ML20126J618
| ML20126J618 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/31/1985 |
| From: | Anderson C, Ebneer S, Ebneter S, Gray H, Paolino R, Prividy L, Raval J, Schaeffer M, Shaub T, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20126J563 | List: |
| References | |
| 50-412-85-07, 50-412-85-7, NUDOCS 8506100649 | |
| Download: ML20126J618 (67) | |
See also: IR 05000412/1985007
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
f Report No. 50-412/85-07
l Docket No. 50-412
License No. CPPR-105 Priority --
Category B
Licensee: Duquesne Light Company
Robinson Plaza Building No. 2
Suite #210, PA, Route 60
Pittsburgh, Pennsylvania
Facility Name: Beaver Valley Power Station, Unit 2
Inspection At: Shippingport, Pennsylvania
Inspection Conducted: March 18 - 29, 1985
Inspectors: - .
C. Andhson,/ Chief, Plant Systems
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date
Section
WSs
H. Gray, LyReactor Engineer
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R. Paolino, ' Lead Reactor Engineer
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L. Prividy, Resident Inspector
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date
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J. Raval, Wactor Engineer date
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M. Scfiaef fer, Re' actor Engineer ' date
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T. Sha\b, Reactor Engineer
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L.' Tri) , Chief," Projects Section #3A date
Approved by: Y- - 5/
S. D. Ebneter, Director, Division ' '
of Reactor Safety date
' Inspection Summary: Inspection on March 18 - 29, 1985 (Report No. 50-412/85-07)
l Areas Inspected: An announced Regional Construction Team inspection of the
Beaver Valley Unit No. 2 facility by regional-based inspectors and the resident
, inspector. The areas of mar.agement, quality assurance, engineering /construc-
l tion interfaces, electrical / instrumentation construction, and installation of
piping, supports, and mechanical components were inspected. The inspection
i involved 928 hours0.0107 days <br />0.258 hours <br />0.00153 weeks <br />3.53104e-4 months <br /> of direct inspection effort (693 hours0.00802 days <br />0.193 hours <br />0.00115 weeks <br />2.636865e-4 months <br /> on-site and 235
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hours in the regional office).
Results: Three violations were identified in the five areas inspected. One
in the area of electrical construction with several examples of problems
resulted from failure to follow procedures. Another in the area of engineer-
ing construction interface (electrical) involving failure to retrieve
records. This violation related to considerations of side wall pressure in
cable pull calculations. The third violation related to numerous examples of
failure to follow procedures involving a lack of attation to detail in pro-
viding correct administrative information on documents.
No major problems were identified during this inspection. The licensee has
made significant overall progress in improving the engineering / construction '
interface with regard to addressing problems and weaknesses identified in the
1984 SALP. This involved the initiation and implementation of several '
programs to correct the problems and strengthening the Site Engineering Group
staff by the addition of key experienced personnel. There are indications of
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lingering problems in the engineering construction interface for electrical
construction activities. Several problems were noted in this area, leading us
to conclude that this area is a weakness. Changes in the project over the
past year from a construction only phase to a construction startup phase have
resulted in frequent changes in the DLC project management and the Nuclear
Construction Division with three different individuals handling the duties of
DLC Project Manager and the DLC Nuclear Construction Division procedures manual
in need of substantial revisions in several areas. This has led us to conclude
that this area is also a weakness. However, no specific site construction
problems have been attributed to the DLC deficiencies in the project management ;
area.
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- In general, the team concluded that the quality of construction is good. An
intensive and coordinated examination of the. primary component cooling water
(CCP) system by the multi-disciplined engineering team members yielded no
significant negative findings. Interviews by all team members of approximately
40 site personnel at random, including crafts and level 1 and 2 QC personnel
over a cross section of mechanical and electrical areas yielded no substantial
negative comments. The consistent view of these site personnel was that work
quality at the site is good,
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TABLE OF CONTENTS
Page No...
1. Persons Contacted 2
2. Purpose and Scope. 3
. 3. Project Management 4
-3'1 -Organization.
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3.2 -Areas Inspected. 4
3.3 ' Findings 4
3.4 Conclusions 11
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4. --Engineering / Construction Interfaces 11
4.1 Background and Organization 11
4.2 Areas Inspected and Findings 13
4.3 . Conclusions 24
5. Quality Assurance (QA) 25
5.1 Organization 25
5.2 Areas _ Inspected 25 .
5.3' Findings
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5.4 Conclusions 32
5.5 Program Review- 32
6. Piping and Mechanical Components 33
6 .- 1 Organization 33
6.2 Areas Inspected 33
6.3 Findings 33
6.4 Conclusions 41
6.5 Documents Reviewed 41
7. Electrical / Instrumentation Construction 42
7.1 Organization 42
7.2. Areas Inspected 43
7.3 Findings 43
7.4. Conclusions 53
8. Status of Previously Identified Items 54
9. JInterviews 56
10. Unresolved Items and Program Weeknesses 56
11. Exit Interview 56
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DETAILS
. 1. Persons Contacted
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1.1 .Duquesne Light company (DLC)
L. E. Arch, Senior QA Engineer
J. Arthur, Chairman of the Board of Directors
J. A. Bajuszik, Director Construction Engineering
J. J. Carey, Vice President, Nuclear Group
F. A. Cavalier, Manager Project Control
R. Coupland, Director QC
C. R. Davis, Director Quality Assurance
C. E. Ewing, Manager Quality Assurance
E. J. Horvath, Engineer
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J. A. Hultz, Deputy Project Manager
E. F. Kurtz, Manager Regulatory Affairs
C. Majumdar, Assistant Director, QC
T.-P. Noonan, Startup Group
D. F. Rohm, Assistant Director, QC
H. M. Siegel, Engineering Manager
R. J. Swiderski, Startup Manager
R. Wa11auer, Compliance Engineer
E. J. Woolever, Vice President Special Nuclear Projects
1.2 Stone and Webster Engineers Corporation (S&W)
W. Barancwski, Assistant Project Manager
W.' H. Bohlke, Senior Project Manager
A. A. Dasonbrock, Senior Construction Manager
H. F. Foley, Site Project Manager
A. C. McIntyre, Superintendent of Site Engineering
F. N.-Morrissey, QA Project Administrator
J. G. Novak, Superintendent of Construction
W. J. Parker, Assistant Project Engineer
J. H. Ronco, Assistant Superintendent of Construction
C. H. Wilbur, Assistant Project Engineer
J. E. Williams, Senior Construction Manager - Vice President
1.3 U.S. Nuclear Regulatory Commission (NRC)
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C. J. Anderson, Chief Plant Systems Section
S. D. Ebneter, Director, Reactor Safety Division
H. Gray, Reactor Engineer
R. J. Paolino, Reactor Engineer
L. Prividy, Resident Inspector
J. H. Raval, Reactor Engineer
M. J. Schaeffer, Reactor Engineer
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E. T. Shaub, Reactor Engineer
L. Tripp, Chief Projects Section 3A
G. A. Walton, Senior Resident Inspector
The above listed personnel attended exit meetings held on March 22
and/or March 29, 1985. Other managers, supervisors, engineers, quality
technicians and craftsmen were contacted during the inspection.
2. Purpose and Scope of the Inspection
The purpose of this inspection was to determine the effectiveness of the
licensee's management in directing the construction of Beaver Valley 2 in
accordance with NRC requirements, licensee's commitments and industry
standards. This was accomplished by performing in-depth examinations in
the areas of management controls, design controls, quality assurance, and
construction. The construction area was further divided into the elec-
trical, mechanical, and piping disciplines.
The inspection spanned a six week period and was divided into two weeks
of preparation, two weeks on-site, and two weeks of report writing. The
inspection began with the two week preparation period in the regional
office reviewing the licensee's construction program documents and
familiarizing the inspectors with the organization. The document review
cansisted of the licensee's quality assurance program, construction
procedures, and the Final Safety Analysis Report.
During the inspection a coordinated examination was made of the component
cooling water system by all engineering discipline team members.
Portions of the system were selected and detailed examinations wera made
of the piping, supports, valves, heat exchangers, pumps, and electrical
components. The examinations consisted of visual observations to verify
that the equipment met the drawings and specifications. The quality
documentation was reviewed to confirm that appropriate inspections had
been performed. Other systems and components were examined as time
allowed utilizing similar inspection methods.
An area given special attention was that of the engineering construction
interface. During the past year the NRC had identified a weakness in the
area of the engineering / construction interface. The licensee committed to
take several initiatives to attempt to improve performance in this area.
An examination was made of these initiatives and their implementation.
Concurrent with the foregoing examinations, the remainder of the team
explored the broader aspects of management, quality assurance and
engineering / construction interfaces. There was continuous communication
between team members to identify common deficiencies or strengths. These
in-depth insights were supplemented by interviews of management staff,
engineers, quality assurance auditors and craftsmen.
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3. Project Management
-3.1. Organization
Project management of Beaver Valley, Unit 2, where construction was
approximately.84*4 complete at the end of January,1985, is accomplished by
a team approach of Duquesne Light Company (DLC) and Stone and Webster
(S&W) personnel. S&W handles the daily activities as the construction
manager while DLC oversees the management of these activities. The DLC
Vice-President, Nuclear Group, who is located at the site, has the total
responsibility for Beaver Valley, Unit 2. This responsibility includes the
supervision and control of S&W, all contractors, QA/QC work and startup
operations. To accomplish this responsibility, the DLC Vice-President,
Nuclear Group, has a staff of Engineering, Startup and Project Control
Groups which assist him in his decision-making. Also, the DLC QA Manager
reports.directly to the DLC Vice-President, Nuclear Group. The DLC
-Vice-President, Nuclear Group, and his staff interact closely with the S&W
Site Project Manager and his staff to stay abreast of the project's acti-
vities and to provide direction. The S&W Site Project Manager, who
reports directly to the DLC Vice-President, Nuclear Group, has overall
responsibility for all construction. To accomplish this responsibility
reporting.to the S&W Site Project Manager, are the SW Construction Manage-
ment, Cost, Scheduling and Site Engineering Groups which define, super-
vise, coordinate and control all site contractors. The actual construc-
tion work is accomplished by various contractors working for the S&W
Construction Manager. The major contractors currently on site are
Schneider Power Corp. (SPC) for the mechanical work and Sargent Electric
Co. (SECO) for-the electrical work.
3.2 Areas Inspected
The inspector reviewed the current organization charts of the project
management team. Approximately 20 members of the project management team
were interviewed and various meeting reports and procedures were reviewed.
Also, the inspector attended a Site Manager's Meeting. These interviews
and reviews were conducted to determine the impact of organizational
changes on the project management effort, the adequacy of management
ccmmunications and reports, the control of site contractors, management
involvement in the project, and management support of QA/QC activities.
3.3 Findings
3.3.1. Organizational Changes - Impact on Project Management
The current project management team has evolved after a series of major
changes in the DLC and S&W organizations in the past year. In addition to
these organizational changes, the project has progressed in the past year
from the construction-only phase to the construction-startup phase. A
major factor that has provided continuity to the project in the midst of
these organizational changes and project transition has been the weekly
Site Manager's meeting which is attended by DLC and S&W Site managers and
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contractors as appropriate. At this meeting DLC and S&W management
discuss the status of significant problems and determine their impact on
project construction, thus providing the necessary direction to the
project.
The inspector reviewed the DLC Nuclear Construction Division Procedures
Manual to determine if it was consistent with the. current alignment of
personnel and their responsibilities. From this review and the interviews
of personnel, it was clear that the DLC Nuclear Construction Division
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Procedures Manual required revisions in several areas as follows:
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Section 1.0, Management - The organization chart for the DLC Nuclear
Construction Division (NCD) needs to be changed to reflect the
designation in March, 1985, of the Vice-President, Nuclear Group as
the individual with the total responsibility for Beaver Valley, Unit
2. The prior Vice-President of the NCD has been assigned a Special
Nuclear Projects function. Nuclear Construction Division Procedure
1.2. Functional Organization and Responsibilities, must be revised to
i provide functions and responsibilities consistent with these DLC
organizational changes.
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Section 5.0, Construction - Procedures 5.1, Organization, and 5.2,
Construction Responsibility and Control, require substantial revision
to reflect a major reorganization of personnel who were previously in
the DLC Nuclear Construction Department. This department was dis-
banded around Mid-1984 as the DLC Startup Group was being formed.
Personnel who were previously in the DLC Nuclear Construction Depart-
ment were assigned to other departments while retaining many of
their construction department functions.
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Section 7.0, Project Control - The DLC Project Control Organization
is a relatively new group formed in late 1984. Various procedures in
this group were being revised by DLC to provide consistency with
changes to be made to Section 1.0, Management, and Section 5.0,
Construction, mentioned above.
Also, the inspector learned from various interviews that other DLC organi-
zational changes in the past year have resulted in three different indivi-
duils handling the duties of NCD Project Manager with the most recent
change being that the Vice-President, Nuclear Group, will handle these
. duties.
The frequent turnover of the NCD project manger duties to different per-
sonnel and the lack of current DLC organizational charts with consistent
procedures in the Nuclear Construction Division Procedures Manual are a
deficiency within the project management organization. Although DLC
management recognized the need to upgrade the Nuclear Construction
Division Procedures Manual in these areas and expected this effort to be
-completed by the end of April, 1985, the inspector considered this
deficiency in the DLC Nuclear Construction Division to be a weakness in
the project management organization. (50-412/85-07-01)
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t In contrast to the weakness noted above, the inspector recognized that
DLC and S&W Management had taken the initiative to strengthen the project
management organization by assigning a full time S&W Site Project Manager
and a full time S&W Site Engineering Sponsor. Both of these individuals
have been contributing to the project management effort since late 1984
and their contributions so far have had a positive influence on the
project. In this regard, the S&W Site Project Manager has been instrumen-
tal in the development of the Quality Improvement Management Plan (QIMP)
l which is discussed further in Section 5.
3.3.2 Management Communication and Reports
Through interviews, reviews of reports and procedures, and general obser-
vation the inspector determined whether DLC and S&W project management
were communicating adequately with all project organizations concerning
the status of activities and problems of the project. The inspector found
that regular reports are distributed appropriately and regular meetings
are held. Examples of these activities are listed below which indicates
that clear lines of authority and communication are present throughout the
project.
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A Monthly Project Status Report is prepared by the DLC Nuclear Con-
struction Division and distributed to the Central Area Power Coor-
dinating Group (CAPCO), the owner of the project which is comprised
of Ohio Edison Company, Cleveland Electric Illuminating Company, i
Toledo Edison Company, and Duquesne Light Company. This report is a
comprehensive status of the project in the areas of cost / schedule,
engineering, construction, test /startup, and regulatory affairs.
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A semi-annual report is provided by the DLC QA Manager to the DLC
Vice-President, Nuclear Construction Division. This report gives a
detailed summary of QA/QC activities for the project during the last
six months.
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An S&W Headquarters Summary Report is provided monthly to the DLC
Nuclear Construction Division. Included in this report is an NRC
Open Items Status List which tracks NRC inspection findings.
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Monthly reports are provided by each member of the S&W Site Project
Manager's staff and the DLC Vice-President, Nuclear Group's staff,
documenting the activities of the respective staffs.
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Weekly construction meetings are held by the S&W Construction Manager
and his building managers to review progress. Weekly progress
reports are issued by the S&W Site Project Manager concerning com-
modities installed and performance achieved.
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Both major contractors, SPC and SECO, report monthly to the S&W Site
Project Manager concerning their performance toward achieving project
goals in 1985 in the areas of quality control, fiscal plan, schedule,
manpower and productivity.
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As mentioned previously, a weekly Site Manager's meeting is held to
discuss the status of significant problems and determine their impact
on construction. The DLC Vice-President, Nuclear Group, conducts
this meeting. DLC and S&W management and contractors, as appropri- )
ate, participate. The inspector attended the meeting of March 27,
1985. It was evident that good communication existed concerning the
16 major items that were discussed.
In addition to these regular forms of communication, the inspector noted
how a recent project issue was communicated within the project---namely,
the issuing of a stop work order on the installation of safety-related
instrumentation tubing. The inspector reviewed letters issued by the S&W
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Construction Manager to the contractors and S&W Site Engineering Group to
the S&W Construction Manager on this subject. Based on the review of
these letters and interviews conducted with the various DLC, S&W, and
contractor personnel, the inspector concluded that communications were
clear from the engineering to the contractor level from the time that this
stop work order was issued until approximately one month later when the
stop work order was completely lifted.
No violations were identified.
3.3.3 Control of Site Contractors
Based on interviews and reviews of various documentation, the inspector
assessed the current working relationships of the S&W Construction
Manager, his staff, and the various contractors. In these interviews and
reviews, the inspector also questioned the adequacy of the control of site
contractors in the past year and determined that project management had
recently taken some initiatives to improve the area where high rejection
rates of mechanical work and slow progress of electrical work were being
experienced.
The S&W Construction Manager, who reports to the S&W Site Project Manager,
has the immediate responsibility for project const:uction. Reporting to
him are key S&W personnel who are managing the various contractor's work.
Since the project is now in the construction-startup phase, construction
management must closely coordinate the construction work with the DLC
startup personnel through an organized system release and turnover pro-
cess. Various S&W building (e.g., Reactor Containment) managers coordi-
nate their activities consistent with the priorities as defined by the S&W
system release and milestone (e.g., steam generator hydro) managers.
After system turnover to the DLC Startup Group, any work that must be
performed is tracked by a post-turnover work tracking group.
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All cor. tractors report to the S&W Construction Manager and closely coor- j
dinate their work through his staff. In addition to various engineering l
documents, the contractors' work is performed through S&W approved Field I
Construction Procedures. SPC and SECO are the major contractors on site
performing the mechanical and electrical work. Other contractors are
present for the insulation, fire protection, structural / civil and painting
work.
The basic planning document that is used to sequence work is the 90-Day
Work Plan which is developed by the S&W Construction Planning Department.
