ML20128A910
| ML20128A910 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/17/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-073, 2NRC-5-73, NUDOCS 8505240361 | |
| Download: ML20128A910 (7) | |
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~~*" EE emeeursn. PA isios May 17, 1985 United States Nuclear Regulatory Conunission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starostecki Division of Project and Resident Programs
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/85-05 Gentlemen:
This is in response to the concerns identified in your letter and to the Notice of Violation cited in Inspection No. 50-412/85-05 and listed in Appendix A (Notice of Violation) attached to your letter to Mr.
E.
J.
Woolever, dated April 9, 1985.
An extension for responding was granted on May 9, 1985, to May 17, 1985, by the Sr. Resident Inspector to incorporate additional information as a result of a meeting held at the Region I Of fices in King of Prussia, PA, on May 7,1985.
VIOLATION 85-05-01
" Removal of Hold / Reject Tags" Notice of Violation:
10CFR50, Appendix B, Critrion XV, states, " Measures shall be estab-lished to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation."
Contrary to the above, Hold or Reject tags were not removed froes required by Site Quality Control (SQC) proce-various corsponents as dures after such component s had been satisfactority reworked to resolve the nonconforming condition that proispted the Hold or Reject tag.
Additionally, despite the tag's instruction, "Do not use this equipment," the inspector observed work in progress on February 12, 1985, on a component tagged with Hold Tag 7895, which was closed by Nonconformance and Disposition (N&D) Report 7076.
This is a Severity Level IV Violation (Supplement II).
Response
d Inmeediate Action Taken
,/
Upon notification of the Inspector's concern, an investigation was D
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.Unitsd Stetso Nuciscr Rigulctory Commission Mr. Richced W..Sterbotscki USNR IE Inspection Report No. 50-412/85-05 Page 2 S
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initiated.
This investigation included a review of applicable logs to identify. those situations where Hold / Reject tags had been listed as missing or where no disposition of the tag was entered.
A total t
'of 418 tags met one or the other'of these conditions. A site inspec-tion was initiated by the Mechanical, Electrical, Structural, Receiv-ing, Surveillance, and System Release SQC Groups resulting in' 65
- expired tags being removed and destroyed.
Three hundred fif ty-three (353) tags co'uld not be found and are presumed lost or destroyed.
The main problem areas were in the SQC Mechanical and Receiving discipline. The SQC Surveillance activity has a possible outstanding problem as this group rejected items because they were improperly protected or stored. Subsequently, these items have been cleaned and wrapped -with plastic.
It is probable that a few of the tags, recorded as missing by this group, are, in fact, wrapped up with the-item.
It has been decided to leave the protective ' wrapping intact and look' for. expired tags when the protection is removed.
This will s.
be an on-going activity.
Long-Term Corrective Action:
The following actions have seen taken to prevent recurrence of this problem:
- 1) SQC-4.4'; )"Nonconformariba and Disposition Reports," and SQC-4.6,
" Construction Deficien.:y Reports," have been revised to require g~
that written or physical evidence that the tags have been removed be presented prior to the close of the document.
2)
SQC-4.4, "Nonconformdnce and Disposition Report," has been revised to1 require the resoval or revision of related tags prior v
to stasping "Not Issuea" on the document when the N&D Report is N
not issued following a review by SQC.
- 3) A training program for SQC personnel reflecting the revised
&r requirements has been completed.
- 4) Construction Management has reiterated the importance of SQC Hold / Reject tags to the contractors as it affects their activities.
N -
VIOLATION 85-05-02
" Performing Inspections Outside of the QA Function" First Item of Concern:
Extract from Cover Letter:
Additionally, we are concerned about the apparent lack of compli-ance with your Quality Assurance (QA) program in that activities i
were performed without involvement of your QA program as described in Section 5 of the enclosed report.
It appears that si
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c Unitqd Stcteo Nuclect Rtgulctory Commission Mr. Richard W. Stercotscki USNR IE Inspection Report No. 50-412/85-05 Page 3 Stone & Webscer Engineering Corporation (SWEC) Engineering and W
Duquesne Light Company (DLC) Engineering made manageinent deci-sions regarding inspections which are currently assigned in your program as the responsibilities of the QA Manager or his subordi-1 3
nates, to direct the compliance and extent of inspections on all quality related matters of this nature.
In your res pons e, you should address your plans to assure that quality decisions and inspections are - performed in accordance with your approved QA program.
