete the remaining inspections and correct any cable separation deficiencies w! thin the Unit 1 containment prior to startup_from the current refueling outage.
i For inspections outside of containment, approximately 20 percent of the Category 12 cable raceways have been inspected to date.
These inspections have been scheduled to give priority to high energy cables and high density raceways.
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'StStu3 Of ActiCn3.
'B j-Combi,ned Inspection Report 50-334/89-12 and 50-412/89-13 Page 3 L
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Approximately 80 ' percent of the Category 1E high energy cable raceways have been inspectnd.
We anticipate completing the walkdowns of the remaining high energy cable raceways prior to startup from the current outage.
Any remaining deficiencies resulting from these inspections will be evaluated prior to startup and a justification i
for continued operation (JCO) will be developed, where necessary.
The remainder of the Category 1E raceway walkdowns will be complete l
by January 31, 1990.
We will provide you with a final schedule for resolut.4on of any remaining deficiencies by February 15, 1990.
The process installation standard for inspection of non-1E cable installations was revised by october 2, 1989 to require all future non-1E cable installations to be incpected by QC to confirm installation separation criteria are met.
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