ML20132H279

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-412/85-07

ML20132H279
Person / Time
Site:	Beaver Valley
Issue date:	07/30/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carey J DUQUESNE LIGHT CO.
References
NUDOCS 8508050297
Download: ML20132H279 (2)

See also: IR 05000412/1985007

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JUL 3 01985

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Docket No. 50-412 License No. CPPR-105

Ouquesne Light Company

ATTN: Mr. J. J. Carey

Vice President

Nuclear Group

Post Office Box 4

Shippingport, Pennsylvania 15077

Gentlemen:

Subject: Inspection Report No. 50-412/85-07

This refers to your letter dated July 9,1985, in response to our letter

dated June 7, 1985. >

Thank you for informing us of the corrective and preventive actions documented

in your letter. These actions will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated.

Sincerely,

bit.!mi rignea Drt

'M

i Stewart D. Ebneter, irector

Division of Reactor Safety

cc w/ encl:

E. J. Woolever, Vice President, Nuclear Construction Division

E. Ewing, Quality Assurance Manager

R. J. Swiderski, Manager, Startup Group

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R. E. Martin, Manager, Engineering

i E. F. Kurtz, Jr. , Manager, Regulatory Affairs

P. RaySircar,-Stone and Webster Engineering Corporation

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Public Document Room (PDR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

FFICIAL RECORD COPY RL BV2 85-07 - 0001.0.0

8500050297 07/17/85

ADOCK 12

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Duquesne Light Company 2

bcc w/ enc 1:

Region I Docket Room (with concurrences)

Senior Operations Officer (w/o encl)

DRP Section Chief

T. Rebelowski, SRI, Millstone 3

RI:DRS RI:DRS :DRS

Anderson Durr Ebneter

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0FFICIAL RECORD COPY RL BV2 85-07 - 0002.0.0

07/17/85

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'Af 2NRC-5-099

(412) 787-5141

(412) 923-1960

Nuclear Construction Omsion Telecopy (412) 787 2629

Robinson Plaza. Budding 2, Suite 210

Psttsburgh, PA 15205

July 9, 1985

United States Nuclear Regulatory Commission

Region 1

631 Park Avenue

King of Prussia, PA 19406

ATTENTION: Mr. Stewart D. Ebneter, Director

Division of Reactor Safety .

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Beaver Valley Power Station - Unit No. 2

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SUBJECT:

Docket No. 50-412

Inspection Report 50-412/85-07

REFERENGE: Letter dated June 7,1985 (S. D. Ebneter to J. J. Carey)

Gentlemen:

Tne above-referenced letter transmit t ed a Not ic e of Violation as

Appendix A. Attachments A through C of this le t t e r provide Duquesne Light

Company's (DLC) r es po ns e pursuant to the requirements of 10CFR2.201 and the

NRC's Notice o f Violation.

The subject ins pe ct ion report req ues t ed that DLC also inform the NRC

of the ac t io ns taken or pla nned to ad dr es s the two prog r ammat ic weaknesses

ide nt i f ied during inspection 85-07. DLC is evaluat ing - these conce rns in

conj unct ion with rela t ed concerns ident i f ied in the BVPS-2 SALP. DLC will

respond to these concerns by July 26, 1985.

DUQUESNE LIGHT COMPANY

By ,

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~fi/J g arey .V

Vice President

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At t achme nt

ce: Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walton, NRC Resident inspector (w/a)

NRC Document Control Desk (w/a)

SUBSCRIBED AND SWORN TO BEFORE ME THIS

_dj._DAYOF Q j _.p- _ , 1985.

_id.MJ.ct14As Notary Public

ANITA ELAINE REITER, NOTARY PUBLIC

ROBIN $0N TOWNSHIP, ALLEGHENY COUNTY

ggygh] O MY COWfSSION EvnRES OCTOBEP 70.1925

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United States Nuclear Regulatory Cotanission

Mr. Stewart D. Ebneter, Director

inspection Report 50-412/85-07

Page 2

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COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF ALLEGHENY )

On this 8 day of , _ ,,,,

, ,,f[tQ,beforeme, a

Notary Public in and fo r said Commonwealth and County , pe rsonal ly appeared

J. J. Carey, who being duly sworn, deposed and said that (1) he is Vice

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President of Duquesne Light, (2) he is duly authorized to execute and file

the foregoing Submittal on behalf of said Company, and (3) the statements set

forth in the Submittal are true and currect to the best of his knowledge.

