ML20092J187
| ML20092J187 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/17/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20092J169 | List: |
| References | |
| 2NRC-4-060, 2NRC-4-60, NUDOCS 8406260377 | |
| Download: ML20092J187 (7) | |
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2NRC-4-060 rf (412)787 - 5141 (412)923 - 1960
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Nuclear Construction Division May 17, 1984 Robinson Plaza, Building 2. Suite 210, '
PRtsburgh, PA 15205
,t United States Nubidar, Regulatory Commission Region'I i
631 Park Avenue
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King of Prussia, PA 19406 1
ATTENTION:
Mr. Richard W. Starostecki f
Division of Project and Res ident Programs s,
SUBJECT:
-Beaver Valley Power Station - Unit-No. 2 Do cke t No. 50-412 USNRC IE Inspect ion Report No. 50-412/84-03
' Gentlemen:
This is in response to the Items of Violation and the :it' era 'of Con-cern cited in Ins pe ct ion No.. 50-412/84-03 and listed in Appendix A (Notice
, of Violation) attached 'to your le t ter to Mr.
E. J. 'Woolever, Jated April 16, 1984.
On M ay 14, 19 84, ' an extens ion was reques ted from Region l' of the NRC to submit.this. response by May 18, 1984, and was granted.
..' Notice of Vio1'ation
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condbet ed on February 22 through March 23, t j,
' Ac c a resul'// of. the ins' ecDio n p
1984, anId in adcordance with the NRC Enforcement Policy (10CFR2,s Appe ndix C), published in the' Fedlerdi Register on March 8, 19 84'/ (49FR85,83 ), the
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-following violation was identified:
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. A. 10CFR50, Appendix B,
Criterion VII requires that me asur es e s t ab lished to as sure that purch ased mat eri al conform to the procurement' documents.
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Contrary to the ab ove,- as of March 23, 19 84, the exci t er control 8?? M-panels electrical - wiring was not securely fas tened to the panels as T/[}
required by thelordering specification.
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's Response to ViolatiornA 4
3 The r'equirement s, included in Specification No. 2BVS-230, for arrange-ment and clamping of electrical wiring ins ide the, panels, in part,
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as follows.
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L Wiring shall be neatly arranged and clamped securely lo
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panels.9,o'.pr, event movement and breaking.
Wiring clamps and s u p-lM ports at hinge 7 transition points shall be properly sized to prevent
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chafinUof ynsulatioji p,en the door is cpe ned and closed.
Band s i
u sed fo r " lac i'nge,,and tying bund les of wiret shall not have met al
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8406260377 840615 PDR ADOCK 05000412/
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United States NucledrJegulc. tory Commission V
Mr. Richard W. Starostecki Page 2 clips or sharp ed ge s.
No met al clamps shal l be used to ho ld bund les or wir es in place.
Plas t ic c lamps or loop s similar to Burndy "Nylo-clip" type HP or approved equal shall be used.
During a shop ins pect ion in October 1977, DLC/QC Vendor Surveillance Group firs t ident ified instances where plastic fi t t ing s wi th a sel f-adhesive base had pulled loos e from the pa nel s.
Between October 1977 and May 1978, four N&D's were issued to de sc ribe this cond i tion in de t ail in both diesel generator units.
The fo llowing final di s po s i-t io ns to the N&D's were provided:
"In general, cab le c lamps used fo r wiring suppo rt were Panduit ABMS-A adhes ive backed mount s.
These clamps cont ain a counter-sunk hole which permits the mount to be used with a flat he ad sc rew fo r sc rew attachment.
Except in places were Vendor has de t ermined to be a high str es s point, c ab le clamps were at t ached with adhes ive backing which is not ac cept ab le.
Vendor now proposes to ad d sc rew type fas tner to Pand ui t adhes ive clamps to provide an installation where the sepa-ration between sc rew fas tened clamps will not be gr e at er than 12 inches.