This document is formulated consistent with achieving the major milestones
given in the Integrated Project Plan. The Core Planning Groups in both
SPC and Seco develop 2-week work schedules to implement the 90-Day Work
Plan. These 2-week work scnedules receive input from the contractor area
l foremen, they govern the daily construction work and they are utilized by I
the S&W building managers for work tracking. The use of the 90-Day Work
Plan in this manner was recently initiated in October, 1984, in an attempt
l to improve the system release process. In addition to developing this
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schedule document to monitor contractor performance, project management
- knew that the following areas needed attention and correction:
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The "first time unsat" rate for piping, instrumentation, and HVAC
j Supports was undesirably high in late 1984. Since then great
emphasis has been placed by S&W on a " quality first" method of per-
forming work in the workplace i.e., making sure that the craftsman
f and his foreman build the product to the best of their ability before
p presenting it to QC for final inspection. In parallel with this l
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corrective measure, SPC replaced their Project Manager and Assistant
Project Manager effective January 1, 1985. The combination of these '
actions has produced a positive turnaround for mechanical work in
early 1985 when the combine "first time unsat" rate for piping,
instrumentation and HVAC inspections decreased from 24% in December,
1984, to 21% in January 1985.
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While the above item related to "first time unsat" concerned pri-
marily mechanical work, control of the electrical work has not been
without problems. Numerous unresolved electrical issues (e.g.,
[ unsupported cable length, cable separation to meet Regulatory Guide
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1.75, etc.) are hindering the progress of electrical work. In an
attempt to address these issues in a systematic way by blending the
problem resolution into the construction schedule, a Project Elec-
trical Plan identifying 24 outstanding electrical issues was
developed in February, 1985. The potential benefit in the use of
this plan-is that S&W should be able to better evaluate and control
SEC0's work.
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While it is premature to assess the overall effectiveness of the above
actions taken by project management, these actions are positive and they
are indicative that management is aware of problem areas and is taking
steps to' correct them.
The inspector had additional observations concerning the control of site
contractors as follows:
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Currently, there are approximately 2500 crafts performing work at the
site and approximately 320 personnel engaged in Site Quality Control
(SQC) activities. The SQC personnel report to the DLC-QC Director.
Approximately 100 and 120 employees respectively are involved in the
electrical and mechanical inspection efforts. The ratio of QC
inspectors to craftsmen is satisfactory.
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There are indications that SPC has strong document control. The
inspector verified that the latest revision (Issue No. 5) of Speci-
fication 2BVS-935, Installation cf Ventilation and Air Conditioning
Systems, was being used. The SPC Document Control Group issued this
latest revision internally to all SPC departments and the inspector
confirmed use of this latest revision in the field by interviewing
the Sheetmetal Superintendent.
No violations were identified.
3.3.4 Management Involvement in the Project
By interviews and review of various documentation, the inspector was able
to determine that DLC and S&W management were actively involved in the
construction of the project. This was demonstrated by the following
items:
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The Chairman of the Board of Directors of DLC visits the site at
least weekly and is briefed on the project status by the DLC Vice-
President, Nuclear Group, who is located on site and is beginning to
devote almost all of his time to the project. The DLC Vice-President
tours the plant several times a week.
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The DLC Vice-President, Nuclear Group, conducts a weekly Site
Managers meeting at the site to discuss the status of significant
, problems and determine their impact on construction.
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In late 1984, S&W added two new members on site to the Project
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Management Team - the Site Project Manager and the Site Engineering
Sponsor who are actively involved in the project.
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There are plans for substantial management participation in QIMP.
This is a new management system for the regular review of construc-
tion quality performance indicators, clear assessment of the causes
for adverse performance trends, and institution of appropriate
corrective measures for performance improvement. Senior management
on the QIMP management board are the DLC Vice-President, Nuclear
Group and the S&W Site Project Manager. Senior management partici-
pation in QIMP has taken the place of a previous group, the Senior
Management Corrective Action Panel, which is being dissolved as
QIMP is being formed.
No violations identified.
3.3.5 Management Support of QA/QC
The inspector conducted interviews with DLC-QA/QC management to determine
if DLC, S&W and all contractors are committed to building a quality plant.
The following observations were made:
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DLC has had in place for over a year a Quality Concerns Program that
enables any employee to report their concerns directly to DLC if
unable to do so through their normal channels. A dedicated telephone
number is assigned to receive such calls. Any such calls and concern
are handled by the DLC-QA Department. This program is visibly
endorsed by the display on a memo signed by the Vice-President,
Nuclear Construction Division which describes the Quality Concerns
Program in detail on employee bulletin boards throughout the plant.
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The staffing of the DLC-QA/0C organization appears to be adequate for
its existing responsibilities. In the past, there has been adequate
support from DLC management to support increased QA/QC responsibi-
lities with additional personnel. It is anticipated that the
inspection load, especially in the electrical area, will increase
substantially in the next year which will present a cost considera-
tion for management.
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The recent (March '85) DLC reorganization, where the DLC Vice-Presi-
dent, Nuclear Group was given total responsibility for Beaver Valley,
Unit 2, has presented a unique set of circumstances not previously
encountered in the project concerning the independence of QA/QC from
the pressures of construction cost and schedule. The DLC-QA Manager
now reports directly to the DLC Vice-President, Nuclear Group. If he
has any concerns that might be in conflict with the DLC Vice-
President, Nuclear Group, the DLC-QA Manager must now approach the
DLC Chairman of the Board. The inspector noted that this was a
potential concern toward future decision-making. However, it does
not reflect on the current or past QA/QC program of DLC, which has
provided evidence of adequate management support. This potential
concern relates to the contrasting ongoing cost pressures on the pro-
ject as evidenced by a recent decision by CAPC0 to decrease project
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funding by 100 million dollars for 1985, and the above noted pro-
jected future need for additional personnel to support the QA/QC
inspection effort. This is an unresolved item pending the NRC review
and evaluation of licensee information regarding the reorganization
to assure that QA/QC is independent from the pressure of construction
cost and schedule (50-412/85-07-02).
3.4 Conclusions
The current DLC and S&W Project Management Team has been determined to be
adequate for successfully completing the project. Senior Management
. involvement in the project has increased and management communications and
reports for the various organizations are satisfactory. Other specific
positive measures have recently been taken which are signs of good project
management such as:
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There have been recent additions to the project management team of
the S&W Site Project Manager and the S&W Site Engineering Sponsor who
both have had prior extensive nuclear experience.
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Senior management is placing heavy emphasis on quality as evidenced
by the " Quality First" method of performing work and the project
adoption of QIMP.
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a Project Electrical Plan has been developed in an attempt to better
manage the solution of 24 major electrical issues and integrate the
resolution of these issues into the construction schedule.
While these measures are positive signs of good project management, they
have not been in place long enough to determine their overall effective-
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ness. The area of DLC project management is considered a weakness. This
is because of the frequent changes within the DLC NCD organization during
1984 a: the project progressed from the construction-only phase to the
construction-startup phase. The weekly Site Managers meeting has been a
positive factor in maintaining project management control in the midst of
this. project transition and project management instability.
In view of the recent DLC NCD reorganization future decision making should
be monitored to ensure that the independence of QA/QC from the pressures
of construction cost and schedule is maintained.
4. Engineering / Construction Interface
4.1 Background and Organization
4.1.1 Background
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In the 1984 Systematic Assessment of Licensee Performance (SALP) Report,
weaknesses were identified in this functional area and it was assigned a
Category 3 rating. In particular, concerns were expressed that engineer-
ing documents frequently failed to contain sufficient information and/or
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information that was clear and unambigous enough for field use by Con-
struction and QC personnel. The NRC expressed the view that several
engineering documents had apparently not received adequate " construct-
ability reviews" before they were used at the site, that resolution of
problems encountered in the field was often cumbersome, and that correc-
tive actions usually involved additional inspections but failed to
identify and correct the root cause(s) of such problems. The licensee was
requested to propose a program for resolution of engineering / construction
interface probleas.
In their response to the SALP report, the licensee committed to take
several initiatives to attempt to improve performance in this area.
These included:
-
Strengthening of the Site Er.gineering Group (SEG)
-
Establishing a constructability review group at the site to review
engineering documents before issuance.
-
Redrafting drawings to clarify details.
-
Improving construction supervision and engineering presence in the
plant.
These initiatives and their implementation were included within the
inspection scope in this area.
4.1.2 -Organization
' Stone and Webster (S&W) has the major overall engineering responsibilities
as the licensee's contracted architect engineer. These engineering
activities are primarily accomplished at Boston under the direction of the
S&W Project Engineer. The SEG reports to the S&W Senior Project Engineer
(as does the Project Engineer). It is responsible to the Project Engineer
for performance of engineering functions as delegated to the SEG. Primary
SEG responsibilities include:
-
Providing resolution of engineering problems encountered during
,
construction.
-
Controlling issuance of engineering drawings and field erection
drawings / isometrics.
-
Coordinating Contractor design activities in the areas of seismic
conduit, small bore piping, fire protection and HVAC. (Most of the
Contractor design activities are accomplished by Schneider Power
'
Corporation and Sargent Electric Company as the primary mechanical
and electrical subcontractors respectively).
-
Interface with Construction and Site Quality Control to clarify
engineering requirements.
I
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13
-
. Maintain close interface with Boston Project Engineering on all
field problems or piping / equipment deliveries requiring Boston
Engineering resolution
-
Provide responses to Requests for Information (RIs) and dispositions
for Nonconformance and Disposition (N&D) Reports.
-
Prepare and coordinate the development of field construction proce-
dures.
-
Evaluate all construction rework.
Most original engineering design and analysis activities are done in
Boston in addition to establishing design criteria, control and issuance
of first level type engineering documents, supporting calculations and
. analyses, etc. Sargent Electric Company (SECO) and Schneider Power Cor-
poration (SPC), maintain on-site engineering staffs. In particular, the
Schneider on-site engineering efforts in translating S&W specification and
orthographic drawings for large and small bore piping were included in
this inspection. Site construction activities are accomplished by the
subcontractors such as SECO and SPC as a part of the site construction
organization under the control of the S&W Site Project Manager (the SEG
Superintendent also reports to the S&W Site Project Manager in addition to
reporting to the S&W Senior Project Engineer).
Since the SEG provides the key interface between off-site engineering and
on-site construction, much of the inspection of the engineering /construc-
tion interface was concentrated on SEG activities with some inspection of
the SPC engineering activities.
4.2 Areas Inspected and Findings
4.2.1 Strengthening of SEG
4.2.1.1 Areas Inspected
The inspector reviewed the organization-and manning levels within the
SEG by comparison of the present organization with that existing
before issuance of the 1984 SALP report on May 18, 1984. In parti-
cular, the addition of key personnel in management level positions to
provide assistance and support to the SEG Superintendent was
reviewed.
4.2.1.2 Findings
The SEG staffing level was increased from 249 on 5/4/84 to 298 on
March 15, 1985. Of these 298 persons, approximately 76 were engineers,
151 were designers, 14 were model makers and 48 were designers from
Schneider and the S&W Toronto office incorporated into the SEG. Actual
strengths were nearly identical to planned strength. More significantly,
- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - -
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staffing of the SEG had been augmented with the addition of senior tech-
nical personnel. This included a doubling of the number of Assistant
Superintendents (from 3 to 6) by the addition of personnel with consider-
able project and field experience from the Shoreham, North Anna and River
Bend projects. A Site Engineering Sponsor has been added. Although not
in the direct supervisory chain or involved in the routine day-to-day
issues, the presence of this senior management level person provides evi-
dence of added upper S&W management level attention to the BV-2 project.
He acts as an advisor to the SEG Superintendent, is involved in major
policy and management issues, provides guidance for SEG activities, and
gives the SEG office a representative within upper level S&W management.
Finally, as an additional indication of increased staffing, the number of
principal piping engineers within SEG has gone from one to three, the
number of principal electrical engineers has gone from one to two, and a
licensing engineer and a planning group have been added. S&W has also
attempted to strengthen and better integrate the contractor design efforts
by putting two key people in the Schneider organization and a key person
in the Sargent organization and placing Sargent and Schneider construction
personnel into the Integrated Construction Support Group (ICSG); see
Section 4.2.3.
4.2.2 Constructability Reviews
4.2.2.1 Areas Inspected
A Mechanical Constructability Review Team (CRT) was established in early
June, 1984 to address concerns such as cluttered drawings for complex pipe
hangers, confusing and sometimes conflicting installation specifications,
and differences in interpretation between the engineers, crafts and QC
inspectors. Similarly, an Electrical CRT was established in early July,
1984 to address essentially the same types of problems in the electrical
area. These CRTs were composed of S&W, contractor and QC personnel.
Activities of these CRTs including responsibilities, reports, progress and
results were inspected.
4.2.2.2 Findings
By charter, each of the CRTs was limited to new or reissued drawings going
to Construction. Approximately 8-10 people were initially involved with
the Mechanical CRT and 4-5 with the Electrical CRT. For the first three
months, this was essentially a full time activity for team members.
Initially, the drawing revision rate was high in both areas (approximately
50% and 75% in the mechanical and electrical areas respectively). The
CRTs provided good feedback to the designers / engineers with respect to
the reasons for drawing rejection (including examples) and provided
training sessions.
The following progress was noted:
.
p
3
15'
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The approximately 96 piping rack drawings which had been very complex
and cluttered, in that each rack drawing provided support for multiple
piping runs, were broken down to individual drawings for each pipe
support.
-
In the first three months, approximately 2500 mechanical drawings
were reviewed. By December 1, 1984, 2111 Sargent electrical drawings
had been reviewed.
-
By late 1984, the drawing revision rate had leveled off to the 3 to
5% range in both areas indicating that the maximum impact of the
CRTs had been achieved.
Following the above successes in improving overall drawing quality, in
late 1984, the CRTs were redirected to review drawings only on an audit
basis as on-site and off-site design groups became more proficient at
constructability review during drawing preparation. CRT efforts were
focused on review of drawings for "installability". Problems with instal-
lation feasibility (approximately 20-30% of support drawings) were identi-
fied in the initial sampling (primarily interferences). Corrective
actions included a mandatory model shop review (where applicable) and a
field check prior to submittal to the CRT. By early March,1985, the
Mechanical CRT was doing both "constructability" and "installability"
reviews on an auditing basis whereas the Electrical CRT was doing " Con-
,
structability" reviews on all new issue drawings and "installability"
reviews on an audit basis. Plans were being developed to put.the field
"insta11 ability" reviews within the ICSG (see Section 4.2.3).
No deficiencies were noted by the inspector.
4.2.3 Integrated Construction Support Group (ICSG)
4.2.3.1 Areas Inspected
An ICSG was established in late 1984-early 1985 in the plant in a cen-
trally located area (top level of Auxiliary Building, adjacent to the
Reactor Building and Fuel, Service, Main Steam and Cable Vault areas). At
the time of this inspection, it consisted of 72 personnel. The activities
of this group were inspected including its charter and procedures.
Inspection emphasis was on the functioning of this group including their
involvement and actions in processing and dispositioning Advanced Change
Engineering and Design Coordination Reports (E&DCRs), Construction
- Revision. Notices (CRNs) and Nonconformance and Disposition reports (N&Ds).
Other activities of the ICSG were inspected by reviewing internal memos
describing field identified problems and the Field Problem Report (FPR)
log.
,
e _ ___ _ _ _ _
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E
4.2.3.2 Findings
The charter and functioning of the ICSG are described in Field Con-
struction Procedure (FCP) 515, " Operations of the Integrated Con-
struction Support Group (ICSG)." This procedure was found to provide
appropriate guidelines and assigns well defined responsibilities for
,
ICSG field operations. In particular, it describes the role of
ICSG personnel in initiating and processing CRNs, Advanced Change
E&DCRs and N&Ds. The active role of the ICSG is defined as engineer-
ing involvement in all areas to aid in timely resolution of problems
affecting construction at BV-2. Production engineering and original
design were not considered to be a part of the ICSG work scope, nor
are such activities being performed by ICSG or SEG. The ICSG proce-
dure (FCP-515) was found to be consistent with other Project Manual
(2BVM), Field Construction Procedure (FCP), and DLC Site Quality
Control Procedures incorporating such procedures by reference as
appropriate.
l A sample of twelve (12) CRNs processed by ICSG and applicable to systems
such as the Primary Component Cooling, Safety Injection, Emergency
Diesels, Main Steam System and Safety Injection System were inspected.
Development, review, issuance and control were found to be in accordance
with existing procedures.
A sample of six (6) N&Ds processed through ICSG were reviewed for proper
handling and dispositioning. This included N&Ds dispositioned " Accept as
Is," " Repair", and " Rework". In all cases, ICSG activities were found to
be in accordance with, " Procedure for Handling of Nonconformance and Dis-
position Reports by Site Engineering Group," 2BVM-218.
A sample of thirteen (13) Advanced Change E&DCRs processed by the ICSG
including the supporting calculations for five (5) of the changes were
inspected. Except for Calculation Z-16A-097, Rev. 3 in support of E&DCR
No. 2PA-7547 and minor administrative problems with Calculation Z-83A-
332, Rev. 1, involving revision of pages without so indicating and voiding
and adding a new page when there was no change, this sample was found to
have been properly initiated, processed, reviewed and controlled. Calcu-
lation Z-16A-097, Rev. 3, involving reanalysis of a support due to dimen-
sional changes to correct a drawing error (E&DCR No. 2PA-7547) was found
to contain several inconsistencies / deficiencies. Although new design
loads had been generated which, for example, increased the peak loading in
the Y' direction from -748 to -1483 lbs., the calculation preparer had con-
cluded that since the new design loads were only slightly more than the
old design loads and were relatively small, they would not affect the
'
structural integrity of the support (by engineering judgement). A state-
ment on page 7 of the calculation which indicated that the standard strap
i
i
used in the support was satisfactory because its capacity of 1000 lbs.
exceeded the peak load of 748 lbs. was unchanged from the previous calcu-
lation revision. The inspector found that the support design was adequate
despite the inadequate supporting calculation because a later revised
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calculation for this standard support strap justified a design capacity of
1499 lbs. This inadequately performed and/or documented calculation has
not been cited since it was an isolated example. Neither the inspector
nor a detailed 1984 technical audit of similar cciculations-by a joint
S&W/DLC team found other examples of similar inadequate calculations (see
Section 4.2.4). S&W committed to correct and revise the subject calcula-
tion.