,.s.,

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Notary Public

ANITA ELAINE REITER, NOTARY PtlBttC

ROBINSON TOWNSHIP, ALLEGHENY COUNTY

MY COMMISSION EXPIRES OCTOBER 20,1986

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ATTACHMENT A

NOTICE OF VIOLATION 85-07-05, -06, and -11

10CFR50, Appendix B, Criterion V states in part that "Act ivit ies af fect ing

quality shall be prescribed by documented ins t ruc t ions , procedures, or

d r awi ng s , of a type appropriate to the circumstances and shall be accom-

plished in accordance with these instructions, procedures , or drawings . . ."

(1) 85-07-05

Duquesne Light Company (DLC) Site Quality Control (SQC) Manual Proce-

dure No. 4.4, titled "Nonconformance and Di s pos it ion Repo rt s ,"

paragraph 5.3.3 states, " Work on a pa rt ic ula r ac t iv i ty shall be

discontinued upon the issuance of an N6D if continued work could cause

damage, prevent further inspections, or prevent remedial action." ,

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Contrary to the ab ov e , the inspector witnessed the continuation of a -

bulk cable pull consisting of 23 c ab le s (2HCSAOC606, 2QSSAOC003,

2RSSAOC0ll, ...). Tnis pull included seven cab le s that were kinked

and one which had three longitudinal cuts in the jacket. These eight

,vables we re identified as nonconforming by SQC on March 22, 1985, and

later pulled on March 25, 1985. This continued work could have caused

damage to or prevented remedial action for these cables.

(2) 85-07-06

The Elect rical Installat ion Specification, 2BVS-931, Sect ion 3.2.1.14

states, "The minimum bending radii shall not be less than the bending

radius given in cable specifications for each table."

Contrary to the above, two instances of minimum bending radius viola-

tions were identified by the inspectors as follows:

(a) Cables 2FPWAOK600 and 2FPWAOK601 located in junction box 2JB*5012

were in vio la t ion of their minimum bend radius criteria of le s s

than 2.1 inches. The measured value was approximately 1.0 inch.

(b) Cable 2SISBPH301, which powers safety injection pump 2 SIS *P21B was

coiled and hanging ove rhe ad by a rope, c re at ing a minimum be nd

radius violation of le s s than the s pe c i f ied 11 inches. The

measured value was approximately ten inches.

(3) 8_5_-07-11

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Tne E lec t r ic al Installation Specification, 2BVS-931, page 3-35, lines

8 a nd 9, states in part, "all cables ins t al led in trays shall be

protected against mechanical damage."

Cont ra ry to the above, cables were damaged in cable raceway No.

2TC138P. Inese cab le s were not pr ot ect ed fr om mechanical damage as

ev ide nced by cables exit ing the raceway at support No. QC93 were in

cont ac t with the sharp edge of the raceway siderail causing an inden-

tation in the cable cover to 50% of its thickness.

The above are collectively a severity IV violation (Supplement 11).

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.R.ESPONSES

(1) 85-07-05

This violation relates to the failure of site personnel to follow

project procedures with respect to work affected by N6D's when the

work involved is of a dynamic nature and in-process. As a result of a

review of the events leading to this violat ion, the following actions

were taken:

(a) The Director of DLC SQC issued a clarifying memorandum, DLC-SQCL-

1. 1183 dated 3/27/85, re-emphasizing to QC staff and Inspectors the

need for the immediate tagging of an unsatisfactory condition

during such a dynamic process as cable pulling. This instruction -

was distributed to all Lead, Senior, and QC Inspectors certified _

for the verification of cable pull activities. The immed iat e

tagging of such a condition is, in ef fect, a "Stop Work" on that

activity uta iI the N6D is formally issued, processed, and

dispositioned.

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(b) The electrical contractor has reinstructed his supervisors regard-

ing in process inspection during cable pulling and has implement ed

management measures for identi ficat ion and control of any condi-

tions in violation of requirements which result in stopping cable

pulling activities.

(c) The Superintendent of the Site Engineering Group re-emphasized the

procedures for N6D processing for cable pulling activities to the

electrical personnel assigned to the Integrated Construction

Support Group (ICSG).

