ML20098H016
| ML20098H016 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/20/1984 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-REGGD-01.075, RTR-REGGD-1.075 NUDOCS 8410090251 | |
| Download: ML20098H016 (5) | |
Text
-
'Af
~
M Tw pnonesi2nsemoo N."o.Ylx 4 September 20, 1984 Shippingport, PA 15077@04 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Dr. Thomas E. Murley Administrator
SUBJECT:
Beaver Valley Power Station Unit No. 2 Docket No. 50-412/84-06 Systematic Assessment of Licensee Performance (S ALP) i Gentlemen:
In your August 21, 1984 letter you had requested that we " periodically inform your office of progress on Beaver Valley Unit 2 initiatives, such as the RG 1.75 Action Plan, the efforts of the recently established constructability
. review group at the site, and the Engineering Confirmation Program."
A summary of our activities in these areas is described herein:
1.
RG 1.75 Action Plan In a meeting with NRC personnel on August 30, 1984, the status of activities of the BVPS-2 Regulatory Guide 1.75 Action Plan, as outlined in Attachment 1 to DLC's June 29, 1984 SALP response, was discussed in detail.
Specific accomplishments cited for the program included:
A.
Electrical installation since May 18, 1984, has been in conformance with project commitments to Regulatory Guide 1.75 (Action Item I.A.l.b).
B.
A training program for engineers, designers, con-struction and QC personnel has been developed and implemented to define the revised separation requirements (Action Item I.A.2).
C.
A computer-based system to track existing separation problems has been developed and implemented (Action Item I.A.3).
8410090251 840920 PDRADOCK05000gg2 G
so
\\
M Mo l
1 3
. -United States Nuclear Regulatory Commission Dr. Thomas E. Murley Page 2 1.
RG 1.75 Action Plan (Continued)
D.
An engineering walkdown of the plant to identify spatial separations which did not comply with the Project Commitments to Regulatory Guide 1.75 has been completed.
The-walkdown identified 1108 cases where rework was required.
Of these, 23 require resolution by SWEC engineering and 180 by
'the electrical contractor's design group.
We are projecting that these items will be dispositioned by both SWEC and their electrical contractor by September 30, 1984.
Construction has committed to complete rework on all items by January 1, 1985.
(Action Item I.A.4)-
E.
Detailed walkdowns by Site Quality Control are proceeding based _on the revised separation criteria (Action-Item I.A.5).
Details of the. planned enclosures, barriers or covers which will be used to meet the requirements of Regulatory 1 Guide 1.75 were also presented at the referenced meeting (Action. Items 1.B.l.b, I.B.2, and I.B.3).
Sample installations of cable wraps have been completed in the plant and potential hardware configurations have been
-assembled for joint discussions by Engineering, Construction and Quality _ Control personnel.~
Planned testing:and analysis to' qualify alternate arrangements ofLenclosures, barriers and' covers are also
-proceeding in accordance with the action-plan schedule for resolving electrical separation ~cencerns (Action Item I.A.6 and I.A.7).
Successful conclusion of the testing effort is expected to-demonstrate that for-certain physical configurations, fewer covers and enclosures than presently planned will satisfy _the Regulatory Guide 1.75 criteria.
A meeting with Mr.iJohn Knox.of NRR is presently scheduled for September 26,.1984, for detailed review of the planned test program andJproposed FSAR amendment.
2.
Constructability Review Group and other Engineering /
Construction Interfaces Six action steps were outlined in the June 29, 1984 SALP response.
The status is as follows:
il Unithd States Nuclear Regulatory Commissiou-Dr. : Thomas E. Murley
-Page 3 2.-
Constructability Review Group and other Engineering /
. Construction Interfaces (continued)
)
A.
'A Constructability Review Group _(CRG) was estab-lished in June for pipe support design review and in July ~for conduit support design review.
These groups have identified a number of issues requiring clarification and/or redrafting to meet the objec-tives for these instructions to be clear, consistent and constructable.
Recommendations have been for-warded to,_and. actions taken by. engineering in this regard.
Training of engineering-and design staffs in the various offices providing these designs has been conducted and_will continue as necessary to ensure project-wide understanding of
-this effort.
The CRG will continue to review the drawings and provide a. level of assurance that instructions to the field are' clear.
Project management will adjust the level of participation and scope of the required training based on the' review. effort.
B.
Pipe rack drawings.were.a subject of concern
'because of the difficulty in interpreting engi-neering' instructions and design details.
These drawings have been redrafted and issued during-July and August.. The number of drawings issued
.has been increased to reduce the amount of detail on each.
