ML20080H463
| ML20080H463 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/05/1983 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20080H441 | List: |
| References | |
| 2NRC-3-059, 2NRC-3-59, NUDOCS 8309210346 | |
| Download: ML20080H463 (1) | |
Text
.. - _-...
. _ _ _ ~.
4 4
4 2NRC-3-059 (412) 787-$141 ls (412) 923 -1960 Telecopy (412) 787-2629 Nuclear Construction Division August 5, I983 Reinson Piera Building 2, Suite 210 Pvatpurgh, PA 15205 United States Nuclear Regulatory Commission Regicn 1 631 Park Avenue King of ? russia, 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. 50-412/83-05 s'
Gentlemen:
1 This is in response to the Notice of Violation (Item 83-05-07), Not ic e of Deviation (Item 83-05-02), and the Significant Observation classified as program weaknesses (Item 83-05-03 and 83-05-04) cited in Inspection Report No. 50-412/83-05 and listed in the attachment s to your letter to Mr. E. J.
Woolever dated July 6, 1983.
~
I.
NRC Violation'83-05-07:
10 CFR 50, Part 50, Appendix B, Criteria XII, Control of Measuring and
- Tes t Equipent - requires that measuring devices be controlled and i
calibrated at specific periods.
'The~PSAR, Section 17, P -agraph 17.1.lA states that the quality assurance program has been written to conform to 10 CFR $0, Appendix B, l
"QACriterigorNuclearPowerPlants".
![
FCP 501, Paragraph 5.2.3 requires that Measuring and Test Equipment l
shall not be used when the calibration due date has expired.
Contrary to the above, on April 28, 1983, the inspector observed a torque calibration. device to be in use for calibration of a torque wrench even though the calibration due date of the torque tester was April 22,1983.
l
RESPONSE
Isunediate Action As described within the Inspector's report, the device was immediately
- re-calibrated and found to be acceptable.
In addition, an investigation l
was implemented to establish the cause of the discrepancy.
)
8309210346 830912 PDR ADOCK 05000412 G
.PDR
United Stets 2 Nuclect R:gulatory Caraission Mr. Richsrd W. Starostecki Page 2 Corrective Action The investigation revealed that the device in question had given problems in the past.
In view of this, the calibration frequency, immediately following the last calibration, had been changed to be more f r eq ue nt. The administrative controls, with reference to formal recall when the date of calibration was due, fell a few days behind, and, in consequence, the recall not ice was not received by the appropriate Tool Room when it should have been.
In addition, it became apparent that the construction forces were over-relying on the recall system and were not paying sufficient attention to the cal.ibration due date shown on the sticker attached to the device.
Following this incident, an improved card system has been established in the Tool Room of the contractor which will enable the Contractor to advise the Calibration Lab in the event that their recall system is not being implemented as required.
The main thrust of our corrective action, however, has been to reiterate to construction supervision and craf ts their responsibilities to check the stickers on the devices regardless of recalls or other adminstrative controls.
In addition, highly visible notices will be provided at each Tool Room used by the contractor reminding craf tsmen of his respons-ibilities not to accept an ins trument wi thout checking himself the date on the calibration sticker, by August 15, 1983.
Safety Implications The device in question was in an acceptable condition, therefore, we consider there is no safety implication related to this incident. It should be noted that our program requires that, in the event an instru-me nt is returned that is out of calibration, a review of the work accepted by that instrument during the period since its last c alibrat ion is reviewed and evaluated.
II.
Deviation 83-05-02:
?SAR, Section 17, Paragraph 17.1.lA states that Duquesne Light Company has established a quality assurance program for Beaver Valley Power Station that establishes general quality criteria for the company and its architect-engineer which utilizes the guidance contained in WASH 1283, dated May 23, 1974. WASH 1283 lists Regulatory Guide 1.64 for quality assurance guidance related to the design and procurement
United States Nuclacr Rzgulatory Cannission Mr. Richcrd W. Starostecki Page 3 phase. Regulatory Guide 1.64 Revision 2, Paragraph C, accepts the requirement s of ANSI-N45.2.11-1974 for establishing and executing a quality assurance program during the design phase of nuclear power plant s.
The following examples have been identified as deviations from ANSI-N45.2.11-1974:
1.