Remov al of the Pand ui t adhes ive c lamps and replacing them with approved Burndy "Nylo-clip" type HP clamps is not pract ical at this time. Therefore, Panduit ABMS-A adhesive clamps are acceptable fo r existing ins tallation, unless otherwise not ed in this N&D, provided the clamps are at t ached with a flat heal sc rew thr ough a t ap ped an ins t allat io n where sepa rat io n be twe en sc rew hole to prov ide f as tened clamps will not be gr eater than 12 inch es.
Where addi-tional clamps were ad ded after the inspection of January 5,1978, only Burndy "Nylo-clip" clamp type HP shall be used.
Adhesive clamps (without screw attachment) where used between screw f as tened type need not be removed; they will provide furt he r sup-po rt.
In pr ov id ing sc rew type at t achment s, it is the Ve ndo r's r es pons ibili ty to pr ov ide pa nels whose face ap pe arance is not degraded."
The above disposition constitutes the approval of the ins t al la t io n as prov ided unde r the specification wording, ".
Bur nd y "Nylo-c lip" type HP or approved equal.
The di s pos it ion al so pe rmi t t ed,
Adhes ive clamps (without screw attachment) where used between screw fa s tened clamps need not be removed A Shop ins pect ion conducted in October 1978 verified that adhesive clamps (without sc rew attachments) were located between sc rew fas tened clamps whose sep a ra-t ion c td not exce ed 12 inches.
8 Therefore, BVPS-2 maint ains that measures were es t ab li shed and c o n-ducted to as sure that the arrangement and c lamping of electrical wiring in the exciter control panel s conformed to the s pe ci fic a t io n requirements.
In cons ide rat io n of the abov e info rmat ion, BVPS-2 requests this violation (84-03-01) be reconsidered by the NRC.
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United States Nucleder.eguletory Commission
(.y Mr. Richard W. Starostecki Page 3 Notice of Violation:
B 10CFR50, Appendix B, Criterion V req ui res that act ivit ies af fect ing quality shall be pr es c ribed by documented ins truct ions or procedures or a type appropriate to the circumstances.
Contrary to the ab ov e, as of March 12, 19 84, Quality Cont r ol was performing ins pect ion on electrical cab le s us ing a proced ur e wh ich-inaccurately described the acceptance standards.
Response to Violation B:
Inspection Report 40-412/84-03 that was included with the NRC letter
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to Mr.
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Wooleve r, da t ed April 16, 19 84, determined that the licens e e has alread y t ake n the neces sary correct ive act ions and,
therefore, no written responses to this item is required.
Item of Concern Extract from the NRC Cover Letter "Ad di t ional ly, we are conce rned ab out the inc reas ing numbe r of QC r eins pe ct ions that are necessary because of cont racto r init iat ed clarified / changed design requi r eme nt s.
Many of these reins pe ct ions are a direct result of following up on violation of NRC requirements
( correct ive ac t io ns ), some of wh ich are disc us sed in the enclosed inspect ion report.
Al c,v, we unders tand that there are ongoing ef fort s to reinspect more than 6,000 support s as the result of des ign changes made af ter installation and QC inspection. Our concerns are reflect ed in the following questions :
(1) why have so many changes occurred fo r s uppo rt s ; (2) are design document s receiving adequate care and atten-tion during preparation and review to ensure that they are unambiguous for field use; and (3) is there enought de s ign det ail / c ri teri a in design documents to provide for ins tallation direct ions and QC ins pec-t io n criteria su f fic ient to assure quality?
Your res po ns e to this letter should also ad dr es s these que s t ions and provide an evaluation of the root causes of the unusually high' number of QC reinspections."
Background
l In rec ognit io n of the fact that mas sive ch anges to piping arx! pipe s uppo rt s occurring at the time of plant finalization can be a source of confusion, pos sib le quality degradation, and s ign ifica nt sch edule delays, DLC began addressing this issue in 1978.
A series of planned actions were undert aken to preclude the incorpo ra-t ion of designs into the phys ical plant that would, at the cri t ical plant completion phase, cause major plant rework.
The first step taken, in 1979, was to cond uct a combined DLC-SWEC review of existing fluids system designs.