Other activities of the ICSG were briefly reviewed by the inspector. It
was noted that the ICSG is performing a field walkdown, Field Investiga-
tion of New Design (FIND), to identify possible problems in installation
such as interferences before the design is sent to Construction for
implementation. (The Post Accident Sampling System and Emergency Response
Facility design packages are examples). The level of ICSG activity was
observed to be high; during the week of March 6, 1985, 577 problems were
received by ICSG and 555 were resolved. A review of field identified
problems during the week ending March 15, 1985 showed that ICSG personnel
were active in identification of other potential problems before they were
brought to their attention by construction or QC personnel. No other
. discrepancies were noted.
4.2.4 SEG Activities
4.2.4.1 Areas Inspected
The inspector reviewed other activities involving the SEG (in addition to
the functioning of the ICSG) that pertain to the engineering /construc- ,,
tion interface. . This included SEG monthly reports of activities and joint
DLC/S&W audits of SEG activities. The inspector reviewed the SEG Reports
for January and February,1985 (No. 94 and 95). Two joint audits of the
SEG by DLC/SEG ("SWEC Engineering Assurance Audit of Site Engineering
Group," April 23 - June 20, 1984, EA-319, and "DLC QA and SWEC Engineering
Assurance Audit of BV Site Engineering Group", DLCQA-5571, 12/13/84),
including responses and resolution of selected audit findings, were
inspected.
4.2.4.2 Findings
The inspector determined that SEG activities were being closely
tracked and reported to the Project Engineer. For each monthly time
period, this included specifications updated, FCPs that were issued or
revised, drawings revised and other site design activities. In partic-
ular, it was determined that outstanding RI's and N&D's were being tracked
with respect to responsible office, whether or not they affected system
completion and turnover (on turnover lists) and whether or not timely
responses were being received. Except in infrequent cases, it was noted
that timely' resolutions were being received.
_ _
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The DLCQA-5571 SEG audit covered topics such as SEG revisions to drawings;
contractor's (Schneider) small bore piping isometrics; pipe support draw-
ings and calculations; contractor's (Sargent) seismic conduit layout
drawings; Advanced Change E&DCRs; and followup on selected SALP commit-
ments (constructability review and ICSG). The inspector found that the
auditors used detailed checklists based upon procedural requirements con-
tained in applicable project 2BVM and FCP procedures. The inspector
determined that the audit established that the sampled drawings, calcula-
tions, Advanced Change E&DCRs, etc. were being processed, reviewed and
approved in accordance with existing procedural requirements. Outstanding
N&Ds and E&DCRs were found to be adequately monitored in computerized
tracking systems and incorporated within the prescribed 90 day time
period.
The EA-319 audit was found to be technical in nature involving several S&W
engineering specialists from the Engineering Mechanics, Materials
Engineering, Power and Control Systems Divisions / Departments to provide
additional scope and technical depth in addition to S&W Engineering Assur-
ance personnel. The audit involved approximately 2500 man hours including
two weeks on site (April 23 - May 4, 1984). The purpose of the audit was
to evaluate the design process by assessing the technical adequacy of
designs / design changes accomplished by the SEG. The inspector reviewed
the audit results and found that they do not appear to be indicative of
any generic weaknesses in SEG. The audit findings demonstrated the
technical nature of the audit coverage. The inspector reviewed the
responses and resolution for the following audit findings: 12241-182-2,
12241-184-1, 12241-185-2 and 12241-187. Audit responses were found to be
required to identify cause, extent of condition, corrective actions and
actions to prevent recurrence. The lead auditor had evaluated the
responses, and determined if they were satisfactory or if additional
followup actions were required. These audit findings had been closed.
The inspector found that audit responses were required to be thorough as -
evidenced by the depth of response, evaluation and followup actions.
No deficiencies were noted. The EA-319 audit was found to be excep-
tionally technical in nature and scope.
4.2.5 Engineering /Ccnstruction Interface for the Component
Cooling Water Systems
4.2.5.1 Areas Inspected
The inspector reviewed documentation and held discussions with S&W and SPC
personnel to determine the adequacy of design change control measures
implemented on this system. The documentation review consisted of a ran-
dom selection of Nonconformance and Disposition reports (N&Ds), Engineer-
ing and Design Coordination Reports (E&DCRs), Bolted Joint Data Sheets,
Flush Breaks, In-Process Check Lists and drawing control.
4.2.5.2 Findings
_- __
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19
Nonconformance and Disposition Reports (N&Ds)
SPC is not involved in approving N&Ds. However, they have to incorporate
N&D resolutions into small and/or large bore IS0s. The inspector reviewed
the N&Ds and affected documents, as listed in Table 4.2.1.
No violations were identified.
Engineering and Design Coordination Reports (E&DCRs)
SPC incorporates the required input per E&DCRs as approved by S&W into SPC
IS0s. The inspector reviewed the E&DCRs and affected documents listed in
Table 4.2.1.
No problems were observed in SPC's translation of E&DCR requirements into
affected SPC documents.
Bolt Joint Data Sheets (BJDSs)
The SPC-QA program requires BJDSs to be generated per FCP-208 for all
bolted joints in ASME III, Class 1, 2 and 3 piping systems. The SPC Chief
Site Engineer / designee prepares and processes a 3JDS for each bolted joint
in an ASME system. The SPC Building Manager /delignee assigns construction
hold points and presents the BJDS to the SPC Site QA Manager / designee for
review, approval and assignment of quality control hold points, as appro-
priate. Upon approval by the Site QA Manager / designee, the BJDS is
presented to the Authorized Nuclear Inspector (ANI) for review and appro-
val by the SPC Resident Engineer / designee. Once all involved parties have
concurred, the Chief Site Engineer places the BJDS in the traveler packet
and notifies the SPC Building Manager to execute the work. Once the
hydrostatic and flushing are completed, the SPC Construction Superinten-
dent / designee, the SPC-QC Inspector, and the ANI sign the " Bolted Joint
Accepted" portion of the BJDS. The original completed and accepted BJDS
is forwarded to the SPC ASME Engineer via the Chief Site Engineer for
retention. If the joint is broken following final acceptance, the BJDS is
stamped " superseded" and a new BJDS is initiated as described above.
The inspector reviewed the following BJDSs and found them appropriately
executed:
1) ISO 107218-0C, MJ-1, on line 2CCP-006-327-3
2) ISO 107218-0C, MJ-2, on line 2CCP-006-327-3.
No violations were identified.
Flush Break Joints
The S&W project document 2BVM-340, " Procedures for Identification of Flush
Break Joint," requires Flush Break Joints to be identified for verifica-
tion of system cleanliness until the required testing has been completed.
__ ___ - ____ - -_____ ~
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20
The SEG issues the Flush Break Identification Forms (FBIFs) to SPC to
identify holds on specific joints, and these joints are not to be com-
pleted until the joints are released after cleanliness verification. SPC
follows FCP-208 to implement the Flush Break Joints requirements. The SPC
Building Manager, upon receipt of the FBIF, maintains Flush Break Points
in an uninstalled condition with the required minimum clearance require-
ments. The original FBIF is sent to DLC-SUG for post-turnover holds or
sent to the SPC - Test Superintendent for pre-turnover holds and is main-
tained by the holder until completion of the required testing for clean-
liness verification. Once cleanliness is verified, the FBIF holder
obtains the required restoration signatures and returns the completed
FBIF to SEG. When DLC/SVG initiates a Flush Break, the DLC Flush / Hydro
Supervisor is required to sign the FBIF and forward it to SEG via the
Principal Advisory Engineer. The SEG logs the status of the FBIF and
turns the completed FBIF over to the S&W Records Management Center for
distribution.
The inspector reviewed the following Flush Breaks and found them in
compliance with the identified procedures:
lSys.Rel l Cleanliness Verification l Flush l Weld l
No.1 No. I Drawing l Break No. I No.
I I I I !
1 l 13A lRSS-13A l 106 l2RSS-064-F04 l
2 l 6 l SIS-11A l 16 l2 SIS-289-F02 l
3 l 10 lRHS-10 l 12 & 13 l2RHS-013/006-F10l
4 l 10 lRHS-10 l 1 l2RHS-018-F11 l
No violations were identified.
In-Process Inspection Check List (IPCL)
The IPCL is part of the SPC-QA program and administered in accordance with
FCP-208 requirements. When special installation controls or inspections
are deemed necessary in addition to the weld and bolted joint control, the
SPC site QA Manager / designee prepares an IPCL based on inspection require-
ments in design specifications and work sequences in applicable project
procedures and control documents, e.g., CRNs, N&Ds, etc. The SPC QA
manager assigns QA hold points and forwards to the ANI for review and
assignment of hold points. Then, the IPCL is forwarded to the SPC Project
Manager for review and assignment of construction hold points. After the
above described process, the IPCL is sent to the SPC Chief site Engineer
for distribution to the appropriate construction departments for inclusion
in the traveler packet. The SPC-Chief Site Engineer maintains a log
controlling issuance and return of IPCLs. The work is not allowed to pro-
ceed beyond any hold points without the acceptance of the SPC-construction
representative, site QC Inspector or the ANI for their respective hold
points. Upon IPCL completion, the SPC-construction representative returns
the IPCL to the SPC-Chief Site engineer and then returns it to the SPC-QA
manager for closure. After closure of the IPCL, it is forwarded to the
ASME engineer for inclusion in the quality record file. The inspector
reviewed the following IPCLs and verified compliance with the identified
requirements:
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21
1) IPCL No. 1332-I for Mark Piece No. 2CHS-TK21A, ISO No. 108352, 1C
2) IPCL No. 324 for Mark Piece No. 2CCP-PSA077, ISO No. 107207, IF
No violations were identified.
Drawing Control
The inspector reviewed documentation and held discussions with the SEG
and SPC engineering personnel to determine the adequacy of drawing
control. S&W is responsible for flow diagrams and piping ortho-
graphics. The SEG revises the onsite specifications, drawings and proce-
dures per resolutions of E&DCRs and N&Ds as applicable. S&W prepares the
detailed orthographic drawings for large bore piping for SPC's preparation
of IS0s. S&W does not provide the detailed orthographic drawings for
small bore piping, however, SPC prepares detailed IS0s for the small bore
piping. SPC Change and Reporting System Procedure, EDM-83-116 identifies
the requirements to incorporate the changes in their IS0s due to N&Ds,
E&DCRs and RP, RB, and RM drawings via SPC in house Engineering Change
Notifications (ECNs). Drawing control, development, review and approval,
distribution and revision-in process are accomplished by SPC in accordance
with the requirements of FCP-208, Control of Fabrication and Installation
Processes for Piping Systems. The inspector selected the following PCCW
System drawings to verify against document control records for proper
revision:
Drawing Revision Drawing Revision
109905 1G 110479-113-009 4
110702 3G 110479-113-008 4
110703 OH 110479-113-003 3
110704 OG CI-410-631 2
110709 0F CI-410-636 4
110711 IF CI-410-626 5
109901 3H CI-410-620 6
109902 2G CI-410-629 3
107224 00 CI-410-639 4
107223 OG CI-410-637 4
107225 IL 107222 1H
107206 IL 107203 OH
110756 20 107209 1G
110743 1C
110683 2 107210 1M
109907 2F 107211 1F
107214 OM
> The above posting records were verified to be accurate.
No violations were identified.
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4.2.6 Trending and Design Change Control
4.2.6.1 Areas Inspected
Trending and change control at BV-2 has been monitored / evaluated by
several mechanisms. The inspector reviewed systems being used by the
ICSG for tracking / trending problems; E&DCRs and CRNs; DLC/S&W management
activities to determine the origin of engineering and design changes;
trend analyses of changes and the Duke Power May 30-31, 1984 evaluation
of BV-2 change control.
4.2.6.2 Findings
The ICSG was found to be tracking Advanced Change E&DCRs by cause codes.
Typical cause codes were rebar interference, support member interference,
incorrect / insufficient weld, and drawing errors. Similarly, Problem
Reports and CRNs were being coded / tracked. These efforts were too recent
(only since January 1, 1985) to provide bases for significant trending,
conclusions or feedback.
A five man team from Duke Power made a site assessment at BV-2 on May
30-31, 1984 including the overall design change process. The inspector
found that several concerns were expressed including lack of notification
to construction that design changes are coming, that the volume of changes
was excessive (criteria or bases for this ccnclusion were not given), that
the process required to make tb design changes was large and that a
review should be done to deterd ne the root cause of the large volume of
changes. The inspector fousd that several of these concerns have received
additional evaluation and/or followup actions as discussed below.
The inspector found that DLC and S&W had held a series of management
meetings in mid-1984 to discuss the origin of engineering and design
changes and develop ways to trend them. In the fall of 1984, meetings
were held to discuss the results of trend analysis over the first nine
months of 1984. "Cause of Change Categories" were grouped into eight (8)
major categories and numerous subcategories. The inspector determined
that DLC/S&W had concluded that there were no appropriate major actions
that could be taken to reduce the number of changes beyond those already
planned. Three causes of changes were identified where some actions were
already being planned / implemented and/or subsequent actions have been
initiated to attempt to address the problems. They were: (1) interfer-
ences - increased emphasis on use of model and in plant walkdowns before
design documents are finalized; (2) inconsistent documents -increased use
of Advanced Change Notice to identify affected documents when major
changes are made and a review of all FCPs and Inspection Plans against the
specifications which was accomplished in mid-1984; and (3) insufficient
information - CRT offorts have included this area.
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23
The inspector reviewed the number and nature of the above design changes.
Although the number of changes appears to be high (for example more than
7000 design changes or changes in supporting design documentation were
made during January - Septeraber 1984), no definitive trends beyond those
previously identified by DLC/S&W could be ascertained. Trend analysis
summaries continue to be issued at three month intervals.
The inspector reviewed the causes for approximately 75 support calculation
changes. This included 20 pipe stress recalculations due to changes such
as piping or support relocation, changed function and a licensing change
to provide for charging pump miniflow capabilities. It was evident that
changes occur due to a wide range of causes.
When more restrictive changes are made to acceptance criteria, the inspec-
tor questioned how existing installations are treated (i.e. extent of
applicability of such changes to past work and/or justification for accep-
ting past work "as is"). The inspector found that the project had no
formal procedures for clearly delineating the methodology used for dis-
positioning previous work when such changes are made. In some cases, t,e
inspector found Engineering issued instructions at the tin,e the change was
-made with respect to the need for rework, reinspection or justification
for " accept as is". It was determined that QC often identifies such
changes during their review of revised documents (such as specificatlons)
to see if Inspection Plan changes are necessary. When such changes are
identified by QC, the inspector found that they write memos to Engineering '
to get guidance with respect to whether backfitting of the change is
necessary. However, DLC/S&W personnel were unable to provide appropriate
assurance to the inspector that all past changes involving more restric-
tive criteria had been properly considered with respect to whether backfit
to existing work was required in that a systematic approach had not been
applied in the past for such changes. S&W personnel committed to revise
existing procedures dealing with changes by the SEG to Specifications (2
BVM-204) and Drawings (2V-BVM-203) and similar procedures applicable to
Boston Engineering to require engineering criteria changes to be evaluated
for scope of impact and implementation. Such evaluations will be required
to explicitly address specific rework, reinspection or justification to
" accept as is". However, at the end of this inspection, final decisions
had not been made with respect to what to do to assure that past engineer-
ing criteria changes had been properly considered for existing work. This
item remains unresolved pending completion of procedural changes and
further review to determine if the effect/ impact of past chariges to
engineering criteria were properly considered for existing work
(50-412/85-07-03).
No other problems or discrepancies were identified by the inspector.
!
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24
.
I 4.2.7 Primary Component Cooling Water (CCP) Walkdown and Turnover
4.2.7.1 Areas Inspected
The inspector determined that the ICSG had performed an extensive walkdown
of the CCP system during the week of March 11, 1985 just prior to this
inspection. It identified numerous discrepancies in the CCP system. In
i
'
that most of the CCP system had been through system turnover, the inspec-
tor was concerned that several of the items identified in the CCP walkdown
might not be included in site work tracking systems. A review was made of
l the findings of the ICSG CCP walkdown versus the site work tracking
systems.
4.2.7.2 Findings
It was found that the ICSG walkdown identified numerous items (approxi-
mately 31 total) in portions of the CCP system that had been through
turnovcr that should have already been identified and be in site work
tracking systems. Typical items included interferences, loose bolts
i and spacers, missing components and damaged equipment. At the inspector's
request, site personnel compared all items as identified during the walk-
down with existing turnover lists. Licensee and S&W personnel were able
to demonstrate that, with the exception of minor discrepancies, all such
walkdown findings were previously either in the Exception Work Tracking
system or other site tracking systems such as the open items list, had
previously been identified and " accepted as is," or were scheduled to be
checked and/or adjusted at a later date (such as after hydro). The most
significant exception was a support that did not agree with cantilever
guidelines (7 foot cantilever versus guideline maximum of 4 feet).
Although the support was not overstressed, a change was made to add a
cross brace for stability. No other significant problems were noted. The
inspector noted that this was a good test of the turnover inspection and
tracking system in that all ICSG identified walkdown itens that should
have been in a site work tracking system were so found.
4.3 Conclusions
All commitments made by the licensee in this area following the 1984 SALP
were found to be in place and fully implemented. The SEG has been sig-
nificantly strengthened by the addition of key experienced personnel.
Constructability reviews of Mechanical and Electrical drawings has led to
a marked increase in the quality of such documents. The ICSG has sig-
nificantly enhanced the engineering / construction /QC interface by improving
the availability and timeliness of engineering involvement in problem
resolution. Detailed systematic audits of SEG activities are being per-
formed including an audit in April - May 1984 that was exceptionally
thorough in terms of technical nature and scope. These audits provide
further assurance of the adequacy of design and design change work
accomplished by the SEG. The engineering / construction interface was found
- -
=0
O
25
to be effective for the component cooling water system in that a coherent
flow of correct up-to-date documents existed to support construction.