Paragraph 7.1 of ANSI-N45.2 requires identification of personnel or positions responsible for preparing, reviewing, approving ard issuing engineering documents and revisions thereto.
Contrary to the above, as of April 13, 1983, no updated matrix, or liat of personnel designated as qualified reviewers was available and design documents had been reviewed and approved by persons not ident ified as qualified.
2.
Paragraph 5.2.4 of ANSI-N45.2.11 requires interface controls of engineering documents when in the review and approval stages.
Where it is necessary to initially transmit design information orally or by other informal means, the transmittal shall be confirmed promptly by a controlled document, Futhermore, Paragraph 4.1 of ANSI-N45.2.11 requires that design act ivities be document ed in sufficient detail to permit verfication and auditing as required by this standard.
Contrary to the above, as of April 13, 1983, practically all of the Project Specification changes and E&DCRs prepared on site which were inspected were signed by individuals who did not perform the review.
The signature showed telephoned approval by the reviewer dnd was identified as such.
The reviewer (s) had not confirmed their telephone approval and documentation was not available in suf ficient detail to permit verification and auditing of review of the engineering document s.
3.
Paragraph 3.1 of ANSI-N45.2.11 requires applicable design inputs, such as design bases, regulatory requirements, codes and standards, be identified, documented, and their selection reviewed and ap pr oved.
Contrary to the above, as of April 15, 1983, the architect-engineer field of fice was using documents which did not identify all of the necessary design input and, as a result, failed to include the design inputs specified in Engineering Technical Guidance 2.8.1 for shimming the baseplates of supports. As a result of this omission, Specification 2BVS-920 (Field Fabrication and Erection of Piping),
and 2BVS-935 (Installation of Ventilation and Air Conditioning Systems) were issued without shimming requirement s.
l l
l l
f
- United Stctc2 Nuclear Regulatory Commission Mr. Richcrd W. Sterottecki Page 4 Reeponse 1.
ANSI N45.2.ll Paragraph 7.1 states that "...The document contro l procedures shall provide fo r:
Identification of personnel postions or organizations responsible for preparing, reviewing, approving, and issuing document s and re-visions thereto. This identification may take the form of Project General Ins tructions, design organizational Policy Statement s, a metrix showing document type against function, or other written forms appropriate to the organizational method of performing the design process."
In view of this requirement, as stated, we must take exception to the interpretation that a "... matrix, or list of personnel designated as qualified reviewers..." is a requirement of ANSI N45.2.ll.
The requirement for identification of " personnel postions or organiza-tions by approved SWEC procedures that identify the personnel positions by title, and organizations where applicable, responsible for prepar-ation, review, approval and issuance of SWEC engineering documents and changes thereto.
These positions and organizations are identified in SWEC Engineering Procedures (EAPs) and supplementing Project proced ur es (2BVMs).
Personnel positions are identified in these procedures by reference to standard functional titles within the project engineeri ng organization such as " Responsible lead engineer" to identify the individual assigned to the project by a SWEC Engineering Department Di-vision to have prime responsibility for the technical adequacy of pro-ject design documents to that engineering discipline (e.g., Electrical, Structural). When applicable, SWEC procedures also identify responsible individuals or organizations within the SWEC Departmental structure by reference to established titles.
With respect to approval of documents by engineers assigned to the Site Engineering Group, discipline engineers are authorized to approve design documents and changes thereto via g ion of authority by th p annn _
s ib le individuals identified by title in Swt;u procedures.
ine require-ments for documentation of this delegation of authority are specified in
~
EAP 3.3 " Site Engineering".
A review of the required documentation for individuals approving specifications and E6DCRs at the site, as of April 13, 1983, has been conducted and all individuals in principal positions, except for the two referred to in Paragraph 5.3.2 of the Inspect ion Report, have been found to be authorized in accordance with SWEC procedures.
The authorizing documents are in the form of approved memoranda on file at Project Headquarters ( Bos to n).
Copies of these document s have been forwarded to the Site Engineering Of fice to provide ready accessibility during future ins pect ions.
For the two individuals referred to in Paragraph 5.3.2. of the Inspection Report, the required authorizing document was approved on April 27, 1983 prior to completion of the inspection. As additional information, it should be noted that also in April of this year SWEC expanded the number of site personnel authorized to approve documents by issuing appropriate memorandum.