C.
Formal feedback has been achieved via the Construc-tability Review Groups and the Senior Management Corrective Action Panel discussed in Paragraph F below.
In addition', the project has sought and received feedback from contractor and construction personnel on other aspectslof installation details.
~An example of this is in the instrumentation installation area.
A comprehensive review of specification, drawing and procedural requirements has been conducted and necessary changes imple-mented.
The Productivity Improvement Program has also-been a source of' feedback regarding repeti-tive issues impacting installation activities and training has been completed in the areas identified Jas deficient through this program.
g.wT-
-4
--so-4-w.
3
.+g w-y V
y y-
---ww y-w T-7
m,
n c
m
,I
- r. -
. ~ United Statos N'uclearLRegulatory-Commission 7
- : Dr.1 Thomas (E. -Murley '~~
},
Page'.4_
M
- 2..
sconstructability Review' Group and other Engineering /
r-
,x,
. Construction Interfaces (continued) s-gj ^
ur OD..
An additional-task' group has b'een.-established to
,~
1 provide ~better yisibility dnd control of required changes..Froject procedures have been issued
< describing-this effort.
E.'
LIn addition to-the_ increased engineering' support
-described in Item No.,.3 below, additional experi-3 enced' construction-supervisors have.been assigned to the construction management team and-the con-tractors' staffs. --This enables more definitive m
1 direction;of, and closer monitoring of problems experienced by the crafts with installation details and expeditious problem resolution.
~
Two add'itional work-locations have been.provided
,for engineers. working in the plant in' support of craft' labor.. The number of engineers and designers
. working directlyfwith= craft supervisors has in-creased.by:eight.since'the'SALP response and will icontinue to increase as required to support construction.. The: presence ofLsenior. engineering' and construction management in_the. plant on'a regular basis has;also increased.. Finally, the
~t
. construction rework control. program,-as described
'in. Field Construction' Procedure-FCP-41/has been implemented.
~
' F.x The SeniorrManagement Corrective-Action Pandl,_
(SEMCAP) ~ described. in' FCP-13. was established in
' July 1984. 'SEMCAP' acts upon recommendations from the Corrective Action Committee,. directing action
,torresolve problems identified. The initial sub-s
~
7 ject of SEMCAP was:aiprogram'to reduce'the project-
? backlog of outstanding Non-Conformance'and Dis-position Reports.- SEMCAP meets cnt a monthly basis.
g to followupLonidirected action and to address!new issues.-
4 13.
Engineering 1 Confirmation Program and Related Site J
Engineering Activities g
s The' Engine'ering^ Confirmation Program, established in L.
.1983, issunderway.
The various: aspects of the program havelbeenlscoped and scheduled.
m.
9 y
q
. > ~. +
~ _. - - ~ _....._--...~._.--.... __,_-
W wa United' States Nuclear Regulatory Commission
~j#
Dr. Thomas _E. Murley Page 5
-3.
Engineering Confirmation Program and Related Site Engineering Activities (continued)
DLCLhas completed the four (4) phases of its detailed program in accordance with issued procedures.- These four.- (4) phases were_ reviewed with a Region I inspector during!the week of September 10, 1984, as part of Inspection 84-14, and the' inspector identified no con-cerns with this' portion-of the Confirmation Program.
DLC has established a program to address continuing DLC Confirmation Program activities which was also reviewed with'the inspector.
~
SHEC portions of the Confirmation Program are pro-ceeding in substantial agreement with the established
-schedule.
The conduct of these portions of.the program are described and available for review in various project procedures.
The staffing of the Site Engineering Group (SEG) has been augmented with the addition.of senior technical personnel. -Since April 1, 1984, twenty-four. additional engineers have been assigned _to the SEG..
This number includes _three new Assistant Superintendents of Engineering, each of whom' brings at least 10 years of engineering
.and' construction experience to his_ position.
Other i-examples of staffing changes to increase the level of supervisory. experience are the addition of two principal engineers in the pipe support area and a senior design supervisor in the. electrical design area.
These personnel will expedite solutions to existing ~ problems and minimize the occurence of future problems.
In addition to these permanent' staff changes, SWEC management has appointed-a Site Engineering Group Sponsor who reports to the SWEC Engineering Manager-and provides management oversight of.the SEG.
We are continuing to address the specific concerns listed in Attachment 4 of the Unit II SALP report and will pursue the commitments as submitted therein.
If-you-have any questions, do not hesitate to call.
Very trul
- yours, L,'
J.
J. Carey Vice President Nuclear Group
_