For the specific cables cited, two N6D's were initiated: N&D 15993A

for the seven cables that were kinked and N6D 16057 for the cable that

was cut. N&D 15993A has been dispositioned te ' accept the cables

involved and N&D 16057 has been dispositioned to sdrap the cable that

was cut. -

(2) 85-07-06

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This condition is believed- to have occurred following the

installation of additional cables in the enclobure, violating

previously accepted cable training radik , FQt' performed a random

re-inspection of 30 previously accepted inst,611a t ions within

enclosures and found no other similar violat.ons. A To preclude

possible recurrence the Electrical Contractor has. reiterated to

its personnel the need to ensure that all cables, including

previously installed cables, comply with the minimum cable bend

radius criteria. SQC has revised its Inspection Plan IP-8.4.1 to

verify that the above requirements are fulfilledi

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As stated in the Inspector's report, SQC initiated N&D 15969 for

the specific cable cited. The disposition required the cable to

be . re-trained; this has been accomplished and the N&D has been

closed.

It'em "(b)":

The project has initiated a program to improve the temporary

-storage of cable to prevent the violation of the cable minimum

bend radius and the potential for storage induced cable jacket

damage. These measures have included the instruction of contractor

personel concerning precautions required for the temporary storage

of cable and the requirement relating to the istallation of

, temporary cable support racks. FCP-431 was revised on 6/28/85 to -

define typical acceptable methods for temporary coiled cable _

storage. The appropriate training of Elect ric al Contractor

personnel will be completed by 7/15/85. The responsibility for

the proper storage of temporary coiled cable has been formally

assigned to the appropriate Cable Pulling Foreman. To ensure

'*" temporary coiled cable is stored in accordance with the require-

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ments of FCP-431, the Electrical Contractor and SQC are performing

an examination of safety related cable in temporary coiled storage

condition. . Any deficient conditions found will be corrected by

I 7/26/85. For future installations, SQC has initiated a formal

surveillance inspection program for an in process review of

temporary coiled cable storage as defined in IP-8.4.2.

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For the specific cable cited, N&D 16014 has been dispositioned as

acceptable and the N&D has been closed.

(3) 85-07-11

At the time of the subject inspection, SQC was performing a backfit

inspection of cable installations, in accordance with IP-10.2.3. This

Inspection Plan included an inspection for cable jacket damage. To

'date, in excess of 1,400 transition point installations have been

inspected and two cables exhibiting cable jacket damage have been

identified; one requiring a repair and the other found acceptable.

The results of this inspection, so far, indicate that installation

damage of the type described can be considered isolated instances.

However, FCP-431 was revised on 6/28/85 to describe protective

measures to be taken to prevent similar instances of cable damage.

The appropriate training of Electrical Contractor personnel will be

completed by 7/15/85. IP-8.4.1 will be revised and the appropriate

training given to QC personnel by 7/15/85.

For the specific condition cited, N&D 16013 identified three cables

with jacket indentation. Engineering has evaluated the indentations

on two cables (Mark Nos. NKA-02 and 2/C-12AWG) as acceptable and one

cable (Mark No. NKA-06) as unacceptable. N&D 16013 has been disposi-

tioned accordingly.

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ATTACHMENT B

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NOTICE OF V10LAT10N.85-07-09

10CFR50, Appe ndix B, Criterion XV11 states in. part, "... sufficient

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records shall be maint ained L.o furnish ev id ence of act iv it ies af fect ing

quality ... Records shall be. identifiable and retrievable."

The DLC Quality Assurance Manual Sect ion 17.3 states in part, ". . . records

are required to be ma int ained ... for the li fe of a pa rt icula r item . . ." .

Sect io n 17 .4 .2 states in part, "... the Ar ch itect Engineer / Cons t ruc t ion

shall develop and ma int ain a Records Management System which will ...

store records in: a readily ide nt if iab le and easily ret r iev ab le manner

...".

Contrary to the above , records were not maint ained or retrievable to

furnish evidence that- calculations to support pulling of elect rical cable,

an activity affecting quality, properly considered sidewall pressure.

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This is a severity IV violation (Supplement 11).

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RESPONSE

EWEC 'has evaluated the circumstances sur rounding the missing site- ge ne r-

at ed elect rical' calculat ion. Int e rv iews with SWEC SEG personnel have

indicated that the subject calculat ion was the only generic elect ric al

calculation prepared in the field. Other specific electrical calculations

have been performed in the body of engineering documents or under E&DCRs,

a nd are ret riev ab le as part of those doc ume nt s . To further ens ur e the

adequacy of any_ supporting calculations used in the development of elee-

trical criteria'or engineering requirements, SWEC is conducting a compre-

hensive review of 2BVS-931 to verify that calculations, codes or standards

utilized as bases ' for the specification are accurate, applic ab le , r et r i ev-

able, and properly documented. To date, no addit ional cases of missing

document at ion have been ident if ied . This review and any necessary correc-

tive actions will be completed by 9/30/85.