^
United States Nuciatr Regulatory Com2ission Mr. Richstd W. Staroatecki Pdge 5 As committed by the SWEC Superintendent of Engineering a list will be maintained of all SEG engineers authorized to approve design documento.
7 As this list will reflect those individuals authorized as described fj above, it must be considered as a document to provide conve ni ent refer _
ence and not_ as an alternate to the requirements described in SWEC
[
y&uceaures for delegation'of approval authority.
2.
The use of telephone contact is in accordance with current SWEC policy for coordination of proposed specification changes and proposed E&DCRs with off-site reviewers for the purpose of obtaining reviewer approval of such changes.
This policy was developed with the following con-siderations:
a.
It is the option of the off-site reviewer to grant or deny approval of the proposed change based upon the telecon, or for specification changes determined to be too complex to be readily described by teleton, direct that a copy be sent for review prior to a telecon acceptance or denial, b.
Copies of issued specifications and E6DCRs are distributed to those who approved the document, including reviewers that gr ant ed ap pr oval via telecon.
Approvals granted via telecon are documented on E&DCR's by identi-c.
fication of the individuals granting and obt aining the approval, inclusion of "telecon" in the appropriate approval block, and the date that the telecon took place.
This documentation is for the purpose of providing auditable evidence of the approval and the means by which it was obt ained.
This policy for coordination of proposed changes with off-site reviewers is reflected in 2BVM-204 for specifications, EAP 6.5 for E&DCRs, and EAP 15.2 for Nonconforoance and Dispositions Reports (N6Ds).
The use of telecon approvals, with the restrictions as described above, is considered to be consistent with the requirement s of Paragraphs 5.2.4 an.1 4.1 of ANSI N45.2.ll.
Procedures as required by ANSI-N45.2.ll Paragraph 5.2.4 for control of design information transmitted between SWEC organizational units have been established in the SWEC EAP Manual and supplementing project pr oced ur es.
The cited requirement of ANSI-N45.2.11 in Paragraph 5.2.4 that address design information transmitted orally as requiring prompt confirmation by a controlled document, should,not be interpreted to preclude the ahove described controlled and documented telecon approval methods. The purpose of the telecon is to discuss a change for consideration by an of f-site reviewer and as such is a part of the review process and does not constitute transmittal of design information between organizational units.
The documentation of approvals obtained via telecon, as previously des-cribed, provides an adequate basis for auditing of this act ivity as required by Paragraph 4.1 of ANSI N45.2.11.
f
- United Stcte) Nuciscr Rigulatory Comnission Mr. Richcrd W. Stercstecki Page 6 3.
The 1/8 in, gap and shimming of baseplate criteria was not initially included in the piping ins tallation (2BVS-920) and HVAC ins tallation (2BVS-935) specifications because it was believed that the plumb and surface level criteria specified in the concrete specification (2BVS-904) would prevent gaps exceeding 1/8 in.
Subsequent inspection of 679 installed HVAC support s, completed in July 1983, confirm that the specified condition has been achieved. However, in recognition that out of tolerance flatness may be encountered, additional requirements for engineering review of gaps exceeding 1/8 inch, if found, have been issued.
From our review of the installed conditions vis a vis the specified requirements, we cannot agree that the project failed to comply with the PSAR commitment to ANSI N45.2.11.
III. Significant Observations (Items 83-05-03 and 83-05-04):
Based upon the results of the NRC Construction Team Inspection (CTI)
(Ins pect ion 50-412/83-05) conduct ed on April 11-19, 1983, the following observations were identified as weaknesses in BV-2 program:
1.
Program Weakness (83-05-03)
The Engineering Department of the Nuclear Construction Division of Duquesne Light Company was formed in December 1982.
To da t e, a charter for this organization has not been established, design ceviews have been performed on a limited basis or not at all and, if performed, have not been documented.
2.
Program Weaknesses (83-05-04)
Design Control by the Architect-Engineer's site Engineering Group has been inef fective in the following respects as identified during this construction team inspection.
- a. Lack of identification and documentation of design input
- b. Discrepancies in requirements for electrical grounding
- c. Deficiencies in supervision and control of training requirements.
- d. One item cited in Appendix B; lack of identification of qualified reviewers.
Response
=
1.