Notice of Violation:
10CFR50, Appendix B, Criterion I, requires the applicant to establish and implement a QA program. The DLC QA program was established pursu-ant to the above and requires the following:
4
" Quality assurance functions shall be performed by persons and organizations with clearly defined authority and responsibilities which are delineated in writing.
Persons performing quality assurance functions shall have sufficient authority and organiza-
-tional freedom to identify quality problems; to initiate solu-tions through designated channels and to verify implementation of solutions; and to control further work on a nonconforming iten until a proper disposition has been made.
The individual or group. assigned the responsibility for inspect-ing or otherwise verifying that an activity has been correctly performed shall be independent of the group directly responsible for the performance of that specific activity.
Activities affecting quality shall be de fined and documented in applicable procedures, instructions, drawings, speci fications, direct ives,
policies, and similar documents."
The QA Manual establishes controls for items which fail to meet the requirements and provides for the use of Hold or' Reject tags to identify deficient items that shall be affixed to the item to identify its status.
Contrary to the above, prior to February 27, 1985, inspection, dispo-sition, and rework of electrical panel wiring was in proces s to verify compliance with Regulatory Guide 1.75, without implementing the approved QA program.
Specifically, personnel performing inspec-
[
tions were not part of the QA function, were not certified to perform inspections, and were not independent,
i.e.,
separated from the organization directly responsible for performing the specific activ-ity.
Nonconformance conditions were found and dispositioned without following the program requirements for tagging, trending, and report-ing.
Procedure FPC-422.1, used for the inspection activity, had not been approved or issued for field use by either the applicant or the engineering organization responsible for the internal wiring.
Unitqd Stctcc Nuc1Gcr Rigulctcry Comunisaica Mr. Richcrd W. Stcrcotscki USNR IE Inspection Report No. 50-412/85-05 Page 4 This is a Severity Level IV Violation (Supplement II).
Response
The details supporting this violation state that,
"....the above rework program is being. performed 'outside' of the approved Duquesne Light Quality Assurance (QA) program although the equipment being reviewed is included in the QA program...." The work referred to is the ef fort of SWEC to review the status of electrical panel internal wiring with respect to separation criteria. The engineers were using detailed vendor wiring diagrams to identify and tag electrical panels which contained wiring that did not meet Regulatory cuide 1.75 requirements; however, the wiring in these panels had not been inspected and accepted by SQC.
SQC will perform a formal inspection of these panels to ensure compliance to our commitments with res pect to Regulatory Guide 1.75.
Any future reviews of this type performed by SWEC or DLC engineers will include an
' inspector to eliminate duplication of effort and to ensure proper documentation of any nonconforming conditions.
In response to the statesent, "... inspections, disposition, and rework was in progress for the separation of internal wiring of electrical panels without implementing the approved Quality Assurance Program,"
DLC QA does not consider the engineering activities (identifying and tagging of electrical panels) to be a formal inspection as described in the approved QA program.
The final inspection to ensure compliance to our coramitments to Regulatory Guide 1.75 requirements will be performed by SQC personnel who are certified in accordance with ANSI N45.2.6.
DLC has determined that the draf t of FCP 422.1 should have been formally issued prior to any field reviews being conducted.
This requirement has been discussed by project management with the personnel involved, stress-ing the need to preclude similar occurrences in the future.
In addition, SWEC has verified that the completed engineering reviews of the subject panels were conducted by appropriate engineering personnel and documented in accordance with FCP 422.1, as formally issued. Thus, no re-evaluations appear necessary of the separation configurations for field and vendor internal wiring.
VIOLATION 85-05-03
" Resolution of N&D 2350 and Associated Matters" Notice of Violation:
10CFR50, Appendix B, Criterion XVI, requires that deficiencies and nonconformances be promptly identified and corrected.
Contrary to the above, as of March 13, 1985, N&D Report 2350, issued by SQC on October 8,1982, has not been satisfactorily dispositioned.
The disposition response only addressed the 19 examples cited in N&D Report 2350 and failed to address the generic problem of electrical cable pull tensions and bend radius for a potentially significant quantity of cable installed prior to issuance of the N&D Report.
~
Unitcd Stcteo Nuciscr Rigulctory Commisaica Mr. Richard W. Secrcstseki i
USNR IE Inspection Report No.- 50-412/85 Page 5 This is a Severity Level IV Violation (Supplement II).
Response
NED Report 2350 was issued by SQC on October 8,1982, to document con-flicting engineering criteria for cable installation regarding pull tensions and bend radii. On July 14, 1983, SWEC dispositioned N&D Report 2350 indicating that the 19 listed cables were acceptable "as-is" based on engineering analysis, and that measures were being taken to ensure consistency regarding the criteria for the pulling of any future cables (the ef fort regarding future cables was completed in September 1983).
