ML20087A008
| ML20087A008 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/12/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20086U568 | List: |
| References | |
| 2NRC-4-002, 2NRC-4-2, NUDOCS 8403070308 | |
| Download: ML20087A008 (4) | |
Text
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2NRC-4-002 (412) 787 - 5141 Telecopy 2) 87 9
Nuclear Construction Division Robinson Plaza, Building 2, Suite 210 January 12, 1984 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 Res ident Programs SbBJECT:
Beaver Valley Power Stat ion - Unit No. 2 Docket No. 50-412 USNRC IE Inspect ion Report No. 50-412/83-15 Gentlemen:
This is in response to NRC Violat ion 83-15-01 ci ted in Ins pect ion No.
50-412/83-15 and listed in Appendix A (Not ice of Violat ion) attached to your let ter to Mr. E. J. Woolever, dated-December 12, 1983.
NOTICE OF VIOLATION:
As a res u lt of the ins pect io n conduct ed on Novembe r 1-30, 1983, and in accordance with the NRC Enformeement Policy (10C5R2. Appendic C) published in the Federal Register on March 9, 1982 (47FR9987), the fo llowing violation was identified:
10C FR50, Append i x B,
Criterion III r equi res that measures shali be estab lished to as sure that the desian basis is correct ly trans lated into s peci ficat ions, drawings, proced ur es, and direct ions.
Chapter 17 of the PS AR c ommi t s to WASH 1283, Revision 1, wh ich includes Regulatory Guide 1.64, wh ich, in turn, endorses ANSI N45.2. ll, Draf t No. 3, Rev i s io n 1 -
-July 1973.
ANSI N.4 5.2. ll requires that de s ign ac t ivi t i es be accomplished such that applicable design input s, such as the des ign bases are correct 1y trans-lated into the specifications, drawings, procedures, and inst ruct ions.
Contrary to the ab ove, as of November 17, 1983, the design basis had not been correctly t r ans la t ed into drawings fo r ins t allation of electrical s uppo rt s in that to le ra nces were not s peci fi ed wh ich would limi t the loading on the su pnort s to within the bound a ri es of the su ppo rt ing des ign calculat ions. As a result, electrical support S152 was ins t al led and ac cept ed by Quality Control, with its loca t ion ap pr oxima t ely four inches of f-c ent e r fr om the locat ion as sumed when the calculat ions were I
made.
8403070309 840228 PDR ADOCK 05000 a
__-_O
f United States Nuclear Regulatory Commission Mr. Richard W Starostecki j
Page 2 4
RESPONSE
It is Duquesne Light Company's (DLC) pos it ion that the des ign proces s is adequately controlled.
This position is based on the following:
A.
The cable tray support drawing (12241-RE-34HL) correct ly depict s the a t t achment in Det ail DH cent ered on the baseplate.
To le rances are 4
speci fied on Drawing No. 12241-RE-34HE which is referenced by 12241-RE-34HL.
1 B.
Request for Infonnat ion No. RI-0383-QC is only applicab le to Det ail KH on Drawing No. 12241-RE-34HC.
IMMEDIATE CORRECTIVE ACTION t
As ident ified in the NRC Ins pect ion Repo rt (50-412/83-15) Stone &
Webster Engineering Co rpo rat ion (SWEC) comple t ed a
veri fica t ion c alculat ion of electrical su ppo rt 5152 and not ified the NRC Res ide nt Inspector that it was acceptable as installed.
1 BACKGROUND:
The to le ra nces (1 1/8 inch) s oeci fi ed on Drawing No.
12241-RE-34HE applic ab le to the centering of the attachment on the baseplate as shown for Det ail "DH" on Drawing No. 12241-RC-34HL were not, as st ated in the ins pect ion report, being used as ac cept ance c ri t e ri a fo r thege support installations.
The cri t eri a being used fo r accept ance was, as - s t at ed in the repo rt,
based upon an eng ineeri ng res pons e to " Req ue s t fo r Info rmat ion No.
RI-0383-QC" provided on November 27, 1978, which pe rmi t ted locat ion of the end plate anywhere on the top surf ace of the mount ing plate.
This RI, however, is clearly ident ified as relat ing to Det ail "KH" on Drawing-No.
RE-34HC with no indicat ion ' of any int ent that the info rma t io n provided applies to-any other detail.or drawing.
LONG TERM CORRECTIVE ACTION:
In view of the _mi_sapplicat ion of _ int end ed tolerances the fo llowing actions are being t aken:
1.
Site Quality Control - (SQC) will re ins pect and issue Nonconformance and Dispos it ion Report s for any out-of-tolerance cond i t ion fo r details that were originally ins pect ed.
The ins pect ion 1 used the guidance provided in "Reques t. fo r Info rmat ion ; (RI-0 383-QC)" and SQ C's int erpret at ion of baseplate de t ail s shown on RE se ri es drawings with reference to centerline synbol on the drawings.
The 4-
United States Nuclear Regulatory Commission Mr. Richard W. St aros tecki Page 3 to le rance to be used in determining if an out-of-to le rance condi t ion exists for the reinspect ion is to be as ind i c a t ed on Dr awi ng No. RE-34HE fo r ce nt e ri ng the at t achment on the baseplate.
Eng i neeri ng di s pos i t ion of each nonconfo rmance wi11 be based upo n anal ys is of the nonconforming cond i t io n fo r those de t ail s ide nt i f i ed as be ing out-of-tolerance.
2.
In ai d i t io n, Engi nee ri ng is in the pr oces s of anal yzi ng al l "KH" applicat ions to confirm the ac cept ab ili ty of the j ud gme nt made in response to Request for Informat ion No. RI-0183-QC.
3.
Drawing No. RE-34HE will be revised to ind ic a t e, fo r c la ri f icat ion,
that un le s s ot he rwi se not ed in de t a il s, all at t achme nt s to base-plates are to be cent ered on the baseplate.
The to le rance s alr ead y shown on Drawing No. RE-34HE apply to of f-center accept ances.
Due to the unce rt aint ies as to the magnitude of work involved, the scope of the above ac t ions will be determined by February 20, 1984, and the l
Res id ent NRC Inspector will be informed as to wh en it is ex pect ed that completion of these actions will occur.
l DUQUESNE LIGHT COMPANY l
By E.(/J. Woolever Vice President SDH/wjs cc:
NRC Document Control Desk Mr. G. Walton, NRC Res ident Ins pe cto r j
Ms. L. Lazo, Project Manager SUBSCRIBED AND S RN TO BEFORE ME THIS g / DAY OF 4,Jf(/./23 1984
-,ri/w U
Not ary Public ANITA ELAINE REITER, NOTARY PUOUC ROSINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,198G
- United States Nuclear Regulatory Commission Mr. Ilarold R. Denton Page la COMMONWEALTil 0F PENNSYll/ANIA )
)
SS COUNTY OF ALLEGHENY
)
On this
/
day of
/72/46/
_jfh be fo re me,
a Not ary Public in and for said C monwealth and County, personally appeared E.
J. Woo leve r, who being duly sworn, deposed and said that (1) he is Vice Pres ide nt 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 A nd Aaka Not ary Public AN!TA ELAINE REITER, NOTARY PUBUC l
RODIN53i4 TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986 i
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