To prevent recur rence , me at,ur es have been impleme nt ed within the SEG t o

ensure that the record keeping requirements of SWEC Engineering Assurance

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Procedure EAP 5.3 are followed for all calculations prepared by the site.

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ATTACHMENT C

NOTICE OF VIOLATION 85-07-04

10CFR50, Appendix B, Criterion V states in part, " Activities affecting

quality shall be prescribed by documented ... procedures ... and shall be

accomplished in accordance with these ... procedures ...".

(1) Procedure 2BVSM-83 Section -4, requires- that corrections / errors,

changes / additions be crossed with a line, initialed and dated by the

person making notation.

Cont rary to the above, engineering documents in the document review

group were found with corrections and deletions that were not properly

initialed and dated. In addition, corrections and deletions were made

by QC personnel. on vendor documentat ion without the date or initials -

of~the person making the notation. _

(2) Procurement specification 2BVS-636, page 2-6, lines 38-43, requires

that " seller submit a certificate of compliance which will be stamped

and signed by a Registered Professional Engineer with the statement

Ft hat he has seen and reviewed. the adequacy of the method for estab-

lishing that the seismic design requirements have been met.

Contrary to the above,.a vendor test report was accepted based on the

vendor Professional Engineer statement that the ' test results "...

appear to conform to seismic requirements."'

(3) Procedure' TP-2 Section 4.3 for Qualification and Certification states

"the Director or Assistant . Director /QC shall certify

inspection / testing personnel by his signature."

Contrary to the above, two QC inspectors were certified by an individ-

ual other than the Director or Assistant Director /QC,

(4) Procedure 2BVSM-202, Section 5.26.6 requires the Responsible Engineer

using an approval stamp to initial and date use of the stamp on engi-

neering documents.

Contrary to the above, the Responsible Engieer used an approval st amp

on SDDF documents without the date and initials of the person autho-

rized.to use the stamp.

The above are collectively a Severity Level V Violation (Supplement

II).

RESPONSE

(1) Items "(1)" and "(4)":

As stated in the subject report, Site Project Management issued a

memorandum on 3/26/85 to reiterate to personnel the requirements for

document corrections and deletions. In addition, QC Management issued

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a similar memorandum dated 3/22/85 on the same subject to QC pe rson-

nel. Proj ect P r oced ur e 2BVM-202 was revised to correct SDDF annot a-

tion . discrepancies. In addi t ion, the Supe rint ende nt of the SEG i

reiterated to his supe rv iso ry pe rsonnel and the Supe rv i so r of the  !

Document Review Group their responsibility for ensuring that documents

are adminis t r atively correct. To measure the ef feet iveness of the

c o r rect ive action, a fo rmal review of 500 of the approximately 1,200

documents (N&Ds, f.5 DC Rs , and SDDFs with associated Material Receiving

Reports [MRR] and Receipt inspection Reports [RIR}) processed through

the SEG between April 1,1985, and June 15, 1985, was conducted by the

Engineering Assurance Engineer as s igned to the SEG. This review

ide nt ified 30 d ocument s with minor admi nis t r at ive discrepancies and

ind ic a tes the project act ion has red uc ed the number of administrative

discrepancies. Site proj ect management will continue to manitor ,

'pe rfo rma nce in this area and t ake action as necessary to improve

performance of personnel in following administrative procedures. -

(2) Item "(2)":

,One discrepancy cited by the NRC involved the seismic ce rt ific at e of

compliance statement , " appear to conform to seismic requirement s" that

was identified as not being in compliance with procurement Speci fic a-

tion 2BVS-636 page 2-6, lines 38-43. A review of 30 additional seismic

certificates of compliance ind ica t ed specification prescribed wording

was correct. The seismic report for the cited certificate of compli-

ance ' has been reviewed by eagineering and found to be technically

correct. Thus, no addit ional action is required or recomme nded

concerning certificate of compliance documentation.

DLC/QA and SWEC Engineering Assurance will re-exami ne areas found

deficient by the NRC in a regular audit scheduled for August 1985.

(3) Item "(3)":

TP-2 nas been revised to pe rmi t , when designated , a ce rt ified Level

111 in the appropriate discipline to ce rt i fy ins pe ct ion / t es t ing

personnel by his signature. Since the individual in que s t ion met

these requirements, no further action will be taken.