The purpose of this review was to as sure that the exis t ing fluid sys t em design conf igur at ion l
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United States Nuclet. legulatory Commission
- Mr. Richard W. Starostecki Page 4~
incorporated the system operating experience of Unit 1, the Regulato ry changes resulting from.the TMI incident and Regulatory changes between 1974 (the CP date for BV-2) and 1979.
In 1979, the' Project expanded its use of computer analyses to encom-pass virtually all piping in the plant.
In 1980, the Proj ect introduced its " Green Isottetric" Pr ogr am.
The Green Isometric Program consisted of a' review of pipe stress analysis and the as so ci ated suppo rt des ign pr ov ided.
Problems ide nt if ied during this review were resolved prior to cons truction. Ad dit io nally, it wa's and continues to be ant ic ipa ted that the Green Isometric
' Program will reduce the impact of any required ch anges due to str es s reconciliation required for ASME III Code certification.
Concurrent with the ab ove ef fo rt s, in 1979 the plant scale model was
- received on site.
This model was used in conjunction with the Green Isometric Program as a design tool to identify and reconcile pipe and s uppo rt ch anges prio r to their issuance to cons truct ion.
The model was also used to des ign rout ing s and locate support s fo r small bore pipe.
In recognition that, even with the above ef fo rt s, some field adjust-ments of ' location and det ail s would be neces sary, field engineering and design forces were incrementally increased as construction ef forts int ens ified.
The detailed changes controlled by the field engineering operation varies by both type and source.
Our specific response to the NRC's questions are as-follows:
1.- Why have so many changes occurred for supports?
Answer :
Changes to approved suppo rt dr awing s, af ter release fo r ins t al la-tion, are caused by a variety of reasons. These may-be categorized as follows:
a) Phys ical int erfe rences de t ermined during the ins t alla t ion process which were not -identified or identifiable on the model or - during engineering rev iew, mostly because of. ins tallation tolerances.
b) Other ins tallation problems ident ified in site nonconformances or construction deficiency reports, vendor engineered supports
( e.g.
Automatic Sprinkler), and vendor problems ident ified in shop nonconformances.
c) Clarifications / data provided to facilitiate-cons truct ion and/or QC ins pe ct ion.
This ca t ego ry also includes nonconfo nnances issued to address QA/QC concerns (both site and vendor shops).
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Mr. Richcrd W. St Arostecki Page 5 d) Changes in SWEC/DLC spe ci fied engineering criteria and design de t ail s because either incorrect criteria or de t ails were s peci fied and were later ch anged as a res ult of eng ineeri ng confirmation or incorporation of state-of-the-art improvement s.
e) Changes in SWEC/DLC s peci fi ed engineering criteria and design details as a result o f ex pa ns io n and be t t e r de fini t io n of c ode and regulatory requirement s.
- 2. Are de s ign do cument s rece iving adequa t e care and attent ion during preparat ion and review to ens ur e that they are un amb iguou s fo r field use?
Answer:
In ac cordance with the "Pr oj e ct Training Program" ( 2BVM-14 0), SWEC e ngineers as s igned to BVPS-2 are requir ed to pa rt ic ipa t e in fo rmal, periodic, orient ation/ indoctrination and cont inui ng ed uc a-t ion courses to impr ove act ivit ies af fect ing quality.
Spe ci fic proced ures are followed, bot h at he ad qua rt ers and at the site, fo r the preparat ion, r eview arxl cont r ol of eng ineering do cume nt s.
Every ef fort is made to eliminate amb igui ty in eng ineeri ng docu-me nt s pr io r to is sue.
In recognition of the fact that there may s t il l be some engineering information which may be misinterpreted,
the " Request fo r Info rmat io n Program" (FCP-7) was es t ab li shed in May 1977.
QC and Cons truct ion, when conf ront ed with a need fo r c la ri f ic a t ion / reconcili at io n of eng ineeri ng info rmat io n,
are required to use this system prior to installation or inspection.
- 3. Is there enough design de t ail criteria in design docume nt s to prov ide fo r ins t alla t ion direct io ns and QC ins pe ct io n c ri t e ri a sufficient to assure quality?
