ML20107F363
| ML20107F363 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/26/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-4-176, NUDOCS 8411050451 | |
| Download: ML20107F363 (4) | |
Text
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( 2 7 514 Nuctsar Construction Division geng Robinson Plaza Building 2, Suite 210 Pmsbur@, PA 15205 October 26, 1984 United States Nuclear Regulatory Commission Region I 631 Park' Avenue King of Prussia, 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. 50-412/84-09 Gentlemen:
Th is is in response to the Item of Violation and the Deviation cited in Inspection No. 50-412/84-09 and listed in Appendix A (Notice of violation) and Appendix B (Notice of Deviation) attached to your letter to Mr. E. J. Woolever, dated September 26, 1984.
Notice of Violation As a result of the inape ct ion conducted on July 24 through August 24, 1984, ud in accordance with the NRC Enforcement Policy (10CFR2, Appen-dix C) published in the Federal Register on March 8, 1984 (49FR8583),
the following violation was identified:
Criterion V,
requires that activities af fecting quality shall be prescribed by procedures and shall be accomplished in accordance with these procedures.
Specitication 2BVS-981 contains in place storage requirements for the Personnel Air Lock to prevent damage.
After the doors are opened, this includes protection of door seals and sealing surfaces and support of the doors to prevent sagging.
Contrary to the above, during the period from July 26 unt;il August 23, 1984, protection of the Personnel Air Lock was not provided to prevent damage of sealing surfaces or support of the doors to prevent sagging.
Corrective Action The following actions have been t aken in regards to the Personnel Air Lock:
- 1. N&D-4691 was issued on August 22, 1984, to obtain an Engineering evaluation of the situation.
It was dispositioned on September 12, 1984, providing an itemized list of maintenance required wh en the door was lef t open for extended periods of time.
- 2. E&DCR-2PS-3633 was issued on August 23, 1984, to change specification 2BVS-981.
This now permits the door to be open with the approval of the Superintendent of Construction and adds new storage maintenance requirements.
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Hr. Richard W. Sterostteki-Page 2s a
- 3. To prevent e damage to the = air-lock door seals. and sealing ' surf aces,
while ' the doors are open, temporary protective coverings and - resps have been installed. The doors.are shinesed to prevent sagging.
- 4. A weekly inspection' of the air-lock by'. the installing contractor. was begun ' on : August 31, 1984, to monitor ;its condition. while the doors remain open.
- These - actions -- have brought the con'dition of the doors into compliance,
' aad will ensure c.ontinued compliance.
Notice of Deviation-As a result 'of the inspection conducted on July 24 through August 24, 1984,- it appears that several~ of your 1 activities were not conducted.in accordance with your commitments. made - in a meeting on May 17, 1984, and followup letters documenting - your commitments dated May 17, 1984, and May 24, 1984.
The following examples - have been identified as a deviation from - your conusi.tunent s :
- 1. Your commitment required revision to Stone and Webster Document 2BVM-88 / to establish overfill criteria for cable raceways.
You cousaitted to complete and issue this revision by June 29,1984.
Contrary to the above, as of August 1, 1984, this document was not revised.
- 2. Your commitment required revision to Stone and Webster Specification 2BVS-931 to address requirements L and controls on visible cable tray overfill.
You committed to complete and issue this revision by June 8, 1984.
Contrary to the above, as of August 1,-1984, this document was not revised.
- 3. Your commitment required revision to Stone and Webster Field Con-s truct ion Procedure FCP-431 to provide information to construction for control of cable raceway fill.
You ' commited. to complete and issue this revision July 30, 1984.
Contrary to the above, as of August 1, 1984, this document was not revised.
- 4. Your commitment required revision to Duquesne Light Inspect ion Procedure IP-8.4.1 to es tablish inspect ion criteria for cable tray overfill.
You committed to complete and issue this revision by July 30; 1984.
Contrary to the above, as of August 1, 1984, this document was not revised.
Response
- 1. 2BVM-88 has been revised (Addendum 1,
dated August 10, 1984) to delineate -the engineering review procedure which must be completed prior to authorizing a cable tray overfill. These procedures include a checklist which will accompany all new computer overfill authoriza-tion forms and a ~ 1ist of required approval signatures.