Extensive analyses and trending of changes and their causes is being
accomplished, however, only limited actions to attempt to reduce the
number of changes have been initiated. The number of design changes l
and/or changes in supporting design documentation remains high. The
turnover process appears to be successful in identifying and tracking
existing hardware discrepancies.
In summary, significant overall progress in improving the engineering /-
construction interface has been achieved within the last year. This '
is particularly true of mechanical activities. However, in the electrical
area there are indications of some lingering engineering / construction
interface deficiencies. These deficiencies are discussed further in
Section 7.4. In general, previous problems and weaknesses identified in
the 1984 SALP have been satisfactorily addressed. However, in light of
the electrical deficiencies identified in Section 7, additional attention
to the engineering / construction interface area is warranted in the
electrical area.
5. Quality Assurance (QA)
5.1 Organization
The Duquesne Light Corporation (DLC) Quality Assurance Unit is located
onsite and reports directly to the Vice President, Nuclear Group. The QA
organization has four sections and the Site Quality Control (SQC) group.
The organization prcvides QA overview and independent inspection for both
units 1 and 2.
The QA unit provides review of the QA program and procedures; audit and
overview of construction related activities including procurement
engineering, (both on and off site) design, and installation; and quality
control independent inspections and surveillance.
The inspector discussed the QA organization and responsibilities with
QA/QC personnel and verified the organization was established and opera-
ting in accordance with the current QA program.
5.2 Areas Inspected
The DLC QA program, as applicable to engineering and construction of
Beaver Valley Unit 2, was inspected for conformance to the requirements
and procedures referenced in paragraphs 5.5.1 and 5.5.2. The inspector
reviewed recent audits, the independent QA program assessment, audit
schedules, QA staffing, organizational interfaces, and training and quali-
fications. SQC activities reviewed included organization; inspection,
I
, 4
"
26
'
sample reinspection and re-verification programs; system turnover /startup
activities; measuring and test equipment control; and, nonconformance and
deficiency trending (corrective actions).
5.3 Findings
5.3.1 QA/QC Organization and Interfaces
The inspector reviewed the QA/QC organization and interfaces with regard
to related attributes and concluded that:
--
QA/QC staff was as specified in the QA/QC program organizational
charts;
--
QA/QC staffing was sufficient to perform their responsibilities;
--
There were adequate interfaces with and audits of other
organizations;
'
---
QA/QC activities received adequate support from upper level
management;
--
Management of QA activities was effective; and,
--
QA/QC management was aware of and involved in resolution of site
quality concerns.
The inspector reviewed the minutes for the last five Wednesday weekly
site manager's meetings and the Friday staff meetings and verified QA
presence and involvement. QA does not participate in scheduling and
planning of activities but participation in the two weekly staff meetings
keeps QA aware of project schedules and problems.
Interfaces with other organizations consisted of periodic audits and
participation in contractor audits of construction and engineering
activities as well as participation in corrective action and quality
improvement programs.
The QA department has recently evaluated the staffing needs for unit
operations and is currently pursuing authorization to fill the projected
manpower needs.
No violations were identified.
5.3.2 Audit Program
The DLC quality assurance program requires a comprehensive system of
planned and periodic audits to verify compliance with all aspects of the "
QA program as it implements 10 CFR 50 Appendix B, and to determine the
effectiveness of the program.
q
w.
27 l
l
The following documents were reviewed to determine the depth and scope of
the audit program.
--
1985-86 audit schedule
--
12 audits
DC-2-85-02, Station Quality Control
DC-2-84-12, Protective Coatings
DC-2-84-25, Startup Group
DC-2-84-31, Electrical Installation
DC-2-84-23, Unit 2 System Release / Turnover
DC-2-84-33, Site Engineering Group (SEG)
DC-2-85-04, Engineering Assurance
DC-2-84-11, Procurement Quality Assurance
S&W Engineering Assurance Audit of SEG
DC-2-84-21, S&W Unit 2 Project Boston
DC-2-84-35, BV-2 Nuclear Construction Division
.DC-2-85-12, Nondestructive Examination
--
Training and Certification for Five Lead Auditors
--
Audit status files
--
Open item file and auditor " tickler" files
--
Cooperative Management Audit Program; 1984 audit and 1985 scoping
documents
From the review the inspector verified the following:
--
Audits were conducted by the licensee or by a joint effort with S&W to
assess all aspect of the QA program.
--
Audits performed were in depth and addressed audit effectiveness
--
Responses to audit findings and observations were timely and adequate
__ - _- -. _ - .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _
e
s
28
--
Followup verification or re-audit was performed to verify
implementation of corrective action
--
Audits were performed as scheduled or modified according to plant
activities.
In addition to audits the QA unit performs surveillance of NDE activities
and plans to develop a surveillance program for the preoperational and
startup testing programs.
Based on the above review and discussions with QA personnel the inspector
determined that the audit program was being effectively implemented. Most
audits were not just programmatic but included field observations and
independent inspection. However, as discussed in paragraph 8.2, the
licensee has not formalized a method for assuring that all elements of the
quality program are considered or addressed in the audit schedule.
No violations were identified.
5.3.3 QC Inspection. Reinspection and Reverification
5.3.3.1
To develop an inspection program all specification and change documents
are submitted to QC engineering. Inspection plans (IPs) are developed by
QC engineering for each specification and then reviewed by the design
organization to ensure proper interpretation of requirements. Inspections
are then performed on safety related construction activities utilizing the
approved inspection attributes.
The inspector verified adequate implementation of the inspection program
by reviewing completed inspection reports generated for concrete anchor
bolts, cable terminations, welding and cable pulling activities; and
accompanying QC inspectors during inspections. In addition the inspectors
witnessed in process cable pulling activities and independently verified
safety related cable terminations. Problems were identified during the
cable pulling activities, refer to section 7.3.2.1 for detafis.
5.3.3.2
The sample reinspection and support weld reverification programs were
established by the licensee due to problems identified with the adequacy
of QC inspection. IP7.1 " Sample Reinspection" and IP 10.4 " Support Weld
Reverification" were developed to administer these programs.
Records of reinspection for 10 inspections from various disciplines were
reviewed. The inspector discussed the reinspection program with QC lead
inspectors and engineers and noted that "unsats" identified during rein-
spection are documented and evaluated to identify any adverse trends,
necessary reinspection or inspector retraining. The inspector accompanied
QC supervisior on reinspections and verified adequate implementation of
the reinspection program.
. _ _ - _ - _ _ _ _ _ _ _ - _ - _ - _ _ - - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _
!.
29
.
Inspection reports SWR-C-307 through 315 were reviewed for support
!
reverification inspections. The inspector verified through discussions
l- and direct observations that the QC inspector was aware of the inspection
l- criteria and performed a thorough inspection for each welded support.
Based on the above review and observations the NRC inspector concluded
i
that the sample reinspection and welded support reverification programs
were being effectively implemented and provided a mechanism for QC
l management to evaluate QC inspector performance,
i 5.3.4 System Release and Startup
To coordinate QC activities associated with equipment turnover and startup
i
activities the licensee has estabitshed a QC section for startup. The
, group is responsible for the turnover documentation, ensuring all appli-
l cable QC inspections have been performed and/or identified, surveillance
of some startup activities and control of reinspection for systems
released to the Startup Group. The inspector discussed the turnover pro-
cess with QC personnel and reviewed turnover package SR-15A-18, Component
Cooling Water. A random sample of drawings associated with the package
was selected and verified that documentation was available to support
Bolted Joints, QC inspections, and rework control. In addition the in-
.
!
spector physically verified the installation of hanger RK-303-MA and the
accepted attributes from QC inspection MEMR-380. Startup test procedures,
requiring lifted leads, were sampled and the inspector verified that these
leads were included in a QC tracking system for reinspection.
To date the QC Startup group has not formalized programs to provide track-
,
ing and reinspection, however the lifted leads discussed above are being
i
tracked and will be included in the formal program. Overall to this point
the QC startup group has provided an effective focal point for turnover
documentation, tracking, and scheduling of associated QC activities.
5.3.5 MeasuringandTestEquipment(M&TE), '
SQC 1.0, General Procedure for OLC/SQC calibration; SQC 5.10 Control of
Measuring and Test Equipment; FCP-410, Calibration of Crimping Tool; and
FCP-501, Control of Measuring and Test Equipment establish the program for
control of measuring and test equipment. The inspector reviewed the docu-
ments listed above and verified that the program contained the following: !
--
responsibility for control and calibration of M&TE was delineated
l
--
a calibration schedule was maintained
--
M&TE records were adequate and maintained
--
storage, labeling and issuance of M&TE were adequate t
. i
l l
t
h
'
,
'
!
-
. _ _ _ - - . _ _ _ _
o-
30
--
M&TE usage was traceable to evaluate the impact of out of
calibration equipment
--
calibration of M&TE was traceable to NBS standards, or adequate
justification was provided
--
M&TE was calibrated with standard or calibration equipment with 2 4
times the accuracy
Test equipment that was used by the crafts and QC inspectors was sampled
and the calibration and tracebility records were examined. The following
test equipment records were reviewed and the inspectors verified current
calibration on traceability of the calibration device:
--
S-26-117, clamp on ammeter
--
S-24-118, AC-DC voltmeter
--
E-43-2143, Tension Tester
--
E-25-2270, Megger
---
E-25-1488, Megger
--
E-25-1669, Megger
The inspector randomly selected the following laboratory calibration
equipment and verified <:urrent calibration and traceability to NBS
standards.
--
A-11-028 surface plate
--
A-11-026 Dead weight tester
--
A-12-029 Torque tester
--
A-11-964 & 967, Reference thermometer
--
B-16-1410, Absorption Spectrophotometer
--
B-12-25, Fluke 8000A Ditigal Multimeter
FCP - 410 controls the calibration and usage of crimping tools. Crimping
tools AY-2 and AY-59, identified on completed cable termination tickets,
were selected. The inspector witnessed sample connections made with these
tools and the pull tests for each of the connections at the SECO tool
issue station. The calibration data for the "go-no go" gauges used at the
tool issue station to calibrate the crimping tools was reviewed and found
acceptable.
- - _ _ _ - _ _ _ .
{
-
e
31
No deficiencies were identified. The SECO M&TE issues station is consi-
dered to be a strength in this project in that it provides a comprehensive
,
and effective program for the control of SEC0 measuring and test equip-
ment.
5.3.6 Corrective Actions
The Site Quality Control Trend Analysis Committee (TAC) reviews Construc-
tion Deficiency Report, Nonconformance and Disposition Reports, Inspection
Reports, and NDE Reports to determine if there are any recurrent unsatis-
factory conditions. The committee meets on a monthly basis to discuss and
evaluate the findings for each discipline. Any trends identified are
reported to the Corrective Action Committee (CAC). The CAC meets monthly
to evaluate trends, determine the cause and recommend or request correc-
tive actions. The CAC's scope is not limited to TAC trending, they
evaluate any site problem brought to their attention.
The inspector reviewed the minutes of the last 5 TAC and CAC committee
' meetings and verified that the recommendation were reviewed and acted on
accordingly by the CAC. The CAC corrective action log was reviewed and
discussed with the CAC chairman. The inspector verified that corrective
action was taken in a timely manner.
The inspector attended the March 22, 1985 TAC meeting and noted the
committee members provided reasonable evaluations for CORs and N&Ds,
including an assessment of the problems and proposed corrective actions.
Recently the licensee has taken the initiative to organize the Quality
Improvement Management Program (QIMP). QIMP will provide a management
system for reviewing and evaluating construction quality performance in-
dicators. Initially QIMP will track installation data on five commodi-
ties; large and small bore supports; terminations; seismic conduit and
supports; stainless steel instrumentation tubing and supports. The
criteria for evaluating construction quality performance will be QC
acceptance / rejection (rejection rate) of installations submitted for
inspection. These evaluations will be provided to the responsible con-
struction manager and will require corrective action.
The activities of the CAC will be incorporated in the QIMP Assessment
Panel. The inspector reviewed the first three weeks of data collected
and evaluated, and discussed the process with the QIMP coordinator.
Based on the above review of meeting minutes, records and discussion the !
inspector determined that the TAC and CAC were functioning effectively.
At the time of the inspection the QIMP was just being formalized but
should provide DLC with a strong management tool to access the quality
of construction activities.
_ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ _ - - _ _ - _ _ _ _ _ _ .
3 .s.
32
5.4 Conclusion
The QA and QC programs are well defined and adequately implemented. QA/QC
personnel are cognizant of plant activities and involved in the site Cor-
rective Action and Quality Improvement Programs. The audit program was
well controlled and conducted in an effective manner by qualified person-
nel. The audits addressed programmatic concerns, implementation and in-
cluded independent verification or observation of the work activitias.
QC is effectively administered by DLC. QC has provided additional inspec-
tion efforts in identified problem areas and performed in a manner to
ensura a high level of quality. The SECo Measuring and Test Equipment
Issues station is a strength of this site.
5.5 Program Review
5.5.1 References / Requirements
--
ANSI N45.2 - 1981, Quality Assurance Program Requirements for
Nuclear Power Plants.
--
ANSI N45.2.12, Draft 3, Revision 4 - 1974, Requirements for Auditing
of Quality Assurance Programs for Nuclear Power Plants.
--
ANSI N45.2.23 - 1978, Qualification of Quality Assurance Program
Audit Personnel for Nuclear Power Plants.
--
ANSI.N45.2.6 - 1971, Qualification of Nuclear Power Plant
Inspection, Examination and Testing Personnel
--
10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power
Plants ..."
5.5.2 Procedures
--
Duquesne Light' Company, Design and Construction Quality Assurance
Program.
--
DLC Quality Assurance Manual (procedures 1.1.1 through 18.3.2)
--
DLC Site Quality Control Manual, February 5, 1985 (sections 1, 3, 4,
6 and 7)
--
Stone & Webster (S&W) Field Construction Procedure FCP-13,
Corrective Action Program BVPS-2, Revision 2 August 29, 1984
--
Project Guidance-Quality Improvement Management Program (DRAFT)
--
Selected Inspected Plans (IPs) for re-inspection, re-verification
and surveillance
The inspector verified the above procedures conformed to the
requirements of references listed in section 5.5.1.
,
_.
.a
g
33
6. Piping and Mechanical Components
6.1 Organization
Piping, large and small bore, and mechanical components are installed by
the Schneider Power Corporation (SPC) in accordance with the requirements
of the Field Construction Procedures (FCPs) and drawings prepared and
controlled by the SPC and Stone and Webster Engineering Corporation
(SWEC). The quality control inspection of piping and mechanical equipment
is provided by Dusquene Light Company - Site Quality Control (DLC-SQC)
department in accordance with the identified inspection procedures.
6.2 Areas Inspected
The purpose of this inspection of the Primary Component Cooling Water
(CCP) system piping and components, which included motor operated, air
operated and hand control valves, and pumps, was to determine that the
piping and component installations were being performed in accordance with
FSAR commitments, design requirements, applicable codes, specifications
and procedures. This inspection included verification of the correct
location of piping and components, use on proper inspection procedures and
review of the materials utilized for this piping system. Completed work,
records of completed work including required QC inspections and work in
progress were included in the areas examined during this inspection.
6.3 Findings
The inspectors examined a portion of the CCP system; the program for
' controlling pipe and component installations;-qualification of personnel;
and selected weld records'and procedures. Interviews were held with
crafts, craft supervisors and OLC-QC inspectors.
6.3.1 Piping
The inspector performed a walkdown inspection of a portion of the
CCP system identified below to compare the current as-built condi-
tions to the design drawings and ASME Code Section III requirements.
A CCP syst'em loop was selected as a representative sample of the
safety related piping systems. The extent of the walkdown performed
was from the CCP pump "A" discharge to the RHR system heat exchanger
"A" suction and from the RHR heat exchanger "A" discharge to the CCP
pump "A" suction. The chemical addition mode, pump recirculation
mode and surge tank mode for operational make-up were included in the
above walkdown. This included the following Isometric Drawings
(IS0's):
. _ _ _ _ _ _ _ _ _ _ _
r
I
<
34
CI-410-631-2 107203-OH 110704-0G
CI-410-636-4 107206-1L 110709-0F
CI-410-626-5 107209-1G 110711-1F
CI-410-620-7 107210-1M 110712-2G
CI-410-629-3 107211-1F 109901-3H
CI-410-639-4 109905-1G 109902-2G
CI-410-637-4 110701-1G 107224-00
107225-1L 110702-3G 107223-0G
107222-1H 110703-0H
IS0's 109906-3D, 110701-1G, and 109901-3H have class 2 piping and compo-
nents which represented the inboard and outboard isolations valves and
piping at the interface of the auxiliary building and inside containment.
The inspectors performed a walk-down inspection for the above system and
examined the installed piping to verify the conformence with the SPC iso-
metric drawings, SWEC Flow Diagrams, SWEC piping engineering and design,
field fabrication and erection specifications for ASME III, Code classes 2
and 3 piping, and SPC spool drawings. The inspectors also reviewed the
design commitments in the FSAR and compared them with the output design
specifications and drawings to verify that they were consistent. Various
design parameters were selected such as pressure and temperature ratings
and these values were compared with the code plate data.
The inspectors made ovality checks at selected pipe spools and welds by
caliper measurements. The visual inspection of the piping revealed no
creases, wrinkles, flat spots or any other defects that would have been
included by improper fitup. The ovality was within specification limits
and ASME III requirements. The referenced documents and data are summar-
ized in Table 6.1 for CCP piping system parameters. The inspectors con-
curred that the installed piping was in compliance with the applicable
documents.
6.3.2 Mechanical Equipment
The inspectors performed a walkdown inspection for the piping loop of the
CCP system as identified under Sub-Section 6.3.1 and examined the in-
stallation of mechanical. equipment to verify conformance with the SWEC
flow diagrams, SPC IS0s, Vendor drawings including associated documents,
engineering specifications, and field Construction Procedures (FCPs).
