ML20076G443
| ML20076G443 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/08/1983 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20076G402 | List: |
| References | |
| 2NRC-3-012, 2NRC-3-12, NUDOCS 8306140672 | |
| Download: ML20076G443 (7) | |
Text
a b
4 e
e 6
4 I
ENCLOSURE 4 l
/sf 2NRC-3-012 H12) 787-5141 (412) 923 - 1960 Nuclear Construction Dmskm March 8,1983 Robinson Ptara. Building 2 Suite 210 Pittsburgh PA 15205 United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starostecki SALP Board Chairman Division of Project and Resident Programs SU BJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC SALP Audit, dated January 31, 1983 Gentlemen:
This is in response to your letter to Mr.
E.
J.
Woolever, dated January 31, 1983, titled " Systematic Assessment of License Performance Report" (SALP) conducted on January 24, 1983, by the NRC Region I SALP Board of Beaver Valley Power Station, Unit 2 (BVPS-2) for the period of December 1, 1981, to November 30, 1982.
The meeting between you along with certain members of the review board team and BVPS-2 management was held on February 15, 1983.
The purpose of this meeting was to review the SALP report and verbally comment on the areas that were assessed as Category II and III -in the report.
As stated in your letter a written response may be provided within 20 days after the meeting.
Attached is BVPS-2 response to the four areas assessed as Category 11 and the one area assessed as Category III.
Also included is an attendance roster of the personal present during the February 15, 1983, SALP meeting at BVPS-2 site.
DUQUESNE LIGHT COMPANY By E. M Woolever Vice President SDH/wjs Attachment Mr. G. Walton, NRC Resident Inspector ec:
Ms. L. Lazo, Project Manager SUBSCRIBED AND SWORN O BEFORE ME THIS ftd DAY OF ? ?/ a rt.c.1 1983.
r1 h,., d [, b.t. d e /(h,/x 8306140672 830608 PDR ADOCK 05000412 Notary Public G
PDR ANITA ELA!NE T.EITER, NOTARY PUBUC ROBINEON TOWNSHIP. ALLEGHENY COUNTY f
MY COMMISSION EXP!RES CCTCBER 20,1935 y
I l
s,*
United States Nuclear Regulatory Commission l
Paga 2 l
COMMONWEALTH OF PENNSYLVANIA )
)
SS:
l COUNTY OF ALLEGHENY
)
I On this
/
day of Nau
/f/J
, before me, e
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 exe-
{
on behalf of said Company, and (3) cute and file the foregoing Submittal the statements set forth in the Submittal are true and correct to the best of his knowledge.
da L A
ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TO'.'.'NSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1586 i'
i 1
l.
I s
BEAVER VALLEY POWER STATION - UNIT 2 NRC SALP REPORT FOR PERIOD 12/1/81 - 11/30/82 SECTION NO. 3 and NO. 9 Welding and Storage The site construction activities addressed in NRC Infractions 82 01, 82-01-04, 82-02-01, 82-02-02, 82-07-01, 82-08-01, 82-09-01, and 82-12-01 and Unresolved Item 82-04-04 involved welding and storege of permanent plant equipment.
The BVPS-2 project has reviewed the problems identified by the referenced reports and has taken effective action to assure their immediate and long-term resolution.
Welding The welding problems and concerns identified by the NRC generally involve engineering information completeness and interpretation and attention to detail with reference to backup documentation for welding procedures and technique sheets as required by the governing codes.
BVPS-2 management considers these problems to be important and is confident that the ac t ions taken to correct the specifics noted and to improve the site welding program address these problems.
The specifics of each problem identified have been reviewed and either corrected or have had the correc t ive action identified for future implementation.
The site welding program has been thoroughly reviewed.
The review has resulted in revision and clarification of the governing engi-neering specifications and welding procedures, reinspection of applicable welds, revision to the site welding program, increased inspection and coordi-nation of inspections, and reorganization of the contractors' welding organi-
- at ion and staffing.
The reorganization and increased staffing of the contractor's welding group has been supplemented by additional involvement of Stone & Webster, Site Quality Control, and Duquesne Light Company Nuclear Construction Department management and technical staff personal.
BVPS-2 management believes that the problems encountered are being resolved, and that the actions taken will continue to improve the site weldi.ng program. Continued involvement of key personnel, increased staffing, and an overall increased attention to detail will permit the program improve-ments to be realized for the balance of the construction effort.
Storage BVPS-2 management has reviewed and evaluated the problems identified relating to the performance of periodic inspection and maintenance of equip-ment, and to the protection of permanent plant equipment stored in place from physical damage and airborne contamination.
The specific referenced storage problems have been reviewed and detailed corrective action has been either identified or im pl eme nt ed.
In addition to these efforts, further, increased and comprehensive corrective l
action was initiated to provide assurance of long term problem resolution.
l SVPS-2 management recognizes the importance and necessity for meaningful and as the construction status of the acceptable storage controls, especially project continues to progress towards testing and operations.
l
a 9
=
to increase the j
Supervisory and craf t personnel have been dedicated storage control ef forts and frequency of area inspections.
Also, additional s
J steps have been taken to revise and enhance the site storage control program and specifications to clarify and identify responsibilities, increase storage inspections and controls, and provide greater maintenance details and clari-
.fication of application.
Supplementing the above actions, greater involve-ment by both Stone & Webster and Duquesne Light Company personnel has been achieved and will continue to be applied.
l l
l
o BEAVER VALLEY POWER STATION - UNIT 2 5
NRC SALP REPORT FOR PERIOD 12/1/81 - 11/30/82 SECTION NO. 8 LICENSING ACTIVITIES DLC has reviewed the draft assessment of licensing activities and provides the following comments.