DLC, Nuclear Construction Division Engineering Department (Item 83-05-03):
The following establishes the response to the areas of weakness in DLC Engineering identified by this audit:
1A. CRARTER FOR NUCLEAR CONSTRUCTION DIVISION, ENGINEERING DEPARTMENT The Nuclear Construction Division Procedure 1.2, Revision 1, dated a.
June 1,1983, " Organization and Responsibilities" is the basic
i
- United Stctes Nuclear Rsgulatory Canziscion Mr. Richard W. Starcstacki Page 7 charter for the Engineering Department as it provides the following:
1.
Eatsblishes the Division Organizational Structure.
2.
Delineates the responsibilities of the Engineering Manager.
b.
The Engineering Department Procedure 2.1, Revision 0, has been
~
issued and is dated July 19, 1983 and provides a detailed charter of the Engineering Department as follows:
t (1) Established the organizational structure of the Engineering Depart ment.
(2) Defines the responsibilities and functions of key positions within the Engineering Department.
l c.
Addittonally, other NCD Engineering Department procedures including design review procedures have also been issued (See Attachment 1) to better defir.e and control the operation of the Department.
1B. INADEQUATE PERFORMANCE OF DESIGN REVIEW a.
DLC E&C Division Completion of Design Review Subsequent to this audit, the DLC/E&C Division has assessed the status of the Technical Review Report (TRR) design review process for each discipline and is providing written documentation to the Project of the completion of this program.
Closeout of the E&C Division design review process methodology (TRRs) resulted from the institution and subsequent completion of the BVPS-2 Fluid Systems Finalization Program, involving review of plant systems by E&C Engineers and Site Start-Up Engineers. Ope n i
items resulting from this review were listed, tracked, and resolved utilizing the "BVPS-2 Open Items List".
l Upon the completion of the Fluid Systems Finalization Progras in January 1982; the Nuclear Construction Division developed the "BVPS-1 2 Open Items List" to assure the erase-out of all items identified during the review.
b.
Nuclear Construction Division Engineering Department Design Review Procedures
?
See Response to Item 1A.c.
c.
Nuclear Construction Division, Engineering Department Performance of Design Reviews and Participation in the Design Review Process During the earlier stages of the Nucipar Construction Division
}l organization, as well as presently, its Engineering Department has provided participation in the design review process through the
)
following:
- United Stctes Nucisor Rsgulatory Consission Mr. Richced W. Starostecki Page 8 Technical meetings between DLC and its Architect Engineer; between DLC and its NSSS Supplier; between DLC Nuclear Construction Division Engineering Department and other DLC Engineering Departments; and among those listed above for design review of plant modifications.
The majority of these meetings are documented by Architect Engineer I
Letters (Notes of Meeting) or by DLE correspondence.
Letters between the NCD Project Manager and the Architect Engineer's Project Engineer on technical design related items are prepared by the Engineering Department and approved by the Project Manager.
Additional involvement in the design review process will be provided i
as needed.
Procedures have been issued for aspects of the design l
review process (See Res ponse Item 1 A.c).
Examples of this commitment presently in process and planned are:
i
- The review and endorsement of critical design basis document s through an acceptance program.
- The planned establishment of a DLC NCD Engineering Department Site
~
Engineering Section. The scope of responsibility for this sect ion is presently in the final stages of development and the section will be in operation before September 1,1983.
- The establishment of DLC NCD Engineering Department Representative in the Architect Engineer's Home Office in Boston, MA.
2.
SWEC Design and Design Control (Item 83-05-04):
The following are the reeponses to the items identified during the NRC audit as representing inef fectiveness on the part of the SEG in the area of Design Control:
e a.
" Lack of identification and documentation of design input".
- See response to 83-05-02. Applicable design inputs are contained in project procedures, FS AR, and other corporate document s.
All personnel reviewing and approving project specifications and drawings are cognizant of these requirements.
b.
" Discrepancies in requirements for electrical grounding".
The engineering requirements for cable tray grounding are provided in electrical installation specification 2BVS-931.
Solid copper cable is specified. Project procedure 2BVM-38 has been updated to reflect use of solid cable. Construct ion procedure FCP-423 that reflects the requirements of 2BVS-931 has been reviewed and several clarifications pertaining to tray grounding will be made.
(1) Definition of expansion joint and shake space will be included.