The inspectors also reviewed the design commitments in the FSAR and
compared them with the output design specifications and drawings to verify
that they were consistent.
,. . _ _ _ - _ _ _ _ _ _ -
-_
?
35
The subsystems, piping isometrics, flow diagrams, specifications, vendor
data, field data, and FSAR requirements that were examined are listed in
Table 6.2.
Various design parameters were selected such as flow rates, pressure and
temperature ratings, motor HP/ rpm / voltage, pump NPSH and valve Cv values,
L/D ratios and their associated pressure drop data. These values were
compared with the nameplate data, procurement specifications and vendor
supplied documents.
The field component data were matched with the vendor and specification
data and found to be in agreement. The equipment design data and FSAR
requirements were in conformance with the vendor data.
The inspectors concurred that the installed equipment was in compliance
with their associated document, design as well as FSAR requirements.
.
l
)
No violations were identified. '
6.3.3 Specific CCP Components Inspected and Data Taken
I
The Tables 6.1 and 6.2 provide the scope of CCP walkdown inspection and
CCP equipment selected for design data review to establish conformance to
the FSAR, design documents and ASME Code requirements, as described in
paragraphs 6.3.1 and 6.3.2.
6.3.4 Independent Inspection - Piping and mechanical components other than
the CCP system.
The inspector observed work in progress and completed work in areas of the
plant and systems other than aspects of the primary component cooling
water system. The presence of component identification, preparation of
welds for inservice inspection, welders symbols, records including quali-
fication of welders, condition of plastic lined valves and control of
equipment such as pumps and valves after construction turnover to plant
maintenance /startup/ testing groups were examined. The details of certain
observations, examinations and records are summarized as below:
6.3.4.1 N&D 7446- A Q.C. hold tag was noted to be in place on the
degasifier tank nozzle shop welds. The inspector found the N&D
7446 to be readily retrievable from the records and noted that
a problem of unsatisfactory radiographic reports was evaluated
and adequately dispositioned. The records thoroughly described
the unacceptable condition and provided clear corrective action.
,
L-
. . . .. . . _ _ .. - . .
_ _ _ _ _ _ _
36
6.3.4.2 Jamesbury Valves
The SPC potential problem report of 3/6/84 stated that in evaluation of
the cause of a leak observed during pressure testing, signs of partial
melting of the teflon seat of one Jamesbury valve was noted. The caution- '
ary tag attached to each valve, option 2A, permits installation by welding
providing the temperature of 350 F at the valve center section is not
exceeded. On 3/6/84, construction craft were instructed to disassemble -
Jamesbury valves prior to installation by welding, the 2B option to
prevent seat melting.
"
On July 6,1984, Engineering Field Action Report (EFAR) number 193A was
issued, as followup to the memos of March 6, 1984, requiring the actions ]
of location, disassembly and inspection of installed VBS-015-D4 (h"-2") u
valves and certain motor operated valves for possible seat damage. The
inspector noted that SPC construction identified the valve seat problem,
provided a corrective action to prevent repetition and involved engineer-
ing for their review and statement of required action.
6.3.4.3 Tufline Valves
The installation manual and valve tag require a maximum temperature of
200 F during installation by welding to prevent damage to the valve
teflon / polyethylene liner components. The inspectors reviewed documenta-
tion of the installation, observed disassembly / reassembly and inspected
the valve internals of the valves 110 and 112 on ISO 410-234. The valve
number was 2 "VPW-015-AW-3 installed in conformance with the vendor's
manual No. 2506-380-091-001D. No internal damage was observed.
6.3.4.4 Post Construction Equipment Control and Storage
The specification 2 BVS-981 defines the requirements and interval for
visual checking for conditions of storage and maintenance of permanent
plant equipment during the construction phase. This specification is
referenced and is a part of the plant start-up manual chapters 4.2 and
5.4. These chapters detail the scheduled maintenance / calibration program
and post construction turnover " superintendence" respectively of plant
equipment while in the testing, start-up and preoperational stages. The
inspectors observed construction activity and startup test activity in- =
cluding control of equipment to be occurring in the same areas simulta- t
neously. Those components or equipment under control of construction were
$f
noted to be in conformance to specification 2BVS-981. Three components, i
2CCP*TCV100C, 2CCP*MOV-150 and MOV-SIS *842, under control of the plant g
maintenance or startup-test group were observed to be partially uncovered $,
and not totasly protected from construction activity as testing was in
progress or recently completed. Although no damage was observed to {f l i
these components, the plant maintenance and startup groups were inter- i
viewed to determine how components would be controlled after turnover by j
SPC/SWEC construction. At the time of this inspection, control including ,
scheduled maintenance was baing performed by the plant maintenance section i
,
!h
I h
1
&
- b
. .
.. . .
_ _ _ _ _ _ _ _ _ _ _ _
.
37
in accordance with the startup manual chapter 4.2. The startup and main-
tenance groups had recognized the possible problems of having construction
and startup test activity occurring in the same areas and provided for
control through startup manual chapter 5.4 which defines the System
Operation Verification (SOV) test section system engineer as the indivi-
dual responsible for controlling periodic observation and activity
designed to ensure trouble-free operation of inactive permanent plant j
equipment (superintendence). The startup manual' chapter 5.4 was scheduled
for implementation on 3/29/85. The inspector concluded that the program
for post construction equipment control and storage as presented in
chapters 4.2 and 5.4 of the startup manual and supporting references such
as 2BVS 981 would provide a programmed basis for effective superintendence
of equipment.
No violations were identified.
6.3.4.5- Qualification Records of Welders
A sample' of welder qualification records primarily from the CCP system
welds were reviewed for comparison to the ASME Code Section IX or AWS
D1.1 welder qualification requirements. Records for-the following welders
were reviewed:
F045 F232 F485
F076 F287 F524 !
i
F104 F291 F704
F130 F251 F848 (Instrument Tube)
F152 F341 F970 (Instrument Tube)
F213 F484 I-95 (AWS D 1.1)
No violations were identified.
6.3.4.6 Work in Progress
Work activity in progress on pipe hangers, piping and other mechanical
components was observed. Hilti bolt measurements, welding, heat treat-
i
ment, work station records, weld materials in use, instrument tube bending
and related activities or conditions were observed. These were compared
to the applicable ASME code, engineering specifications, procedures or
contractor isometric requirements. The following were included in the
sample of work in progress inspected:
t.. -. . . . . . . . . . . . ..
. .. .
..
.. .
_ _ _ _
'
.
38
-- 2 MSS-032-35-2 Weld 2 MSS-035-F03 Preheat and Welding.
-- RCS-108-28 150-110909-3 RCS 242-2 Valve to Gate Valve.
-- Pressurizer top head, nozzles to piping - welds and welding in
progress.
-- RHR pump, heat exchanger and associated piping in
proximity.
-- 2FWS-016-22-2 Welds 2FWS-022-F501/F07 Weld root
tacking and preheat.
-- 2 DGS-PSA-030R ISO 410785-110-001 REV 2 - Pipe
hanger.
-- GWS-PSR-394R ISO 410515-089-012 REV 1 - Hilti.
-- 2 CHS-500-364-2 ISO 108306 - Welding.
-- 1 CHS-003-300-3 ISO 108335-003-300-3 - Valves and
welds.
-- 2 CHS-003-10-3 ISO 108334 - Welding (2CHS-010-F801).
-- Category II instrument tube bending station.
-- Instrument tubing - CI-410-320-1, tube bend diameter
control.
-- 2 CHS-21A and 218 at 755' elevation-tank and attached
piping.
-- 2 RCS-004-173-1 Weld 2RCS-173-F502 - welding.
-- Line 2 SIS-002-107-2 weld SA, Pce 3 to 7 - weld repair. .
-- Line 2CCP-006-57-3 weld 2CCP-057-F505, ISO 11820-
welding.
-- Neutron shield expansion tank at elevation 750'.
-- Corrosion control tank at elevation 750'.
-- Incore instrumentation sump pump - stud welding
for mounting (DWG 10080 RV).
l
- _.
.-
p-
39
-- 2RHS-HCV 758A-SN N141141-3914 - storage of valve to
pipe assembly.
-- 2RCS-PSR-041, DWG-BZ109A-35-2B and E&DCR 2PA-8090,
hanger.
- -2WSS-410-233--003,- Weld FW6.
- 2CHS-FT 122 HP&LP Uelds 35/36/37/38 - instrument tubing.
-- Weld 2 MSS-043-F03, ISO 100211/2B - Heat treatment.
-- Weld 2FWS-012-F10, ISO 101702-6C - Heat treatment.
No violations, deviations or failures to follow appropriate procedures
were observed.
6.3.4.7 Proximity of Pipe Supports
The inspector noted that the supp' orts 2CCP-PSSH-326 (spring hanger) and
2CCP-PSSP-316 (snubber) at discharge side of pump 2CCP*P21A, on line
2CCP-020-463-3 were separated, center line to center line, by.1' -3 3/8".
The' inspector discussed the identified closeness of supports with the
SWEC - Boston and onsite personnel to clarify the issue. It was concluded
that the support 2CCP-PSSH-326 was required to support the dead weight of
the valves 2CCP*V8 (20" check valve - 400 lbs) and valve 2CCP*V11 (20"
butterfly valve - 1147 lbs.). The lateral support 2CCP-PSSP-316 (snubber)
was required for seismic loading which has nothing to do with the carrying
of dead weight of the valves and corresponding flooded piping weight. The
SWEC calculation No. 12241-1VPN-X72F, R.0 was reviewed to verify the per-
formed stress analysis on the piping system covering the discharge side of
the pump including the above identified valves. The stress analysis
justified the need of a support 2CCP-PSSH-326, however,- it increased the
nozzle loading on the pump nozzle by 25% more than the vendor recommended
value. SWEC has requested Ingersoll Rand the pump vendor, to provide
their response to the increased nozzle loads. SWEC has formed a Stress
Reconciliation Program for the increased vendor allowable nozzle loading
for all pumps at BVPS-2, which also includes the identified pump. SWEC
and_0LC are tracking the identified program and once the stress reconci-
liation is performed, on a case by case basis, the support system design
will be updated, as required.
No violations were identified.
6.3.4.8-. N5 Data Report Form
The ASME Code Section III, paragraph NA-1210 requires that the installer. ,
of'ASME components complete the Data Report Form N-5 which serves to in-
dicate that each component or associated appurtenances assembled into the
nuclear power plant and the installation meet the requirements of ASME
L
-
.
40
Section III. The inspector reviewed the following, discussed the N5
program with site personnel and examined records and documentation in
progress:
-- Letter dated 3/21/85, P. Ray Sircar to A. C. McIntyre
(SWEC).
--
2BVM-231 Review and certification of the Schneider Power
Corporation generated N-5 data reports
by SWEC.
-- FCP 211 N-5 data report and certification system.
-- N-5 Program Generic Schedule, Rev. 1, dated
1/25/85.
-- Documentation program status report, dated
March 7, 1985.
-- Computer report printouts of N5 data report attributes
by ISO number and N5 systems for specific CCP
components.
The computer reports reviewed provide for the status of the relevant
attributes to determine that code requirements have been met and that
components have been both installed and inspected to the latest engineer-
ing/ installation drawings. The computer report format is comprehensive in
that almost 100 attributes may be tracked with 35 data points showing on
those reports reviewed . In related inspection activities, it was deter-
mined that welding and bolting data sheets, material test reports and
other records for specific pieces of equipment did exist, were readily
retrievable and had been reviewed or were scheduled for review.
Where a problem is identified in review of documentation, the problem is
described and tracked until resolved. For example in review of the vendor
documentation, one material bend test was noted to have not been reported
by the material supplier. This condition was shown on N&D 7963 which
provided for engineering review, evaluation and disposition. The inspec-
tor noted that as part of the disposition to N&D 7963, that the base line
FSAR document, BVM-179 and the subject pump specification BVS-010 would be
revised. Also, vendor recertification per the ASME 1974 code addenda, for
seal gland plate would be obtained.
No violations were identified.
On the CCP system, the inspector noted that the pipe support number
PSSP-929 was not in place. The N5 system data base computer printout was
reviewed for this specific support. The printout did indicate the support
was not in place. Subsequent steps in preparation of the N5 data sheet
for this component were on hold pending installation of the support and
inspection.
I
_ _ _ _ _ _ _ _ .
o
3
41
The inspector concluded that SWEC and Schneider have provided for and have
in place a systematic program to control and establish completion of ASME
requirements that will be summarized by the N5 data report documentation.
No violations were identified.
The SWEC N5 Data Report program that assures that components meet the
requirement of ASME Section III is considered to be a strength
at this project.
6.4 Conclusions
Piping Based on the review of procedures, observation of ongoing work
including welding, walkdown of portions of the plant piping and detailed
examination of the Primary Component Cooling Water system, examination of
specific welds and records, evaluation of weld filler metal control and 3
j
review of selected weld data sheets, the inspector concluded that the site {
installation and welding function is under control by site supervision and
management utilizing a core of competent, qualified craftsmen. The
inspection functions of licensee site QC including NDE are in evidence as
is overcheck of the system by QA.
Mechanical Equipment The licensee has complied with the appropriate
specifications, FSAR, committed standards and codes, and regulatory
requirements for the installed equipment.
Other Inspected Areas Independent inspections were conducted of selected l
components, activities and topics not specifically covered in the CCP 1
system. N&D's, plastic lined valves, post construction equipment control
and storage, qualification records of welders, work in progress, expen-
dable products, proximity of pipe supports and preparations to complete
ASME code N5 data reports were examined.
The N5 data report generation and control system is considered to be
a strength of the project. A strong program has been established and
is being implemented effectively. Management is actively involved.
6.5 Documents Reviewed
-- BVPS-2 FSAR, sections 3.2, 3.983.4, 3.9N.3.2 and 9.2.2.1
-- FCP-211, N-5 data report and certification system
-- 2BVM-231, review and certification of the SPC generated N-5 data
reports by SWEC
-- ASME documentation program, February 1985
-- FCP-5.1, requirements for establishing and maintaining
cleanness zones
-- 2BVS-920, Field fabrication and erection of piping; ASME section
III, classes 1, 2 and 3 and ANSI B31.1, CL.4
, . . .
. . .
-
,
-
p e.
,
-
.
+
42
~~
- '
-- FCP-208', control of fab'rication and installation processes for
piping systems
- -- IP-7.2,EASME section III and VIII welding
,
--- 2BVM-163, licensing commitment / design criteria correlation, for
-
FSAR section 9.2.2
-
- --12BVS-981,' storage'ofmaintenanceduringstorageofpermanent
- plant' equipment.during the construction phase
-- DLC.startup manual, chapter 5.4 post turnover superintendence
'
' - DLC startup manual, chapter 4.2.- schedule
l maintenance / calibration program
--- N&D 7446 andlDLC - radiographic ' interpretation _ report 2BVM-114,
'
" essential systems, components, and instrumentation required for
-safety functions. -- 2BVM-81, tabulation of S&W mark numbers for
'
, valves, steam traps, and. strainers-
- 2BVM-12', instructions for preparation of flow diagrams
idiagrams-
+ --jN&Ds. 7495, 7184, 7184A,-7448, 7599, 7603, 7440A and 7963
'
-- ERDCRs 4381, 3396, 3717, 5034, 5049, 5050
--lSPC's ECNs - 1778, 2564,'1947, 1978, 1745, 1797, 2618, 1230,
1015, 2508, 2578, 2801, and 2805
-- FCP-302, removal or disassembly / reassembly of permanent plant
'
equipment
-- EDM-83-116, SPC change control and reporting system
- Tufline maintenance and repair instructions for 1" thru 4"
plug valves
-- SPC - ASME. weld data sheets
-- SPC - Bolted joint data sheets
-- NPV-1-forms'for CCP system equipment
-- BVPS-2,-stress analysis data package for SI-RM-77A-1
'
-- SPC IS0s: 109905, 110701/2/3/4/, 110709 through 110711, 109901'
.and 2, 107223~thru 107225, 107206,:110756', 110743,-109907 and 8,
107217,-107214, 110-683, 410-701
-- SPC spool' packages: 1141 - 2628, 2629 2625, 3159, 3160 2782,
3441,~3474,'3476, 3477, 3478,.3480, 3481, 3482, and 3486'
-- SWEC flow diagrams RM-77A and 77B
' -- Vendor drawings, SWEC ' file nos: 2007.630.209.092C,
2006.390.069.048C and 044G, 2006.390.069.065A,'.2006.435.022.004B,
- 2006.450.076.0038, 2006.450.076.0658,-~2006.450.076A.071E,
2002.260.010.001F, 2003.230.054.001F, 2004.110.012.001G,
2006.310.073.021F, 2006.510.073.0310, 2006.320.064.028E,
. 2006.320.064.0300, 2006.390.069.045C, 2006.390.069.047E,
~
and 2007.630.651.050A.
~ 7 .' Electrical / Instrumentation Construction
,
- 7.110rganization
'
.-Duquesne Light Power Company has delegated responsibility for design
-control during the engineering and construction phase to Stone and Webster
Engineering Corporation. -Duquesne Light, however, does conduct engineer-
ing reviews on a selective basis of the design of certain components,
l'
,
.
r ._
=
.,.
,
43
systems and structures. Similar reviews are conducted of significant
design changes which: occur during construction. Installation of
electrical component s/ systems is done by Sargent Electric Company under
contract to the Stone and Webster Engineering Corporation. Installation
of instrumentation systems,. components and tubing is done by the Schneider
Power Corporation, also, under contract to Stone and Webster Engineering
Corporation. The Quality Control function is performed by the Site
Quality Control (SQC) Group under the direction of the Duquesne Light
Power Company.
-7. 2 Areas Inspected
The objective of this portion of the inspection was to evaluate the ade-
quacy of the control of the design and installation of the electrical /-
instrumentation components / system pertaining to the safety-related
sections of the component cooling water system. The team examined the
degree of conformance to the FSAR, Regulatory Guides, Criteria, Standards,
and design input from other disciplines with emphasis on the handling and
control of interface information from these disciplines. The team also
reviewed the responsibilities of the organizations involved in the
Electrical / Instrumentation design and installation process, and various
applicable project, administrative and general engineering design proce-
dures.