In the case
- w..
Unitcd Ststas Nuc1Gcr R:;gulctcry Conuniccion Mr. Richtrd W. Stercotecki Page 3 of C and X trays, 100 percent fill in the design-basis computer system is based on a 3 inch usable depth of cable tray. However, all trays at BVPS-2 are constructed with a 4 inch usable depth.
There-fore, if projected fill is ~ between 100 and 133 percent, no detailed review ef fort will. be - performed.
If the projected fill - is greater pract icable alternate than 133 percent, it will be verified that no routing exists.
The ' engineers will then establish that the cable depth due to the new cables will be les s than 1-1/2 inches above the tray side rails and will determine the projected weight due to the new cables.
The signature of the _ Lead. Structural Engineer (or his designee) will be required if the projected weight of tray cables, after overfill, exceeds 35 lb/ft.
If the projected depth is greater than 1-1/2 inches above the side rail, the overfill authorization will not be approved.
Final cable installation and tray fill verification will be accom-plished by DLC Site Quality Control (SQC).
Nonconforming conditions will be documented by SQC and formally dispositioned. by SWEC engi-neering.
It should be noted that the raised covers can accommodate fills up to 2 inches above the side rail. The 1/2 inch margin may be used to - prevent the need to remove cable in nonconforming installations.
- 2. Engineering and Design Coordination Report (E&DCR) 2P-4505 was issued August 2,1984, to revise 2BVS-931 in accordance with the response to Item 1 of commitments. The tray fill controls discussed in E&DCR 2P-4505 apply to both safety and nonsafety-related trays as well as tray fittings (e.g., tee's, crosses, etc.).
3&4. Change No. 15 to FCP 431, " Cable Pulling" was issued August 3,1984, to meet commitment No.
3 above.
Site Quality Control (SQC) has revised IP 8.4.1, dated August 9,
- 1984, to reflect the above requirements.
The revisions tu FSAR Table 8.3-4 were submit ted to the NRC in 2NRC-4-084 dated June 15, 1984.
A change to the FSAR has been generated and will be inco rpo rated in a future acendment to the FSAR. As previously stated, the modified tray installation can accommodate overfills up to 2 inches above the tray side rails.
Although design criteria and field construction procedures will limit installations at 1-1/2 inches above the s ide rail, the 1/2 inch margin r ey be used to accept field nonconfocmances between 1-1/2 and 2 inches upon proper engineering evaluation.
The above actions complete the commitments documented in 2ASR-01126 and 2ASR-01135 from the meetings of May 17, 1984, and May 24, 1984.
Completion of these commitments should provMe the necessary controls on the amounts of cable overfill allowed.
Completion of the revisions to the FSAR Table 8.3-4 ensures an accurate de sc rip t ion of the amount of tray fills.
These actions should provido the necessary information in order to close Unresolved Item 83-05-09, " Cable Raceway Fill."
DUQUESNE LIGHT COMPANY SUBSC IBED AND R
BEFORE ME THIS 47$
DAY OF
, 1984.
Ab)
. Wool Notary Public Vice President ANITA ELAINE REITER, NOTARY FUDLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986 -
l
,U;itsd.Stctco Nuc1ccr R gulttcry Commiccion Mr. Richcrd W. Stcrootscki J
Page 4 JS/wjs cc:
Mr. R. DeYoung, Director (3)
Ms. M. Ley, Project Manager Mr. E. A. Licitra, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk
REFERENCES:
1).NRC Inspection Report 84-09 to Mr.
E.
J.
Woolever dated September 20, 1984
- 2) 2BVSW-34, 288-DLLN from Mr.
C.
R.
Bishop to Mr.
R.
J.
Swiderski dated October 18, 1984 3)-2DLS-23155, dated October 22, 1984 COMMONWEALTH OF PENNSYLVANIA )
)
SS:
COUNTY OF ALLEGHENY
)
On this g 4 M day of
/
/A_.
//,f '
, before me, 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 execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set fo rth in the Submi t tal are true and correct to the best of his knowledge.
Notary Public
' ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20.1986 A
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