In addition, although the N&D Report did not explicitly state this, SWEC's initial review of the problem indicated that there would be no signifi-cant impact for other cables already installed. Af ter being dispositioned
. by SWEC, NED Report 2350 was submitted for SQC review and approval, in accordance with applicable project procedures. SQC requested a redisposi-tion of N6D Report 2350 because the original disposition did not explic-itly extend beyond the 19 identified cables.
On July 28, 1983, in accordance with SQC's request, SWEC initiated efforts to provide a docume nted response to the overall issue under N&D Report 2350A.
N&D-Report 2350A was dispositioned on March 25, 1985, and reaffirmed that the 19 listed cables were acceptable as-is.
It indicated that changes had been made to preclude future conflicts regarding pull tension values and bend radius ' values, and confirmed that all previously installed cables were acceptable as-is.
These conclusions were justified by appropriate electrical calculations referenced in the disposition of N&D Report 2350A.
SWEC's oversicht in failing to formally disposition N&D Report 2350 regarding previously installed cables, as identified by SQC, is con-sidered to be' an isolated condition; there were no adverse impacts associated with this oversight, as confirmed by N&D Report 2350A.
On May 7,1985, a meeting was held between the NRC, SWEC, and DLC at the NP.C Region 1 Offices in King of Prussia, PA.
The subject of the meeting was the electrical cable installation process at BVPS-2, including a discussion of the engineering limits established for cable pull tensions, cable sidewall pressures, and cable bend radii.
At this meeting, SWEC and DLC committed to review the technical bases for engineering criteria contained in the BVPS-2 electrical installation specification (2BVS-931).
This review, scheduled for completion by July 1,
1985, will provide further assurance that consistent criteria are in place regarding cable installation, thereby minimizing discrepancies such as those originally identified under N&D Report 2350.
SECOND ITEM OF CONCERN - DLC Commitment to Regulatory Cuide 1.75 and IEEE Standard 384 Extract from Cover Letter:
Also, we are concerned that your commitments to Regulatory Cuide 1.75
'Unitsd Stctu Nucl= r Regulstory Commicaion Mr. Richard W. Starostecki USNR IE Inspection Report No. 50-412/85-05 Page 6 and IEEE Standard 384 are presently not being met for wiring of the electrical panels as described in Section 6 of the enclosed report.
Specifically, it appears that you are not assuring proper electrical separation when both vendor-installed and field-installed wiring are considered. We request that you provide, in writing, your basis for not applying the separation provisions of Regulatory Guide 1.75 and IEEE Standard 384 in internal panel wiring.
Response
Based upon the results of electrical conductor separation testing conducted at Wyle Labs for BVPS-2, it has been determined that the minimum spacing of wiring within panels may be reduced to one inch for certain applications. This applies to both vendor installed and field installed wiring and includes the inter-relationship between both.
Detailed information is included in the Wyle Labs document entitled " Test Report on Electrical Spectrum Verification Testing". We are currently completing our evaluation of the report and will submit this information to NRR along with the DLC conclusions by June 15, 1985. We are currently revising the appropriate field construction procedures in order to implement this reduced separation criteria as verified by the test results.
DUQUESNE LIGHT COMPANY I
I By
/
J. @ Wrey
(/
Vice President SDH/wj s cc:
Mr. R. DeYoung, Director (3)
Mr. B. K. Singh, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk SUBSCRIBED AND SWORN TO BEFORE ME THIS Y M AY OF d 4
, 1985.
$/O W? basma-Notary Public Will(A 5. FAfl00E, NOTARY PUS (IC SMlPPilIGP0tl 3000. OEAWER C0tfNTY
- f CON #15589h EXPseil SEPT.16.1985 tiember. Posesylvenne Association of Noteries
UnitGd Stctos Nuciocr RIgulctcry Connaisoien Mr. Richcrd W. Stcrectacki USNR IE Inspection Report No. 50-412/85-05 Page 7 COMMONWEALTH OF PENNSYLVANIA )
)
SS:
COUNTY OF BEAVER
)
On this /
day of M,
[M before me, a said Commondalth and County, personally appeared Notary Public in and for J.
J.
Carey, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Corspany, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
Yll. Y-W&
/
Notary Public WiiLA N. FAff001. 80fAtf P90 tlc SMIPPleGP00T B000.SEAvit COURTT NY CONNIS$1001(IPlats SEPT.14.1905 Member. Pennsyleenie Assepehen el Gotories
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