ML19329C768
| ML19329C768 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/15/1975 |
| From: | Rohrbacher R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8002190885 | |
| Download: ML19329C768 (1) | |
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Hr D. Thornburg, Chief, Field Coordination and Enforcement 3 ranch, IE TRU:
J. H. Sniazck, Chief. Lir,ht *4ater Reactor Prograr:s Eranch,12 ICLTD0 EDISON K2370'iSE TO EO NOTIC OF VIOLATION RICMLI2G DAVIS-LESS2 R2FER2MCE:
L.*. TIT.R. J. P. %7LLU2303, TECD, TO J. C. DAVIS, 12:20, DATED AUGUST 25, 1975 The subject response was reviewed as requested (AI No. IIO 0912 P1).
'le consider the Toledo Edisen reply to the :i?C latter o' G-1-73 transmitting a notice of vielation re3nrA.ing construction cetivities at the Davis-Besse 'Tuclear Power Station to be 2dequate.
'Dio reply is responsive to identified cancerna and discussen the. si:mifie int aspects of this.::atter.
It should be noted that the above coments pertain to the com::it-renta made by Toledo P.dison and not to the execution of these conc:1 treats which need be verified by "egion III.
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Y._.1 U W G.' L u JOHN P. W LUAMSON August 25, 1975
[L7l73..m Docket No. 50-346 License No. CPPR-80 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. John G. Davis, Deputy Director for Field Operations Office of Inspection and Enforcement Gentlemen:
This is in reply to your August 1, 1975 letter transmitting a Notice of Violation regarding construction activities at the Davis-Besse Nuclear Power Station.
The Notice of Violation resulted from inspection findings by representa-tives of the Region III office during their May 19-22, 1975 site inspec-tion of safety related electrical wiring and raceways. The enclosure to this letter contains specific responses to the infractions contained in your Notice of Violation.
l I am concerned that our cwn quality assurance program, as well as those of Bechtel and our other contractors, permitted conditiens to exist that allowed these findings to be made.
I am confident, however, that the actions taken by myself and the responsible individuals under me have corrected any shortcemings and have strengthened all aspects of our quality assurance program.
I fully concurred with and supported the prcmpt co= sit =ents by Mr. Roe for a thorough inspection of the installed safety related cable, wiring and raceway systems. This inspection program has been carried out in an exp&ditious and professional manner.
Ccapletion of this inspection and correction of all discrepancies found uill provide ccmplete assurance that this cable and wiring system is correctly installed with proper decu-mentation.
I am requiring frequent reporting to =e of the status of safety related activities and have directed additional effort be given to the quality THE TOLECO EDISCN COMPANY ECISCN PLAZA 3C0 MADISCN AVENUE TOLEDO. HIO 43552 foo? e Go ?7c.
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'inited States I
Nuclear Regulate Commission t
Page 2 j
August 25, 1975 11 i
j assurance efforts of the Davis-Besse project. As a result of this, the following actions have been taken:
Additional personnel have been assigned to the Toledo Edison Quality Assurance Department to provide increased field sur-1 veillance and audit of site activities.
A special inspection of piping and mechanical systems was 4
initiated and has been essentially completed to provide assurance that this area of site activities is in conformance with requirements.
The Bechtel Quality Control group which, at our insistance, was set up to operate dependently of their other site activities has been strengthened and is providing closer surveillance over contractor and construction management activities.
Where additional instructions have been shown to be desired, to strengthen quality related activities, they have been pre-pared and are in force.
With these actions outlined, together with others that have been taken, I as confident that.our quality assurance program and cetivities are properly implemented and will be adequately maintained for this project.
Yours very truly, ff JPW/ pip Enclosure i
Copy:
Mr. James G. Keppler Regional Director Region III i
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Docket No. 50-346 August 25, 1975 License No. CPPR-80 Response fo Notice of Violation Dated August 1, 1975 Infraction No. 1 The requirements to meet the design bases for separation of redundant essential cables was properly provided in the necessary design documents and drawings Criteria to meet the design bases for separation of essential from nonessential cables and wire, however, was not detailed and specific enough to provide assurance that the design bases could be met.
This detailed, specific criteria has since been fully developed and has been used by the inspection tea = as a part of their inspection docu=ents.
This criteria has also been reflected in the necessary documents used by the contractors in performance of the work.
Electrical standards and drawings have been revised to provide the required details for seismic support of conduits carrying Class IE circuits. These stan.dards and drawings are being used for installation of these supports for ongoing work. An engineering team has been formed on site to review and evaluate all previously installed supports for conduit carrying Class IE circuits. As a result of this review and evaluation, each existing support will be certified as acceptable or will be =odified to meet acceptable criteria. This effort is expected to be completed by February 1, 1976.
Infraction No. 2 The inspection procedures being used for the special inspection program of the installed Class IE cable, wiring and raceway system include inspection of cable jacket and conductor insulation for damage, inspection of the raceway system for sharp edges and inspection of the raceway s stes for debris. This special inspection is about 75 percent co=plete.
All cases of cable jacket damage found had been previously documented for proper dispositioning. Some conductor insulation da= age has been found that was not documented and these items are being properly dispositioned. All areas
- of the raceway syste=, where sharp edges were found to exist, have been properly protected. Debris found in the raceway has been re=oved.
Added emphasis has been given to all field personnel to follow established procedures. The contractor quality control inspection effort has been increased and the quality control inspection by Bechtel QC has been increased.
Additional inspection procedures are being prepared by the contractor and completion and approval of these procedures is expected by August 29, 1975.
- 'D'ocke t No. 50-346 License No. CPPR-80 Page 2 Infraction No. 3 The special inspection program has completed inspection of 1150 Class IE circuits to date. There have been some discrepancies found in routing of these circuits that were not documented, but none of this violated separation criteria for redundant channels. All discreoancies found have been promptly documented for proper dispositioning.
The importance of following exactly, the circuit and raceway cards have been re-emphasized to all contractor personnel. A review of the contractor procedures has shown the desirability of revisions to preclude improper routing and these procedures are being revised with approval expected by August 29, 1975.
Added contractor and Bechtel QC surveillance of cable installation has been instituted.
Infraction No. 4, Procedural changes have been made to the Davis-Besse Field Inspection Manual to provide positive require =ents for expeditious processing of contractor nonconformance reports (NCR's). As a result, new Field Engineering Instructions and new Field Quality Control Instructicns have been written, approvec, and implemented. The backlog of outstanding NCR's has been tignificantly reduced by the revised, streamlined process.
Additionally, other detailed instructions for tracking NCR's are being developed by the Bechtel Field QC organization to assure that contractor NCR's are processed within the procedural requirements and as expeditiously as possible. A periodic status report will be required. The expected completion date for these procedures is September 1, 1975. Full compliance is expected to be attained by September 15, 1975.
General Toledo Edison project engineering and quality assurance personnel have and are continuing to be involved in the special inspection program including f ormalization of inspection criteria and procedures, together wit'a evalua~
tion and dispositioning of inspection results. Close review and approval of new and/or revised procedures and engineering design details is being exercised.
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