The analysis states, "The applicant met with NRR in August, 1982 to discuss the contents of the FSAR.
At that time, the applicant requested deferral of several broad areas of information which are required as part of the technical information included in the Operating License application."
The "several broad areas of information which are required" consisted of two areas:
(1) technical specifications, which are typically not sub-mitted at the time an application is tendered, and (2) a NUREG 0800 compari-son which became regulation in March, 1982. Guidance providing an acceptable method for implementing the NUREG 0800 comparison was not forthcoming until October 1982.
Other material recommended to be included in the application by NUREG's, Regulatory Guides, or NRC correspondence was also discussed for the purpose of obtaining feedback on how NRC review would be af fected by a delay in providing the material.
The analysis also states that, " Subsequently, the applicant provided a list of othe.r specific technical information which would not be included in the initial FSAR submittal.
Based on NRR comments regarding the pos tponed information, BVPS-2 stated they would set priorities for addressing each item in order to accommodate the staff review schedule."
This list comprised detailed information as opposed to the "b road areas" discussed at the August interface meeting.
This list was provided to promote good communication and provide the NRC with information on the expected content of the FSAR at submittal as well as to obtain NRC feedback.
Informal comments on the list were appreciated and have been used in planning future amendments.
As stated in the analysis, no submittals were made during this period since none were scheduled.
The analysis summarizes with, "In conclusion, the applicant seems to have a comprehensive approach to completing its application and demonstrated on licensing activities towards the close of this an increased emphasis period, but does not appear to have strict control of preparation activities as indicated by lack of a firm tendering date.
The delays in the schedule for tendering the operating license application warrant increased licensee management attention in the area of licensing and application preparation."
In late 1981, DLC took positive steps to provide stricter control of the project by creating a Nuclear Construction Division, which has as one of its responsibilities, the licensing of Beaver Valley Unit 2.
Although we believe that this action has resulted in progressive improvement in control of licensing activities, management's attention will continue to focus on this critical area.
L
r a-
. o PEAVER VALLEY POWER STATION - UNIT NO. 2 NRC SALP REPORT FOR PERIOD OF 12/1/81 - 11/30/83 SECTION NO. 10 ENGINEERING RESPONSE We have noted your assessment result which identified Engineering as an overall Category 2 activity.
For purposes of continuity in this let-ter, all references to Engineering performance in the first nine (9) function areas are addressed in this response to functional area #10, Engineering.
Response to Functional Area #10 - Engineering The bolting problems in HVAC ductwork were discussed in our site meeting on February 15, 1983.
We believe that the situation is an isolated example of a problem associated with a vendor's tolerance control.
At this time, the problem does not warrant changes to the existing Engineering or QC now imposed on vendors.
The other HVAC Engineering control requirements related problems were addressed in our response to inspection 82-11.
That response also included an addressment of these types of problems to non-HVAC support activities and included descriptions of the reviews that are being and will be performed in non-HVAC support areas.
Further, the QC inspection results of installed HVAC supports that have been reviewed by the Engineers to date have not identified the need for any re-work, i.e.
the installed conditions were satisfa.ctorily analyzed by the Engineers.
Additional DLC Engineering involvement in the design process is planned to assure that the design basis of BV-2, as described in our recently submitted FSAR, is being used as designs are finalized or as ch anges to existing designs are found necessary.
The involvement will also assure that existing inprocess activities used for the collection of as-built documenta-tion is planned and implemented in a consistant manner and meets our design and operating requirements.
Also, DLC Engineering will participate in QA audits of the SWEC design process.
These audits will be planned to assess the ef fectiveness of the SWEC design control programs used to correctly translate the applicable regulatory requirements and plant design basis into SWEC specifications, drawings, procedures and instructions.
a*
e o s
l BEAVER VALLEY POWER STATION - UNIT NO. 2 CONFERENCE PURPOSE: NRC MAN /GEMENT MEETING (SALP)
JO No. 12241 DATE 2/15/83 PERSONNEL IN ATTENDANCE Stanley D. Hall, Sr. Compliance Engineer, Duquesne Light Company George W. Knighton, Chief Licensing Board #3, Nuclear Regulatory Commission Glenn A. Walton, Sr. Resident Inspector, Nuclear Regulatory Commission Rick Keimig, Chief Projects Board #2, Nuclear Regulatory Commission (Region I)
Rich Starostecki, Director, DPRP, Nuclear Regulatory Commission (Region I)
Lowell Tripp, Chief Projects Section 2A, Nuclear Regulatory Commission (Region I)
~
J. A. Hultz, Deputy Project Manager, Duquesne Light Company Paul Orr, Deputy Project Manager, Duquesne Light Company Rich Swiderski, Manager, Nuclear Construction, Duquesne Light Company E. J. Woolever, Vice President, Duquesne Light Company E. F. Kurtz, Manager, Regulatory Affairs, Duquesne Light Company R. Washabaugh, Project Manager, Duquesne Light Company C. E. Ewing, Manager, Quality Assurance, Duquesne Light Company J. F. Zagorski, Station Superintendent, Duquesne Light Company R. Coupland, Director, Quality Assurance, Duquesne Light Company H. M. Siegel, Manager, Engineering, Duquesne Light Company A. C. McIntyre, Superintendent of Engineering, Stone & Webster C. R. Bishop, Resident Manager, Stone & Webster f
l i
l I
i l
l t
,s