ML20010E916
| ML20010E916 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/24/1981 |
| From: | Aswell D LOUISIANA POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20010E914 | List: |
| References | |
| W3K-81-0268, W3K-81-268, NUDOCS 8109090102 | |
| Download: ML20010E916 (4) | |
Text
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,e I-LOUISIANA P O W E F1 & L I G H T! P O BOX 6008
- NEW OnLEANS. LOUIS!ANA 70174 34a ouAnoNoe S1nm
- (504) 366-2345 mwn D. L ASWELL Vce President-Power Production July 24, 1981 W3K 0268 Q-3-A35.02.01 Mr. K. V. Seyfrit, Director, Region IV U. S. Nuclear Regulatcry Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
Waterford SES Unit No. 3 USNRC Inspection Report 50-382/Rpt. 81-14
Dear Mr. Seyfrit:
The following information regarding IE Inspection Report No.f0-382/81-14 dated June 9, 1981, is herewith submitted.
The subject USNhC inspection report staten that in the area of pipe supports and electrical cable installation drawings, that aultiple drawing changes via FCR's or DCN's have not been incorporated into the design documents in a timely manner.
In addition, the report states that no criteria has been established for timely revision of design drawings.
The following is our response to the IE Inspection Report:
I.
In the area of Electrical Drawings:
1.
Corrective Action Taken and the Results Achieved:
The electrical cable and conduit installation drawings (B288) have been revised to incorporate FCR's and DCN's and are in the review and signout process in accordance with Ebasco Engineering procedures such as E-69 (Design Change Notice and Field Change Request). The revised drawings will be issued by August 10, 1981.
It should be r,oted that approximately 80% of the FCR's and DCN's posted against the B288 drawings were not changes, but new details to be added.
2.
Corrective Action Taken to Preclude Repetition:
Ebasco Site Engineering is currently preparing a Waterford 3 specific as-built drawing procedure which will cover the revisions of all Ebasco design documenta. This procedure will establish the criteria for initiation of the drawing revision process due to the accumulation of Fi;R's and DCN's.
In general, the criteria which has been n109090102 010814 PDR ADOCK 05000 o
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Mr. K. V. Seyfrit July 20, 1981 established between LP&L and Ebasco for the timely revision of design drawings ;is as follows: Once 5.or more DCN's and/or FCR's have been issued agsinst a design drawing, or detail cheet, the revision of the drawing will be initiated.
3.
~ Dates by Which Full Corrective Action Will be Achieved:
As' stated in our response to item l',
the B288 details will be a.
formally issued by August 10,.1981.
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b.
The Waterford'3 procedure'for the "as-built" revision of design drawings will be issued by August 15, 1981.
II.
In the Area of Pipe Supports:
1.
Corrective Action Taken and the Results Achieved:
Normally, FCR's and DCN's are' not issued against hanger installation sketches. The following represents the process by which hanger sketches are revised. This is being offered in order to clarify the present program.
t When a revision to a hanger sketch is required'to facilitate inatalla-tion. Tompkins-Beckwith identifies the' request either by an Information Request or a verbal request for an Ebasco Redline depending on the
. severity of the change required.
Information Requests are normally dispositioned by a formal field revision to the sketch.
Subsequently, Bergen Paterson will issue a formal home office revision to Ebasco for incorporation it.:o the Ebasco Emdrac System.
Less severe revisions' are handled by an Ebasco redline performed by an Ebasco Sitt Support Engineering Designer.
Such Ebasco redlines are logged in the ESSE Redline logbook. The hanger sketches are formally revised once Tompkins-Beckwith has QC accepted the installation of the support and the QC~ accepted redline drawing is submitted to ESSE for as-built
-reviewfalong with all other'as-bbilt hangers and piping isometrics.
This review is done on a st' rtup system basis using the attached time a
line as the schedule for review. Tompkins-Bcckwith has limited red-line capability as described in Ebasco Site Procedure ASP-IV-37, 2.
Correcti_ve Action Taken to Preclude Repetition:
Ebasco Site Engineering is preparing a site specific procedure for the
~as-built review of hangers and piping isometrics. This procedure will reflect the time frame for review of safety related hanger and isemetric drawings as-built submitted by the installation contractor, Tompkins-Beckwith. This procedure will be issued 'by August 10, 1981.
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1 Mr. K. V. Seyfrit July 20, 1981 3.
Date When Full Corrective Action Will be Achieved:
stated in response to Item 2, the procedure will be issued by a.
na August 10, 1981.
b.
The as-built review of safety related as-built hanger sketches and piping isometrics will be handled on a startup system basis and is predicated on the receipt of QC accepted hanger sketches and isometrics from the contractor. The time line for review and submittal is attached for your information.
III.
The El'asco procedures which describe the review an approval of field design changes are as follows-a.
E-69 estal'11shes a procedure by which Ebasco Engineering will a) inform Field of changes to an approved Ebasco drawing. design document or specification having immediate and significant impact on construc-tion work or schedule; b) promptly advise Field regarding approval of Field-proposed changes so as to minimize construction delays; and (c) provide documentation necessary to satisfy quality assurance requirements.
b.
ASP-IV-37 delinentas guidelines for field revisions to design drawings, establishes measures to control as-built information for piping and pipe support systems, and defines the flow of feedback of informet an to responsible personnel for incorporation into design documents. This procedure does not supersede existing design control measures but is intended to give guidelines for making minor modifications in the field which do not affect the intent of the design. The contractor shall be limited to specific types of modifications as described in the procedure.
The Ebasco Construction Engineer or ESSE Engineer shall have a wider capability to make modifications as described in the procedure.
If you Iave any questions concerning this inspection, please advise.
Yours very truly, h[
D. L. Aswell Attachment DLA/LLB/grf i
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Timeline of As-built Submittals & Review 1/27/81 D J Lott Sys. Const.
Complete g
30 day (Final.
All as-built 1st Walkdown (Punchlist)
Unikdown Walkdown) data: isos &
Start-up hgrs
- Release, alk l
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-150
-90
-60
-30 7
O Construction LP&L Walkdown )
t Hot Complete T-B Functional
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Q.C. accepted
-paper Turnover May "82" i
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+30
+9O
- = Har and Iso as-builts (redlines) reviewed (preliminary), signed off and returned to T-B.
Review will include:
A.
Hgrs:
Structural review ESSE will B.
. Icos:
Conformance with FCRs/DCNs, Flow Diagrams and as-built
- P guid lin s (see F-51123E, dated 11/3/80)
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bit fo C.
Stress Analysis:
" Judge =ent" that S/A will not change to site significantly.
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' Jk = imposed deadline by design engineering (ESSE & N.Y.,0) to' complete. up-dating of S/A and review devices with Cinal "as-built" loads.
N Code sign-off form, no established data for this to be signed.
However, it must be completed prior to Hot Functional.
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