ML20064F429
| ML20064F429 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/02/1982 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20064F419 | List: |
| References | |
| 2NRC-2-042, 2NRC-2-42, NUDOCS 8301060345 | |
| Download: ML20064F429 (4) | |
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Nuclear Construction Division Robinson Plaza, Building 2 Suite 21o December 2,1982 Pittsburgh, PA 15205 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starostecki Division of Project and Resident Programs SUBJECT :
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/82-12 Gentlemen:
This is in response to the Item of Violation cited in Inspection Report No. 50-412/82-12 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever, dated October 29, 1982.
NRC VIOLATION (82-12-01) 10CFR50, Appendix 3, Criterion V, requires that instructions, pro-cedures, or drawings shall include appropriate acceptance criteria to assure that important requirements have been satisfactorily accomplished.
The BVPS-2 PSAR states that the Quality Assurance Program utilizes the guidance of WASH 1309, Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants.
ANSI N45.2.2, endorsed by Regulatory Guide 1.38 and WASH 1309, requires instrumentation equipment to be stored under Level B conditions (as defined therein) and requires measures to be established to protect the equipment from the effects of airborne contamination.
Further, BVPS-2 Specification 2BVS-981, Require-ments during Storage, assigns Level B storage conditions to instru-ment and control cabinets and requires that measures be implemented for equipment protection from physical damage and airborne contami-nation.
Contrary to the above, on October 6, 1982, the Primary Process Racks and Cabinets, Motor Control Centers and the Main Control Board and Emergency Shutdown Panels, located in plant level B 8301060345 830103 PDR ADOCK 05000412 G
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storage areas, were not protected from citborne contaminatiot.
Penetration caps protecting the cabinets had been 'rexaved and pro-tective plugs were missing from the electronic equipmec.c installed in the equipment cabinets.
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This is a Severity Level IV violation (Supplement II).
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RESPONSE
Beaver Valley Power Station Unit No. 2 managIement evaluated the existing site storage program and determined that theistorage pro-gram procedures should be upgrsded to provide'supplemendal protec.
tion beyond current controls against airborne contamination.
The storage specification (2BVS-981) and field construction procedures dealing with housekeeping criteria (FCP-5.0 and 5.1) will be i
revised as follows:
Housekeeping Zone Illa will be added to1 FCP-5.1, A.
A new
" Requirements for Establishing and Maiataining Cleanness Zones," to provide greater control of all airborne contaminate--
producing work activities in the area.
Cootdinators will be assigned to each Zone IIIA area to ensure that ; no conflicting, work activities are in progress at the same time.
As ~ an example, most of the Control Building will be designated a Zone IIIA area.
B.
A new section will be added to FCP-5.0, " General Housekeeping,"
to define those minimum preventive measures to be applied when performing airborne contaminate-producing work adtivities in a Zone IIIA area or other areas within rpecified minimum distances from electrical panels that are not sealed.
C.
Two existing attributes (809 and 819) in 2BV9-981, "Specifica-tion for Storage and Maintenance During " Storage of Pernanent Plant Equipment During the Construction Phase," vill be revised to provide greater detail as to the intend 3d funct' ion of covers as they apply to various levels of storaf e.
Emphaais shall be placed on protection against the harmful effecta of airborne contaminates and physical damage.
D.
2BVS-981 will be revised to assign the appropriate storage and maintenance requirements for all permanent plant equipment which presently indicate no maintenance after installation.
E.
2SMR-1 in Attachment 3 of 2BVS-981 which addresses all equip-ment supplied under the NSSS specification,(2BVS-1) will be revised to assign storage attributes 809 and/or s819-for all-electric equipment.
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~,.a These procedure changes, implemented with appropriate retraining of personnel, establishes a storage program that emphasizes protection against airborne contamination for electrical equipment stored 1.
9 under Level B conditions (as defined in ANSI N45.2.2).
The above changes will be implemented by February 1, 1983.
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These actions are expected to prevent any future recurrence of the conditions identified in violations 82-12-01 or 82-08-01.
In addi-tion, the equipment is given a thorough final cleaning and inspec-tion at the time of release of equipment by Construction to the s
Start-up Group.
This will ensure removal of residual dirt or any contaminants which may have escaped detection during the construc-t tion phase.
I DUQUESNE LIGHT COMPANY h
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By E. JA/Woolever Vice President
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- NRC Document Control Desk Mr. G. Walton, NRC Resident Inspector h
Ms. E. Doolittle, Project Manager i
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SWORp AND SU3 SCRIBED TO ME THIS
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M DAY OF.A,t/AH361/,1982.
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Notary Public l
MDITH K Nlll, NOTARY PUBtlC ROSSTOWNSHIP, AllECHENVCOUNTY MY COMMISSION EXPIRES MAY 28,1934 Member. Pennsylvama A5500atta of Notants 4
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Unitzd Stctes Nucisor Con::truction Divslen Page 4 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF ALLEGHENY
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On this 3
day of
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, before me, Judith M. Nill
, a Notary Public in and for said Commonwealth and County, personally appeared E. J.
Woolever, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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J JUDITH M.NtLL, NOT ARY PUBLIC ROSSTOWNSHIP AllEGHENYC00NTY MY COMMISSION DPIRES MAY 28.1984 Member Pennsylvama Associaten of Notanes s