7.3 Findings
7.3.1 Documentation
The team examined procurement documents, Material Certifications, speci-
fications and receipt inspection reports for selected materials and compo-
nents of the component cooling water system. Components selected for the
quality assurance document review consisted of the following:
-- Primary Component Cooling Water Pump Nos. 2CCP*P21A, B, and C
-- 16" differential control valve Nos. 2CCP*DCV 101A, B,
and C
-- 1 " - 150# 1evel control valve Nos. 2CCP*CCV100A, B and C
-- Pressure Differential Transmitter Nos. 2CCP*PT150A,
~B and C and 2CCP*PT107A, B and C
-- Pressure Differential Transmitter Nos. 2CCP*DT100-1
and 2
-- Level Transmitter Nos. 2CCP*LT100A and B
-- Flow Transmitter Nos. 2CCP*FT117Al and B1
7.3.1.1 Quality Assurance documents reviewed for the above components
include:
-- Receiving Inspections Reports (RIR) Nos. RIR-E4-5725,
E-4-5732, P-3-6990s, P-3-649, P-3-7903-S
-- Purchase Order Nos. 2BV-648A, 2BV-10, 2BV-648A-32,
,
m
.- , . .. -. .. . . . . . - ~
. :
t
~44
,
.
-- Material' Receiving Report (MRR) Nos. II83-5052,
'
s
II83-1575, II84-4163 and II84-3940
'
J-- Certificate of Conformance No. 354, dated
- January 6,1983 :for 16" level control valve
-
-- Inspection . Report'. (IR) No. IR-0036 for:2BV-10
-- Nonconformance and Disposition Report (N&D) No. 7963 pertaining to'
'
1
lack.of Seal Gland Bend Test Data for Component Cooling Pumps ,
-- Certified-Test Report for Heat Treat No. 802L80720
-- Seismic Test Report No. 17567-82N for 16 inch Butterfly Level
Control Valves.
.
,
-7.3.1.2
'
In reviewing the above_ documents, the inspector noted several deficiencies
-attributable ~to lack of attention to detail on the part of licensee per-
- '
sonnel in complying with licensee project administrative procedures and
procurement specifications.
,
-
-The, inspectors' identified the'following examples:
E
a)- Engineering documents in the Document Review Group were found with
- " corrections and deletions that were not made in.accordance with.
.
'
established procedures in that they were not properly initialed and
.or dated.
, .
. .
.
Section 4 of Procedure 2BVSM-83 requires thatLcorrections/-
errors, changes / additions be crossed with a line and initialed ,
and dated by the person making the notation. i
'
'
b) LSupplier documents (SDDF) were not annotated to show "NOT" in the -!
' returned to vendor block.
.
,
Section-F12, pg. 5-29 of Procedure 2BVSM-202 allows'the addition ofL
-
"the word "NOT"_on the SDDF form.- However, there is no requirement to
,
,
initial or date the notation. This is contrary to management inter-
office memo _(2BVSW-60874-CRB/M) of September 23, 1985 which does not
allow changes / additions without the. initial and date of the person
'
.
making the notation.
Corrections and deletions were made by QC personnel on vendor docu-
~
c).
mentation without initial or date by _ person making notation -(re:
requirement per item a)
- d) Vendor-test report accepted'with vendor Professional Engineer'(PE)'
statement that-test results " appear to conform to seismic require-
ment." . Procurement-Specification 2BVS-636, pg 2-6 line 38-43
requires that: _ " seller submit a certificate of compliance which will _
-
be-stamped-and signed by a Registered PE with the statement'that he
.has;seen and revicwed the adequacy of the method for establishing
'
that the seismic design requirements have been met."
,
i
+
4h11 ,-M' --- -c- t3-,,. ,#a,, A,,,3 %. a-, , c w m w y.y v m,-- .--w,_,g-y yi , -,. ,,,yyng.,--y,,-n,me -,w.g-~ , , - , -. , . - . - , - .., yyy.,. - .w..,,., , . -
__ .__
.
45
e) Certification of two QC inspectors by an individual designated in
writing by the Director, QC to perform the administrative duties of
the. Assistant Director, QC during a 30 day vacation absence of the
' Assistant Director.
Section 4.3.of Procedure TP-2 for Qualification and Certification
states; "the Director or Assistant Director /QC shall certify inspec-
tion / testing personnel by his signature."
The Procedure does not permit a designee or alternate.
f) Responsible Engineer approval stamp used on SDDF documents without
initial and date of person authorized to use the stamp. Section
5.2.6.f of Procedure 2BVM-202 requires Responsible Engineer using
stamp to initial and date use of stamp on engineering documents.
7.3.1.3
Prior to. leaving the site, the licensee had taken specific action to
address the above deficiencies as follows:
--
'The site project manager issued a memorandum, dated March 26, 1985 to
project peesonnel reiterating requirements for document correction /-
- deletions.
--
The licensee revised Procedure 2BVM-202 to require annotation of
"NOT" in the-return to vendor block of the SDDF form.
--
_The Director, QC will clearly define responsiblities of
designatec alternates.
7.3.1.4
The implementation'of the above licensee actions and the results will
-be reviewed in subsequent inspections, however, because of the number
of deficiencies identified the licensee is in violation of 10 CFR 50,
Appendix B, Criterion V, which states, in part, that: " Activities
affecting quality shall be prescribed by documented instructions,
procedures ..... and shall be accomplished in accordance with these
instructions, procedures ...." (50-412/85-07-04)
7.3.2. Electrical
The inspectors observed work performance, partially completed work and
completed work on selected cables, raceways and terminations to determine
whether the requirements of applicable specifications, work procedures and
inspection procedures are being accomplished in accordance with NRC
requirements and licensee commitments. Particular attention was given to
items in the component cooling water system. However, observations were
not limited to this system.
...
_.
46
Specifically, the inspector reviewed the safety-related electrical speci-
fications, witnessed in process cable pulling, verified cable termina-
tions, observed the use and calibration of Measuring and Test Equipment,
and assured that the M&TE recorded on the documentation was traceable back
to the site calibration facility.
7.3.2.1 Electrical Cable Pulling
The inspector reviewed the documents listed against the FSAR criteria
and for consistency with the applicable lower tier documents:
--- 2BVS-931, Specification for Electrical Installation,
--- Field Construction Procedure (FCP) 431, Cable Pulling, and
--- Inspection Procedure (IP) 8.4.1, Inspection for Cable Pulling.
On March 22, 1985 the inspectors witnessed the beginning of a bulk cable
pull consisting of twenty three (23) different size cables. These cables
were being pulled from their respective reels at elevation 730' in the
service-building to elevation 745' in preparation for final pulling to the
Safeguards area. DLC Site Quality Control was present prior to pulling in
accordance with FCP-431.
While pulling the cables off the reels the inspector observed that several
of the cables were' damaged after reaching elevation 745'. Specifically,
SQC _noted that Seven (7) cables were kinked and one (1) had three (3)
longitudinal cuts in it. The cables affected were:
2HCSAOC606
2QSSAOC003
2QSSAOC801
2QSSB0C801
2RSSAOC002
2RSSAOC011
2RSSC0C010
2CESC0C010
On the same date the Site Engineering Group (SEG) was notified of the
discrepancies being noted by SQC and began taking corrective action.
-
After approximately one and one half hours, the Sargent Electric Company
foreman decided to discontinue the pull because of the numerous problems
that SQC was identifying on their cable pull inspection attribute sheets.
On March 25, 1985 the cable pull had resumed prior to the issuance and
written dispositioning of Nonconformance and Disposition Report (N&D)
number 15993 generated on March 25, 1985 and validated by SQC, March 26,
1985. Continuation of the pull resulted in violation of Site Qualilty
Control Manual procedure 4.4 titled "Nonconformance and Disposition
Reports", paragraph 5.3.3, page 7, which states, " Work on a particular
-
activity shall be discontinued upon the issuance of an N&D if continued
. _.
,
47
work could cause damage, prevent further inspections, or prevent remedial
action". This activity is in violation of 10 CFR 50, Appendix B,
Criterion V, which states in part that " Activities affecting quality
shall be prescribed by documented instructions, procedures .... and shall
be accomplished in accordance with these instructions, procedures ...".
(50-412/85-07-05)
7.3.2.2 Minimum Bend Radius of Cables
The inspector observed that cables 2FPWA0K600 and 2FPWA0K601 located in
junction box 2JB*5012 were in violation of their minimum bend radius
requirement. This was confirmd by the Licensee's SQC engineer by direct
measurement of the two orange channel power cables. The SQC Inspection
Plan on Cable Pulling, IP-8.4.1, attachment 3.9, lists the cable manufac-
tures minimum bend radius criteria for this type of cable (NKZ-10) as 2.1
inches. The measured value was between 0.9 inches and 1.0 inch. The
SQC organization generated N&D 15969 identifying the nonconforming condi-
tions and in addition revised the cable pulling Inspection Plan IP-8.4.1,
inspection attribute E540, to inc1 Ae an additional statement:
"While witnessing cable pull inside e: closures, the Inspector shall verify
that previously installed coales, if retrained during the pulling process,
meet the minimum bend radius criteria specified for the applicable cable
mark number."
The inspector, accompanied by the Licensee's SQC Lead Cable pulling
inspector, selected three (3) additional junction boxes to determine if
additional cable bend radius problems existed. The inspector had the
covers removed and verified that in 2JB*5046, 2JB*8815, and 2JB*8817 there
were no minimum bend radius violations present.
The inspector observed an additional instance of a minimum bend radius
violation in the Safeguard building at elevation 718'. Cable 2SISBPH301
which feeds the safety injection pump 2 SIS *P21B from the 4160 Volt switch-
gear 4KVS*2DF was coiled and hanging from overhead by a rope. The contact
point of the rope created the minimum bend radius violation. DLC SQC
verified the violation and issued N&D 16014. The specified minimum bend
radius for this cable (NKB-09) is Eleven (11) inches. However, the actual
radius measured was between nine (9) and ten (10) inches. The above
mentioned minimum bend radius violations is contrary to 2BVS-931, section
3.2.1.14 which states, "The minimum bending radii shall not be less than
the bending radius given in cable specifications for each cable". This
activity is in violation of 10 CFR 50, Appendix B, Criterion V, which
states in part that " Activities affecting quality shall be prescribed by
documented instructions, procedures . nd shall be accomplished in
accordance with these instructions, pr 2dures ..." (50-412/85-07-06)
. . ._.
.
~
ne
'*
b >
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48
,
- 7.3.2.3 . Electrical' Cable Terminations
'
lThe . inspector verified the licensee's cable termination inspection program
by inspecting twenty six (26) cables in the CCP system to assure correct
termination. The cables verified and identified as complete by SQC are
- tabulated below:
ORANGE TRAIN CABLES PURPLE TRAIN CABLES
2CCPA0C300 2CCPBPC300
2CCPAOC305 2CCPBPC301
2CCPA0C801 2CCPBPC801
2CCPC0C300 2CCPCPC300
2CCPC0C305 2CCPCPC304
2CCPC0C801 2CCPCPC801
2CCPACC307 2CCPBPC306
2CCPC0C306 2CCPCPC306
2CCPN0C022 2CCPNPC022
I 2CCPNOC032 2CCPNPC032
L- 2CCPAOC390 2CCPBPC303
.
2CCPAOC304 2CCPBPC305
2CCPA0H301 2CCPBPH301
The inspector verified the following:
I
---
Cables were trairrd properly
Wiring diagrams consistent with actual termination
'
--
i , points
f ---
Cable minimum bend radius was not exceeded
m.
F.
..
is
f
49
!-
!
---
Termination ticket included crimping tool and megger
M&TE number.
---
Proper connecting hardware
No problems were identified with the terminations except the following:
While verifying the 4160 volt power cable terminations for cables
r
2CCPA0H301 and 2CCPBPH301, which feed the Component Cooling Water pumps A
and B, the inspector questioned the requirements for bolted connections
when terminating to the load side of the circuit breaker stabs. There
<
exists inconsistencies between the electrical installation specification
2BVS-931, the cable terminating field construction procedure FCP-432, the
inspection procedure IP 8.5.2, and the Sargent Electric Company. drawing
concerning the tightening of hardware in making up these medium voltage
terminations.
Specifically, 2BVS-931, section 3, page 43 gives torque values as a guide
for medium voltage terminations. In addition, the specification states
"Where lock washers or belleville washers are used, bolt shall be torqued
until washers become flat". FCP-432, section 6.5.7, page 12 states " Lock
washers and Belleville washers shall be torqued until the washers become
flat". In addition, section 6.5.7.1 states "When lock-washer or Belle-
ville washer is not visible at time of installation, bolts shall be
torqued to values shown on attachment 3.5". This attachment in FCP-432
states the same requirements as the specification.
The SQC inspection plan IP-8.5.2, section 6.5.2, page 14 states " Verify
that the hardware used is in accordance with attachment 3.9." This
attachment states only that for joint tightness " Lock /Belleville washers
are flattened".
Sargent Electric Company drawing " Wire and Cable Termination Details" No.
1.2.3.4.A6, revision 27, Note 1, states, "If Belleville or lock washers
are used, tighten only until flat, do not torque." However, note 10,
states, "Make sure all screws and bolts are tight. See recommended torque
chart. Do not overtighten."
The inspector had discussions with the licensee and S&W Engineering
concerning the above inconsistencies in the documents mentioned. The
licensee stated that they would revise the documents and remove the
inconsistencies.
This item is considered unresolved pending licensee review of these
documents for ambiguities and making any needed changes in these
documents and pending NRC review and evaluation. (50-412/85-07-07)
p
, .
50
,
7.3.2.4 Cable Sidewall Pressure
The inspector reviewed the requirements for calculating the maximum
-allowable pull tension in the documents listed below:
--- 2BVS-931, Specification for Electrical Installation
---
FCP-431, Field Construction procedure for Cable
Pulling
---
IP-8.4.1, Inspection for Cable Pulling
The inspector discussed with the licensee and S&W representatives how
i- cable sicewall pressure was factored into cable pulling calculations
prior to cable pulls. The Licensee and S&W representatives responded
that all cable pull calculations were done in accordance with the
above procedures prior to the pull. The licensee could not show how, side
wall pressure is considered when these calculations are performed.
The cable pull ticket, which has the maximum allowable pull tension, is
stamped on the ticket for a particular type of cable and used in the
calculatio.n. The inspector then asked the licensee and S&W representa-
tives if sidewall pressure is factored into this value on the pull ticket.
During the inspection, after awaiting three (3) days the A/E did not sat-
isfactorily provide the inspector with sufficient information to determine
if sidewall pressure is considered when the maximum allowable pull
tension value is given on the cable pull ticket.
I
_
Following the inspection, Region I pursued this issue in phone calls with
! the licensee on April 25 and 30, 1985 and in a meeting with the licensee
at the NRC Region I office on Tuesday May 7, 1985. It was determined that
sidewall pressure was factored into the cable pull calculations. An in-
direct method was used consisting of limits on the maximum pulling length.
While the licensee could not retrieve the original 1980 records document-
p~ ing this method, the engineer who developed the method reconstructed the
method. This method could not be shown to be conservative with regard to
'
sidewall pressure in all cases. As a result Stone and Webster proposed
replacement of the old method with a more rigorous calculational method
that explicitly considers side wall pressure limits. It is a more
conservative method than the original method with side wall pressure
l limits more easily demonstrated.
! -The new method was applied to 5064 Class IE cable installations at
the site with the result that for 99 percent of the cables reviewed, it
- could be shown that conductor strength and sidewall pressure limits are
- not exceeded. Acceptability of the remaining 30 cables could not be
l' readily shown using the new method with its conservatisms. Additional
j refined analysis is ongoing. The licensee anticipates that most of these
L
remaining cables can be shown to be acceptable.
$
l
,
,
51
However, for a small number of cables they anticipate they may have some
difficulty in establishing cable pull acceptability. As a result the
licensee has requested cable testing from a cable vendor to provide addi-
tional data on cable limits.
The licensee plans to include the new method as an appendix to the Elec-
trical Installation Specification, 2BVS-931 in the near future. In the
interim most pending cable pulls have been shown to be acceptable by the
new calculational method. Furthermore, they have imposed a hold on
pulling of any unpulled cables in the 30 cables that have not been shown
to be acceptable.
Pending reso'ution of the acceptability of the installed cables and
acceptaoility and incorporation of the new method in station procedures
and specifications this issue is unresolved (50-412/85-07-08).
The licensee's inability to retrieve the documents showing how cable
sidewall pressure was factored into cable pulling calculations is a
violation of 10 CFR 50, Appendix B, Criterion XVII, which states in part
that " sufficient records shall be maintained to furnish evidence of
activities affecting quality .... Records shall be identifiable and ,
retrievable" (50-412/85-07-09).
7.3.2.5 Switchboard Wire Traceability
During the termination inspection with the licensee's SQC, the inspector
found several reels of orange, purple, green, and grey standard SIS
switchboard wire outside the control room. An indepth look at the wire
itself revealed that only the grey wire had the vendors name, wire type,
voltage rating, grade, and gauge marked on the insulation of the wire,
e.g; wire #14 AWG Rockbestos G Firewall Type SIS 600V (UL) Nuclear.
The reels of the SIS wire were properly identified and traceable back to
the Pre-Engineered Material specification which states the procurement
requirements. However, the inspectors concern was once the unmarked
orange, purple, and green wire left their respective reels, one could not
determine what type of wire it was because of the absence of marking. The
inspector asked the licensee and S&W representatives if they had ever
questioned the vendor as to why they did not mark the colored wire. The
licensee replied that they had called the vendor about this concern,
however, the vendor could not give them an answer.
The inspector then verified that the only vendor presently supplying
the project with SIS wire is Rockbestos. The inspector raised the
concern to the licensee as to procurement of SIS wire in the future
from an unqualified vendor in that traceability may not be maintained
and what precautions the licensee would take to assure that this
would not occur.