1 ir-4
+=
er e
--e.
-eyg,-weer---N w t--2*TN~*wWee,-
y--e-we-
ca-snme-ryy g
'vT gy=g ywy
-r"w'w
- 1F P "
f'
#"v'W""-Y-T
""t-
i
,' United Stctco Nuclocr R:gulatory Canziccion Mr. Richcrd W. Staro:tecki J
Page 9 i
i (2) Attachments 3.3, Sheet 1 of 3, will be expanded to reflect additional grounding conditions, i.e. b ond i ng j umpe rs, shake space and expansion joint grounding and multiple tray grounding.
This procedure will be reissued by the end of August, 1983.
c.
" Deficiencies in Supervision and Control of Training Requirements".
(1) A monthly " Delinquent Training List" will be issued by the Training Department to the Superintendent of Engineering identifying SEG personnel who have not attended scheduled training sessions or are deficient in self reading training assignments. Copies of " overdue training" memoranda will be sent to SEG supervisors / principal engineers for neces sary action.
(2) Correlations between training and actual work has been comple t ed. The SEG training matrix will be upriated and reissued semi-anually. New personnel and/or assignment change s will be immediatley reflected in the Training Department's copy of the matrix.
This was also identified as an unresolved Item (83-05-10) in the NRC CTI ins pect ion report.
d.
" Lack of Identification of Qualified Reviewers" See res ponse to 83-05-02, It em 1.
In addition to the detsiled findings against Engineering specified in Ins pect ion Report 50-412/83-05 the report also referenced cert ain violations and unresolved items identified during routine inspections in 1982 and 1983, as additional examples of weakness in Design Control.
Although, responses to each of these items have been provided and corrective actions have been or continue to be taken, their accumulation
\\ and root cause has been the source of management concern.
)-
Both DLC and S&W have taken certain management act ions to resolve these concerns and are evaluating additional organizational or programmatic adjustments to address them. These adjustments are scheduled to be completed prior to the 4th Qtr. of 1983.
DUQUESNE LIGHT COMPANY SUBSCRIBED AND SWpRN TO BEFORE ME THIS
.Sd DAY OF (lm,% d 1983.
c-w vN" 6
m/t_
g By i L o d-f (
E. p Woolever e.x o Not ary Public Vice President EJW/slb cc:
Mr. G. Walton, NRC Resident Inspector Ms. L. Lazo, Project Manager NRC Document Control Desk ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20.1986
b United States Nuclear Regulatory Commission Mr. Richard W. Starostecki Page 10 COMMONUEALT!! 0F PENNSYLVANIA
)
)
SS:
COUNTY OF ALLEGHENY
)
On this day 4 62.
day of b%)
/ 9 TJ before me, a Notary Public in and fot said Ccanmonwealth 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 statement s set forth in the Submittal are true and correct to the best of his knowledge.
~
l LaL EL-
~
Not ary Public ANiTA ELAINE REITER, NOT!.RY l'UBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTCBER 20,1986 i
4 I
l i
l j
~.. _ _ _ _ _... _,,,,., _ _ _,
ATTACHKENT 1 ISSUE DATS: 07/19/83 NUCLEAR CONSTRUCTION DIVISION PROCEDURES HANUAL INDEX Section 2.0 - ENGINEERING Procedure Date of Number Title Revision Issue 2.1 Engineering Department Organization and Res ponsibilities 0
07/19/83 2.2 Invoking EMPs 0
06/22/83 2.3 2.4 Engineering Department Indoctrination and Training 0
07/19/83 2.5 Initiation of Engineering Documents 0
07/19/83 2.6 bV-2 Design Basis Document Acceptance 0
03/08/83 2.7 Engineering Specification Review & Action 0
06/22/83 2.7.1 Engineering Specification Review & Action 0
07/19/83 2.7.2 Technical Recommendation Review & Action 0
07/19/83 2.7.3 Equipment Qualification Review & Action 0
07/19/83 2.7.4 Pre-Engineered Items Review & Action 0
07/19/83 2.7.5 Non-Conformance & Disposition Reports 0
07/19/83 2.7.6 Advance Change Notice & Engineering &
Design Coordination Report s 0
07/19/83 2.8 2.9 2.10 Engineering Change Control 0
06/22/83