Answer:
The developme nt of Field Cons truct ion Pr ocedur es (FCP's) arri Ins pe ct ion P lans (IP's) is closely coupled to the engineeri ng c ri teri a and de t ail s prov ided in s pe ci f icat io ns,
pr oced ur es,
drawings, etc.
FCP's are rev iewed by Engieering, and along with engineering document s ment ioned above, provide the bases fo r int e r-pr et at io n of engineering criteria and de t ail s by Cons truct ion and QC.
Ge ne ral ly, IP's have not been rev iewed by the Eng i nee rs.
BVPS-2 will now require the Engineers to review all IP's.
Occasionally engineering criteria and/or details are changed during and after ins tallat ion /QC ins pect io n due to pr ogr ams ide nt if ied abov e.
This was mainly due to the " Fluid System Finalization" and the " Green Isometric" programs.
liaweve r, BVPS-2 believes these programs have improved overall quality of engineering inf o rmat io n.
The " Advance Change E&DCR Program" (FCP-36), established in Octobe r 1982, has red uc ed s igni f ic ant l y the impact of in process ch ange.
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. United States Nuclec a egulatory Commissiou Q
Mr. Richerd W. Starostecki Page 6 Both, the NRC (Region 1) and INPO have evaluated the Advance Change E&DCR Program and have commented favorably.
Evaluation at the Root Cause:
The nature of the individual changes ide nt ified either internally or by the NRC, prompt ed the reins pect ion pr ogr am.
It is the BVPS-2 pos it ion that the proj ect must ens ure the proper implement at ion of ch anged engineering criteria and design det ails irres pe ct ive of the r eason for ch ange.
In this case, because of the large numbe r of relatively large nunber are individual pipe suppo rt s in the plant, a potential candidates for reinspection.
Summary In summary, over the pas t several years, BVPS-2 has taken many pos i-t ive act ions to es tab lish/de fine speci fic engineering criteria to f acilitate installation and ins pect ion.
From the fluid system designs review program initiated in 1979 through the Engineering Confirmation Program (which was presented to the NRC on October 21, 19 83), BVPS-2 h as taken steps to confirm the adequacy of engineering information to assure consistency in information, to strengthen design interf ace, and in design control implementation.
As BVPS-2 approaches comple t ion, speci fic as pect s of the previously ident ified prograns may require QC reinspection to as sure the progr am obj ect ives.
Furtnermore, the project rec ognizes that further confir-mation ef fort s be yond those discussed that are incumbe nt in a rein-s pect ion program, will be necessary to ensure that ins t al la t io ns meet cur rent engineericg criteria and licensing commitments. These ef fort s must ba t ime-phased with cons truct ion ef fo rt s fo r maximum ef fect.
j BVPS-2 does not cons ider the reins pect io n program to be a nega t ive a spe ct.
The reinspection program will furthe r as sure all concerned
. part ies that changes, whether resulting from regulatory requirement s,
- s tate-of-the-art improvements, design final i.:a t io n, etc.
have been properly incorporated into the ins talled configuration.
DUQUESNE LIGHT COMPANY SUBSCRIBED AND SWORN TO BEFORE ME THIS
_47d DAY OF _
, 1984.
By _.
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_ G _M2 E. J. Woolever
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Vice President
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Notary Public ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY JS/wjs MY COMMISSION EXPIRES OCTOBER 20,1986 cc:
Mr. C. Walton, NRC Resident Inspector Mr. M. Licitra, Project Manager NRC Document Control Desk
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n-p United S Mr. Richard W. Staroatecki Page 7 COMMONWEALTH OF PENNSYLVANIA )
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SS:
COUNTY OF ALLEGHENY
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On this
/ 76[ day of _ h
/[]
, be fo re me,
a Notary Public in and for said Commonwe alth and County, pe rsonal ly 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 fo regoing Submit t al on behal f of said Company, and (3) the statements set fo rth in the Submittal are true and correct to the be s t of his knowledge.
4 Not ary Public ANITA EiAINE REITER, NOTARY PUBUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986