. 1
.;
i,
52
This is an unresolved Item pending NRC review and evaluation of licensee
- controls to assure traceability of SIS wire procured from other vendors
in the future. -(50-412/85-07-10)
7.3;2.6 Damaged Cable
During the course of this inspection the inspector identified multiple
cable damage in cable raceway no. 2TC138P, located in the Control Building
at elevation 725'-6", at the intersection of the cable vault and the Main
Steam _ Vault. Cables exiting the raceway at support no. QC93 were in
contact with the sharp edge of a raceway siderail causing an indentation
in the cable cover to 50% of its thickness.
Failure to protect cable against mechanical damage is a violation of
licensee specification 2BVS-931 pg 3-35 lines 8 & 9 which states, in part:
"that all cable installed in trays shall be protected.against mechanical
.... damage." This item is a violation of 10 CFR 50, Appendix B,
Criterion V_which states, in part, that " Activities affecting quality
shall be prescribed by documented instruction .... and shall be accom-
.plished in accordance with those instruction ...." -(50-412/85-07-11)
7.3.3 Instrumentation
7.3.3.1 Component Cooling Water System Observations
The inspector observed work performance, completed work and partially
completed work pertaining to the installation of safety related instru-
mentation and control systems associated with the Component Cooling Water
System. .The objectives was to determine whether the instrumentation and
control systems were in conformance with established procedures, NRC
requirements and licensee commitments in the areas of routing, slope,
supports, instrument type, range, separation of redundant system and
inspection.
Instrumentation and Control Systems selected for examination include:
--
Electronic Differential Pressure Transmitter Nos. 2CCP*PT150A,-B
and C; 2CCP*DT 100-1 and 2, associated instrument lines and
supports.
--
Level Transmitter Nos. 2CCP*LT104A3 and 2CCP*LT100A and B,
associated instrument lines and supports.
--
Flow transmitter nos. 2CCP*FT107A and B, associated instrument
lines and supports.
--
Drawing Nos. RK-303-E, RK-303CW-1, RK-303-J-1 and 2, RK-303-H-1
i
.
c
b? .
53
iSing1e Ifne drawings were used to walkdown each system verifying routing,
- slope,- support-location and anchor type for each system.
No violations were identified.
7.3.3.2: Instrument Tubin'g Marking Pens
'During observation of seismic Category II, non nuclear safety (NNS)
. instrument tube bending, the inspector noted the tube bend operator to be
marking the tube.with an unapproved marker. The marking pen in use was
-not.shown on.the expendable products approved 11st for materials that
contact' metallic' surfaces (Specification 2BVS-901).
Immediate action was.taken by SWEC construction to stop the use of
unauthorizedLpens. . Corrective actions included revised instructions to
the craft personnel and issuance of memorandums to appropriate site per -
sonnel.by_the SWEC site project manager. This re-emphasized requirements
for proper pipe-marking devices and prohibitions against use of other
materials which could adversely affs.ct plant components. Q.C. issued N&D
19539;for engineering evaluation of the situation.
The NRC inspector reviewed specification 2BVS 901, the FSAR part 3.2.and-
the memo dated December 4, 1984 by H. Krafft (SWEC) which states that..
' expendable products such as inks are nonpermanent and are to be removed-
-after-use. The inspectors observed installed Category I and II tubing.in
the field and noted that expendable products including marking inks'were
generally removed from Category I instrument . tubing but not removed _ from
' Category II tubing. This is an unresolved item pending NRC review of the
~
disposition to N&D 19539 and the program controlling removal of expendable
products from metallic surfaces wherever removal is required.
- (50-412/85-07-12)
7.4 Conclusions
Electrical
.Imnlementation of electrical construction activities is generally
acceptable. LConstruction supervision, craft and QC personnel are
generally knowledgeable of good construction practices.
Two' problem areas were identified. The first problem area was related to-
~
a. previous problem in the area of engineering / construction interfaces.
~
As discussed in Section 4.3, the licensee has made generally good progress
1towards correcting this problem, particularly in the mechanical area.
However, in the electrical area there are indications that the interface
'between engineering and construction include a few lingering problems.
These' include the interface difficulty between engineering / construction /QC
that lead to the cable pull violation and the difficulties involved in
establishing if sidewall pressure was satisfactorily considered in cable
pull calculations. The' cable sidewall issue also led to a violation. A
m
.
~
..
54
related difficulty was that of establishing torquing requirements for
bolted connections when terminating 4160 volt power cables to the load
side of the circuit breaker stabs. The engineering / construction interface in
the electrical area is a weakness (50-412/85-07-13) and warrants further
attention.
The second problem relates to several cable installation deficiencies.
This included several examples of failure to maintain bend radius
requirements and multi-cable damage to cable covers resulting from cable
contact with the sharp edge of a raceway siderail. Both of these
deficiencies resulted in a violation. However, they appear to be
isolated events.
Instrumentation
The licensee appeared to be knowledgeable of site activities.
Documentation and records were current, signed by authorized personnel
and ledgeable.
Fabrication and construction of the component cooling water system
instrumentation and controls conforms to the construction drawings.
Documentation
A number of small adminstrative deficiencies were identified leading to a
violation. These deficiencies involved inadequate attention to detail
with regard to such matters as dating and signing document changes.
8. Status of Previously Identified Items
8.1 (0 pen) Unresolved Item (50-412/83-05-06)
Hilti Concrete Expansion Anchors are required to be torqued during initial
installation. If for any reason, the nut was removed, there was no formal
program to identify control and document the retorque activity. The
licensee established FCP 103.1 and 2 and IP 1.39 to formalize this
program.
During a containment tour the inspector identified Hilti's that were only
finger tight, and no work was in process on that instrument tubing
support. The licensee stated that a final inspection had not been per-
formed on that support and the inspection should have identified the loose
nuts.
However, some confusion still exist about the meaning of the blue
paint " dabs" placed on hiltis to identify QC inspection, and when the
installer or QC is-to be notified for the retorquing and inspection.
The licensee acknowledged the inspectors finding and stated that the
appropriate FCPS and IPs will be revised by April 15, 1985 to state that
the blue paint " dabs" will indicate only that the Hilti bolt setting has
been accepted by QC, and that appropriate FCPs will be revised by
m , ,
,. . .
~
55
>
TApril 30,1985' to require construction to notify QC when a Hilti-bolt _ nut
.
is loosened. Additionally, QC and construction will establish a tracking
Lsystem-to ensure that Hilti-bolt have the final torque accepted by QC,
' ~
This item remains unresolved pending licensee actions as noted above and
, subsequent NRC review.
'
~ : 8.2i (0 pen) Unresolved Item '(50-412/83-05-01)
~
The licensee's audit scheduling procedure does not provide a method
m
to assure that all elements of the quality program are considered or
-addressed in the audit schedule. The licensee representative stated
that.a computer program would be prepared to provide documentation
of quality elements covered and assist in the overall planning and
scheduling of. audits.
To date the licensee has e' valuated each-audit and determined the
quality element / Appendix B criteria covered in each audit and entered
7this information into the computer._ system. However, the licensee has
not developed a~ formal output from the computer that can be used to
,
plan and schedule audits or assure coverage of all aspects of the
quality program.
Prior to the inspection exit the licensee'did provide to the inspector a
han'dwritten' matrix of the 1983-84 audits.versus quality element / appendix B-
cr.iteria. This_ item remains unresolved pending licensee action to
- formalize this computer system and subsequent NRC review.
'8.3 :(Open) Unresolved Item (50-412/85-04-04)
'The' inspector questioned the licensee with' regard to monitoring the
' separation criteria for redundant systems as specified in the Instrument
Installation Specification 2BVS-977. This characteristic is not included
in the. inspection plan as reported in IE Report No.-85-04 and noted in
item 85-04-04. The inspector.had several discussions with licensee and
' Architect / Engineer site representatives regarding this issue. The
licensee has revised Specification 2BVM-228 providing tighter control on
engineering designs released to the site,'however, the licensee is relying
on the revised specification and the Hazards Walkdowns Program 2BVM-165 to
verify conformance to established procedures.
- The licensee is still hesitant about QC involvement in monitoring the
separation criteria._ The issue of whether QC should be involved in
' assuring conformance to specification requirements for separation of
redundant instrument lines remains unresolved.
-.
U .
, _
.g .:
56
'9. Interviews
The NRC inspectors conducted interviews of QC inspection personnel and
craft workers. Approximately 20 QC level I and II inspectors covering a
range'of electrical and mechanical activities were interviewed. Time on
site for these inspectors ranged from three months to 12 years. Inter-
views'of site craft personnel included a cross section of 20 mechanical
and electrical craft with site times ranging from one month to seven
years.
~
QC inspectors were interviewed to determine effectiveness and quality of
training; views of site work quality and knowledge of situations where
work quality or safety was compromised to meet construction schedules;
. interactions with craft and engineering personnel; and knowledge of
threats or harassment in relation to the performance of their duties.
Inspectors interviewed agreed that training programs were adequate for
the job. Views of work quality at the site were good. No situations of
sacrificing work quality for construction schedule were identified.
Interations with craft workers and engineering were positive.
Engineering cooperation in resolving issues was noted. There were no
indications of harassment, intimidation or threats to ignore proper
procedure or quality checks.
Crafts interviews were similar covering the areas of orientation
training; site work quality and known problem areas; interaction with QC
and engineering personnel and DL presence on site. Orientation training
was reported to be adequate. Again the view of work quality at the site
was good. No previously unreported problem areas were identified.
Interactions with QC and engineering was reported to be good. DLC
presence on site and their interest in quality work was noted.
10. Unresolved Items and Program Weaknesses
Unresolved items are matters about which more information is required to
ascertain if it is acceptable, a violation, or a deviation. Unresolved
items are discussed in sections 3.3.5, 4.2.6.2, 7.3.2.3, 7.3.2.4, 7.3.2.5
and 7.3.3.2.
A program weakness represents a condition which, if left uncorrected,
could lead to problems and/or contribute to the violation of a regulatory
requirement. Program weaknesses are discussed in sections 3.3.1 and 7.4.
11 1 . Exit Interview
The inspector met with licensee representatives (denoted in paragraph 1.0)
at the conclusion of the inspection on March 29, 1985 at the construction
site.
The inspector summarized the scope of the inspection, the inspection find-
ings and confirmed with the licensee that the documents reviewed by the
-
F.
'*:
i
r:.
57
, team did not contain any proprietary information. . The licensee agreed
that the-inspection report may be_placed in the Public Document Room
I without prior licensee- review for proprietary information (10 CFR 2.790).
'
'At no time during this inspection was written material provided to the
-
licensee by the team.-
!
'
fs
_
h
-
,
u
- -----.-s-_---_._x-x._-_u-- . - - - -- - - - _ ----- - - - - -- - - - _ ---- - ---_.------- - - - - - - - - - - - - - - .- --. _ . . - - , - -
._.
V
-
TABLE No. 4.2.1
Review of N&Ds and E&DCRs
Document Description SPC-ECN No. SPC-CRN No. SPC-1SO No, Other Affected S&W Documents Remark
I I I J 1 -l
E&DCR No. (S&W) i 1230 l 110743-1C l 110743-1C RM-778-14 l No Finding 'l
2 P-4381 1 1 110756(1-2) l' 110756-2D RM-77C-13 -l l
i I (2-1) i I I I
I I I I I
EkDCR No. (S&W) i 1015 l 109902 l 109902-2G I RM-778-14 1 No Finding
2PS-3396 l l 109908-23 l 109908-2D i i
I f 1 I I
E&DCR No. (S&W) i 2508 l 110-683-2 1 110-683-2 i RM-778-14 l - No finding i
2PS-3717 l l l l. RP-107H l
l l l l RP-107N 1
1 1 1 I u !
E&DCR No. (S&W) i 2578 l 107217-12-1 1 107217-0M i RM-77E-13 I -
No Finding i
2 PT-5034 'I h l l RP-72A-7G l
l l l RP-72F-7J
l i I
E&DCR No. (S&W) l 2801 1 410-701(2-1) l 410-701-3 I RM-77A-14 No finding
2PT-5049 I i 107210(10-1) I 107210-1H I RM-778-14 l
l 1 109901 (4-1) 1 109901-3H l RM-77E-13 l
l l 109907 (3-1) I 109907-2G I I
I i 107214 (7-3) i 107214-ON I i
1 1 1 1 l
E&DCR No. (S&W) I 2805 '
107210(10-1) i 107210-1M 1 RP-72A-7G No finding i
2 PT-5050 I i 109901(4-1) i 109901-3H I R P-728-7 L l
l l l 109907(3-1) 109907-2G I RP-72F-7U l
I i 107214 (7-3) 107214-ON ' RP-990-5F
l l ll RP-99F-3M
i l i li
i
N&D No. (DLC-SQC) i 1778 107226-1E I 107226-1E .
RP-72C-7F No Finding l
l 74;5 l 107222-1F i 107222-1F I R P-72 F-7J l
'
i 1 i RK-303J-1-6
i l I BZ-72A-53/72/120 I
i l l l
'
M&D No. (DLC-SQC) i 2564 l 110712-2F 110712-2F l RP-107C-8A I No Finding
7184A i l l RP-107Q-2AD
l l l l l RP-107G-6Q l
l
1 l l l RS-52A-11B l
l 1 i i
N&D No. (DLC-SQC) i 1947 l 107225-1K 107225-1K RP-72F-7J l No Finding I
7599 I l RP-72C-7F 1 l
l l .
BZ-72A-72-3D l l
i BZ-72A-56-5C
'
l I 1 I
I 1
N&D Mo. (DLC-SQC) i 1978 107226-1E 107226-1E RP-72C-7F No Finding I
7603 1 107222-1F 107222-1F RP-72F-7J l
l RK-303J-1-6 I l
l l , ,
BZ-72A-53/-72/120
l 1 1
l
Nk0 No. (DLC-SQC) 1 2618 1 410-622-5-6 1 410-622 i BVS-64 No Finding
7448 I l 410-427-1-2 . I 410-427 i 6/26/1984
I I 410-636-2-3 1 410-636 l l l
l l 1- 1 l l
.
w-w y w 4 ww'4 pp.. w &
'
.
c
Table 6-1 Page 1 or 3
l
PCCWS WALKDOWN INSPECTION
l l lSPC ISWEC Pipe i PIPING DATA !I i
l
i SWEC Dwg. 11 (Piping Flow Dia. Spool H Mat & Ovality FSAR Field I
!
Mode Desiq. De sc r i p . ISO # # DWG.(SPCI Class Sch. Ratino Findino Data Findino..
Su rge 2-CCP-002- Tank T21A Cl-410-631, RM-77A-12D 631-2/3 151 SMLS,SA106, ANSI None ASME ASME Ill
T:nk 437-3 ' D i scha rge u636&626 i '636-1 to 7 CR 8;SCH.80 150lb; ident, 111/ CL-3; QA
Cisch.l to PCCW l l625-1/2 C.S. CL-3; CAT-l;
i pumps l I i l Class No Find-
I lscr+ ion l l 1 lE 'ing
I theader l l
l l l \ l
Chem. 12-CCP-001 lPCCW pump l CI-410-620,
"
1 620-1 to 4 " " "
l "
l
" "
Addit.l-465-3 Idisch. 629, 639 629-1 tg 6 1 l
l Iheader to .
-
637-1 to 7 I
l
'
tank TK22
l 1 .
I
Chem. 12-CCP-001-l "
lCl-410-637 IRM-77A-120 637-1, 2&5 151 SMLS, SA106, ANSI None ASME ASME Ill
Addit.1444-3 l l ll CR.B; SCH.80 150lb; '
ident. . Ill/ CL-3; QA
l ,1 1 1: I '
C.S. CL-3; CAT-l;
I l l l Class No find-
1 I I '
IE ing
h l L L
Mini- l 2-CC P-010- IIPCCW pumpn 107225 1
" 456-1/2A1 "
STD.WT SMLS
" " " "
mum '456-3 ll d i scha rge : l SA 106 CRB
R circ .
l oin. flow .
I l l
l line ! l l l 1
"
l2-CCP-008- "
l "
lRM-77A-12D 455-1 1 151 "
l455-3 i l l l 150lb; ident. l lil/ lil/
l l ! l l ! C.S. ;CL-3; CL-3; QA
I I l l . Class CAT-1;
I I I l
'
'
IE NoFind-
1 I q l ino
Mini- l2-CCP-008- PCCW pump l 107225
"
1 454-18 "
STD.WT.SMLS " " " "
mum 1454-3 :
d i scha rge l l SA 106, GR.B
Raci rc i min, flowl I l
l line l l l l
"
R2-CCP-010- To PCCW "
ll RM-7 7A-12DI 453-1 A/2A l 151 "
- 453-3 l pump i I l l 150lb; i ident, 111/ . CL-3; QA
l suction l l l C.S. CL-3; CAT-1;
l . header l l l l Class No Find-
I ,
I i l l H IE ino i
PCCW 1 2-CCP-010 lPCCW pump , 107203 i
"
N/A "
ISTD.WI.,SMLSi
" " " "
l
Pump l-683-3 1"A" outlet . L lSA 106, GR.Bl l
"A" l l l l
l l
Disch.I I I
'
H
'
i
"
12-CCP-020 ITo PCCW l " "
1 463-1A1 & 2Al 151 "
ANSI None ASME ASME Ill
l-463-3 lPumpDischl l 150lb; ident. Ill/ lCL-3; QA '
l l Header l l l C.S. CL-3; l CAT-1;
i l l ! I ClasslNo Find-
l l l l l l
'
IE lino
__-. -- _.
_,
-- - - - - .
i
t 5
l
Table 6-1 Page 2 of 3
f
PCCWS WALKDOWN INSPECT 10N
l l ISPC llSWEC l Pipe PIPING DATA I I .
- 1SWEC Dwg. l l Piping ;IFlow Dia. ll Spool Mat & Ovality FSAR. Field
14 ode Desio. IDescrip. ISO # # DWC.fSPC) Class Sch. Ratino Findino Data Findino
PCCW 2-CCP-020 l F rom PCCW 10/206 RM-77A-120 473-1A, 2&3 151 STD.WT. SMLS ANSI None- ASME ASME ill
Pump l-473-3 IPumpDischll l l :SA 106, GR.B i 150lb; ident. til/- CL-3; QA
"A" l IHeader tol I l' C.S.
.
'
CL-3; CAT-1;
,
Disch.1 IHeat exchl l ' Class ; NoFindng
l l l "A" I i H IE
l "
l 569-1 A1 A " " " " " "'
Pump l-569-3 l Heat Exchl l
"A" l l "A" l l
Disch.l l j l ;l
"
12-CCP-016 l "
l 107206 ;
RM-77A-12DI 570-1 2&3Al151 SID.WT. SNLS ANSI None ASME ASME Ill
l-570-3 I : 1 SA 106, GR.B. 150lb. Ident. lIll/ CL-3; QA
l CL-3; CAT-8;
'
I I H C.S.
I l l l ! Class NoFindng
i l l l IE
PCCW 12-CCP-020 : PCCW Heat , 107209 I "
492-1,2,3A1 i
" " " " " "
Pump l-492-3 ;Exch "A" l l -
Exch. I : Outlet I i -
l '
l
"A" l l l l 1 l -1 l
Disch ! .I I l l
"
12-CCP-020 i!PCCW Heatl 107210 lRM-77A-12D1 493-1A/2 151 ll ST D. W T . , SMLS ; ANSI None ASME ASME 111
l-493-3 lExchDischl i l ISA 106, CR.B 150lb; Ident. Ill/- CL-3; QA
l ; Heade r i i ! , l
C.S. CL-3; CAT-1;
I H 1; I I i Class NoFindng
i i l I l IE
PCCW l2-CCP-018 (Header tol .107210, lRM-77-12D l 032-1 thru. l
" "
l
" " " "
Pump l-32-3 lcontain- l 107211, & RM-77B- 1B
Exch. 1 iment i 109905 1.12B
"A" I l I i
Disch.1 I l ;I
12-CCP-018 l l 109905 RM-718-1281 30-1, 2&3A 151 STD.WI.,SMLS ANSI None ASME ASME lit,
" "
l-030-2 1 I 110701 l lSA 106, GR.B 150lb; ident. lill/ CL-2; QA
l l l l l l C.S. CL-2; l CAT-l;
I l l l l Class NoFindng
i i ,
I l '
l ll l'
PCCW l2-CCP-018 Header 110702 1
"
31-2 thru "
'
" " "
P :t I-31-3 Inside i 5 I CL-3; CL-3; QA
Ex 7 I Contain-ll I ll Class CAT-l;
"A" i i ment I i '
IE NoFindng
Disch.I ll l l
Inlet 12-CCP-018 l Header i 110703 RM-778-128 95-1 th ru 151 'STD.WT.,SMLS ANSI None
" "
l
to RHSI-95-3
'
I inside i 110704 1 5 SA 106, CR.BL 150lb; ident.
- E21A I l Contain-l i I C.S.
1 I ment to l l
l RHS Heat! I
l Exch "A" 11
"
12-CCP-024 "
110704 h
"
-
" " " "
l-718-3 i CL-3; CL-3; QA'
l l Class CAT-I;
I H l IE NoFindna
~ ' ~ - ' ~
4.g 11
- , 'a - .
d-
' Table'6-1 Page -3 or 3 ,
'
..PCCWS WALKDOWN' INSPECTION
l' l l SPC ISWEC Pipe.. .I ) PIPING DATA: .'
. Ovality:
ISWEC Dwg. l' l Piping Flow Dia. Spool .
Mat & . .
.FSAR' Field.
. Mode IDesia. IDesc ri o. ISO # # DWC.fSPC) Class Sch. Ratina Findina Data' Findina
Outlet l2-CCP-024 l0utlet to 110709 RM-77B-128 719-1 151 STD.WT; SMLS; ANSI None .. ASME ASME Ill
-t3 RHSI-719-3 IRHS Heat SA 106, CR.B '.150lb; ' 'ident. CL-3; CL-3;-QA
CE21A l lExch."A" C.S. Class CAT-1;No
l l IE - Findina
Outlet l2-CCP-018 (Disch. " "
96-1, 2&3.
" " "' " "- "
t1 . l-96-3 loff RHS
GHS* l Heat Exch
[gjA "A" l '
l
Retu rn 2-CC P-018 RHS Heat. 110711 RM-778-128 37-1 thru 7 151. STD.WT;SMLS; ANSI . None ASME-- ASME-lil
Exch "A" 110712 SA 106, GR.B CL-3; CL-3; QA
'
Header -37-3 150lb; ident.
t2 LDisch to C.S. Class _ CAT-1;Ho ,
- '
PCCW Return IE- Finding
Pump
Suct.
"
2-CCP-018 '
Retu rn 110701- "
36-1A, 2
"' " " "
l-36-2 Hea de r 109901 CL-2; CL-2; QA
l inside. Class CAT-1;No
l Contain- I E. Finding
i ment _
2-CCP-018 Retu rn 109902 RM-77A-12D 35-1 thru 4 151 STD.WT;SMLS; ANSI . None ASME
"- "
-035-3 Header 107222 & RM-778 SA 106, GR.B 150lb; ident. CL-3;
Outside -12B C.S. Class-
l Contain- IE I
l ment
12-CCP-020 PCCW Pump 107224 RM-77A-12D 433-1 thru " " " "
ASME I l l
" "
l-433-3 Suction 107222 3- .
CL-2; QA
i Header i CAT-1;No
Findina
PCCW 2-CCP-020 PCCW Pump 107222 436-1A & 18 151 STD.WT;SMLS; ANSI None ASME
" "
Pumps -436-3 ; "A" 107223 SA 106, CR.B 150lb. Ident, CL-3; i
Suct- I Suction C.S. Class
ion IE
PCCW 2-CCP-012 To 107223 RM-77A-12D 530-500
Pump -530-3 "A" pump
Suc- " " " " " "
'A" l tion.
Suc- l
tion i
r ~-'
~
'
,
O
TABLE 6.2 Page 1 of 3
PCCW SYSTEM EQUIPMENT SELECTED FOR DESIGN DATA REVIEW ',
'
I ISWEC SPC lSPECI. FSAR FIELD NAME VENDOR 000.& NPV-1
SWEC_ EQUIP #fDESCRIPT__ Gf ILW D A. # ISO ipATA DATA PLATE DATA _ DATA
2CCP*P21A lPCCW Pump 1RM-77A-12D , 107203 :2BV-010 ASME lil/CL-3/ Class ingersoli Ha nd, Came ron Ingersoll Rand;
I"A" l -
2107223 IIE, Seismic CAT-1; Div Pump; 400 psig 0 Cameron Div 6000gpm
l l
'
,
'
lHoriz. CF Pump; 170F, ASME Ill/CL-3 0 200rt, Err. 78%,
I i 16000gpm O 200ft., SN 574110, NB #97 400HP/1800 RPM motor;
1
I -
~
H400psig dsgn, 400HP casing (disch) 30ft NPSH, ASME Ill
I } 1 400HP motor XX-10X18AA 1971 + W 1972
! l '
. : addenda, SH 574110;
I f, .
> ,
lNB #97, CL-3 DWC #
'
l __ __l* l_. 1 D-10X-18AA 321X15
'RCCP*E21A lPCCW Heat l l 10 ? 2L% - 28V-128_ _ _ _ _lASME__ lil/CL-3/Seis. Struthers Wells, Struthers Wells;
"
I .
'
lExchancer 110/209 l C AT,- 1 ; 33x10 BTU /HR 225psig/200F-Shell; 225psig/200F - Ghell ,
l "A"- 1 ITube SA-149 TP304 175 psig&Vac/100FTube; 175psig&Vac/100F
i%' '
lShell 225psig/200F ASME lil/CL-3; NB # Tube; Shell capacity
i ITube 175psig/;00F 14335 SN 1-73-06- 1627 gal.; Tube
-1 L I, '
31643-1 capacity 940 gal ASME
> I
'
l' lil/CL-3 1971 +W1972 ,
?
/ l H I ADD NB #14355, GN 1-
___
- l . H 1 .
H 73-06-31643-1
RCC P* T ,'21 A l PCCW Surge l RM-7 7A-120 (Cl-410 2BV-054 ASME 141/CL-3/ CAT-l;l Not AccesslDie ASME lil/CL-3 -1974;
l Tank "A" l .1-637 ,1650' gal; 50psig 0 I .
SN 6206,SA 285-GR.C
i i I d300F, SA-285-CR.C
'
Nat. Annealing
l . !
' -
1 50psig 0 300F; 1650
l 'l gal, cagac. SA-285-
CRC.:72 ODX 12'higtL
,__ l l . _
.
2CCP*Ik2P IPGCW CNem.l l 2BV-058 - l F ield fabrica ted; 12" gb ASME lil/CL-3; Field
(Addition l
" "
Tank x 4' H: ASME Ill l Fabricated; Ngminal
ITank l /CL-3; SA-105 capacity; 12"4 x 4H;
_ ____ll D i f fe ren- ;
'
IMaterial SA-234-WPB. STD.WT
OCV- 10p- 1 RM-77A-120 1107225 2BV-209 ASME lil/CL-3; Class l Copes Vulcan, 165 psig Copes Vulcan; 8"
l 10 180F; SN 8320-594 . Class 150#, D-100
Itlal IE
l p re s su re I '53-1-1; ASME l i i/CL-3~ va lve v/Borg Wa rner
! control NB #2462 Ac tua to r, ASME l i l/
Ivalve on Cl-3 1980 + S1981
12-CCP-008- l
'
.l' ' ADD, ND#2462,165PSl/
454 &455-3 1 180F & 2850si/100F
DCV-101-A D i f fe ren- 107206 2BV-651 Masonellan int:135psig Masoneilan Int; 135
" " 150F, 285psig/100F, psig/150F & 285 psi /
tial
pressure l l ASME lil/CL-3, SN AE 100F, ASME Ill/CL-3
. control
'
897-1-1 6/1971 + 6/1973 ADD
lvalve on L l .
SN AE-897-1-1, 16"-
J2-CCP-016- 37000 series, Class
570-3 150#, Model 3, Actu-
ator position-3
MOV-150-1 Butterfly RM-778-128 109906 2BV-076 ASME lil/CL-2; Class Hen ry P ra t t , 153psig/ Henry Pra tt, 153 psi /
(outside Dvalves l IE 150F, ASME lil/CL-2 1150 F , 275 psi /100F, i
CTMT) & MOV- motor i SN A0027-1/2-1 ASME fil/CL-2-1971 + l l
150-2 ( in- ope ra ted W1972 ADD, SNA-0027-
side CTMT) l on 2-CCP- 1/2-1
1 018-030-2
_ _ _ _ _ _ _ _ _ _ _
.
. . . .. .. .
. .. . ,
y.
{f,
(@
. TABLE'6.2'
'
Page 2, of 3
PCCW SYSTEM EQUIPMENT SELECTED-FOR DESIGN. DATA REVIEW < i-
1 SWEC SPC SPECl. FSAR. FIELD NAME VENDOR DOC.& NPV-1
SWEC EQUIP # DESCRIPT FLOW DIA. # ISO DATA DATA PLATE DATA DATA
MOV-112A Mo to r0pe r- RM-7 78-128 110703 2BV-076A ASME Ill/CL-3; Class POSI-SEAL INT, 153 psi / POSI-SEAL I NT, . inc.
~
ated .. I I IE. 100F,'ASME lil/CL-3;; 150#,.18"-2144 type;
Ibutterfly 1. I li SN 152-45-5A, limit- ASME lil/CL-3 1974 +
Ivalve on l , to rque op r. t SN 261757f S1976 ADD, SN-15245-
12-CCP-018 i Type H- 5A, 153 psi /100F,
I-95-3 i Li m i t to rque, H l BC- -
l l .
I I SM800012
V5 BCheck lRM-77A-12D 1107222 2BV-069 ten ry Pra tt; 200psig/ Hen ry P ra t t, 20"- l
tvalve on l l 300F, ASME lil/CL-3; 1400 series, MDT -
"
12CCP-020- 1 I , SN A-0034-8-2 manua l opr, 200 psi / .
1436-3 l l .I 300F, 275 psi /100F,
I l l I.'
l ASME-lil/CL-3 1971 +
l 'l i l W1972 ADD,SN A-0034-
l l t 8-2. VV1015-AR-3
V2 l Butterfly I ASME Ill/CL-3; ' Henry Pratt; 200psig/ Henry Pratt; VVF015-
" " "
Class IE '200F; ASME I l l/CL-3; . A-3, 20"-1100 series
l valve on i
i SN A-0034-1-1 MDT manual opr SN .
'
12-CCP-020-1
1433-3 l l l A0034-1-1, 200psig/.
l l l l 200F, ASME Ill/CL-3'
l l _. l l
'
-1971 + W1972 ADD
V34, V35 l Ga te l RM-77A-120 lC4-410- 2BV-064 Hancock va lve-Dresser Dresser IND-Hancock
1639,620 "
D V29 l valves on I IND; 940psig/700F,VCS- Line, 1"-600# CS-950
12-CC P-001 l ik 637 I i 060-B-3; SN H096/94/' W-3-XN VCS060-B-3,
1-465/444-3l l l 110 AAE;ASME lil/CL-3; C009 valve, 940 psf /
l l l l 1700F, 1440 psi /100F,
I 'l l l ASME lil/CL-3-1971+
l 1 1 S1973 ADD,SN H096/94
l l 110 AAE
V539 k V96 lCate Valvel . CI-410 ASME lil/CL-3; Hen ry Vog t mach i ne 2"-600# CS Dresser
" "
lon 2-CCP- l l-636 & Class IE 2"-600#;ASME lil/CL-3; valve; VCS060-B-3, I
l002-437-3 1 1626 l SN 97-214959 & 101- 1480 psi 4100F, ASME l
l l l 1 1 214959 lil/CL-3-1977+S1979 l-
l l l ADD, SN 97-214959 &
l l 101-214959
MOV-156-1 Motor i RM-778-128 110701 12BV-076 ASME lil/CL-2; Class , Henry Pratt, 153 psi / - Hen ry Pratt, 18"-
(outside l ope ra ted l .kl099011 ,
IE 150F; SN A-0027-2-3 & VV1015-AR-3, 1400
CTMT)& MOV- butterfly l I I I A-0027-1-3;- ASME lil/ series, 153psig e
156-2(inside CL-2
'
valves on l l l l 150F & 275 psi 4100F i
CTMT) 12-CC P-018- 1 l l l ASME lil/CL-2, 1971
13 l l l l +W1972 ADD, SN
l l 1 l i A-0027-1-3 & 2-3
RV-102 & 10413/4" x 1" l
"
l "
'2BV657 U "
i Dresser ind; Cold Set: Dresser IND, 3/4" x
(inside Irelier i i 155 psi;ACC:15 psi SN 1" relier valve;3/8"
CTMT) l valve on l TE97415 & TE97413 ASME orifice, SN TE97413/
12-CCP-018-l l Ill/CL-2 15, 150psig SET
130/36-2 i L pressure, 793#/HR
I I l sat STM e 10% blow-
) i i I down, ASME I l l/CL-2-
l l l l 11974 + 1974 ADD,
I l l l 1200 osi/400
. _ _ _ _ _ _ _ _ _ .
- _ _ - _ _ _ - - - . . . _ .
_ _ . , _ ,___ ,, , --
. ,
%
TABLE 6.2 Page 3 or 3
PCCW SYSTEM EQUIPMENT SELECTED FOR DESIGN DATA REVIEW
SWEC SPC SPECI. FSAR FIELD NAME 1 VENDOR DOC.& NPV-1;
EWEC EQUIP # DESCRIPT FLOW DIA. # ISO DATA DATA PLATE DATA .
DATA
V20 & V21 Gate RM-77A-120 107225 2BV-073 ASME ,I l l/CL-3 Walworth valve; ASME Wa lwo rth Co. , 8"-150
valves on i lil/CL-3, SN D66475 & ' #CS, VGWO15-A-3,
2-CCP-008 D66483, 275psig 0100F 275 psig/100F, ASME
-454/455-3 .(600F MAX) lil/CL-3 -1971 +
6/1972 ADD, SN
0-66475 &.483
V8 Chec,k 107203 2BV-022 TRW-Mission MFG; Size Mission MFG Co. Buo-
valve on
" "
20; 275ps ig/100 F; SN Check Valve-20"-150#
2-CCP-020- B8631 ASME 111/CL-3 VCl-015-C-3, 275psig
463-3 100F, ASME 111, CL-3
1974 + 6/1974 ADD,SN
88631
V49 & VS1 Butterfly RM-77A-12D 107209 2BV-069 ASME lil/CL-3 Henry Pratt; 200psig/ Hen ry Pra tt,20"-1400
valves on 300F, operator deltaP series VV1015-AR-3
2-CCP-020- 153 psi SN A0034-8-1&5 200psig/300F, 275 psi
492/493-3 l ASME lil/CL-3 100F ASME lil/CL-3
1971+W1972 ADD, SN
A-0034-8-1 & 5
VII & V19 ' Butterfly 107203 Henry Pratt; 200psig/ Henry Pratt; 20"-
valves on
"
" "
200F, opr delta P=135 l
1100 series VVF015-A
2-CCP-020- psi, SN-D-0134-1-2 & 4 l-3, 200psig/300F,
463/464-3 ASME lil/CL-3 l275psig/100F, ASME
lil/CL-3 1971 + 1972
L
l ADD.SN 0-0134-1-2&4
V146, V147 Gate RM-778-12B 110703 2BV-073 ASME lil/CL-3 Walworth valve; 275 psi Walworth Co. 18"-
& 158 valves on 100F; (600F max) SN VCWO15-A-3, 150#,
2-CCP-018- D63683,84&85, ASME Ill 275psig/100F; ASME
31/96/57-3 CL-3 lil/CL-3, 1971 +
6/1972 ADD, code case
1672, SN D63683,
84 & 85
_ . _ _ _ _ _ _ _ _ - _ _ _ ___