ML20132H279
| 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
Text
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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
R. E. Martin, Manager, Engineering
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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
$DR
ADOCK
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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
7
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7//t/85
7p85
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0FFICIAL RECORD COPY
RL BV2 85-07 - 0002.0.0
07/17/85
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(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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SUBJECT:
Beaver Valley Power Station - Unit No. 2
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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
h$4
By
,
~fi/J g arey .V
Vice President
RW/wjs
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
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Mr. Stewart D. Ebneter, Director
inspection Report 50-412/85-07
- Page 2
s
COMMONWEALTH OF PENNSYLVANIA )
)
SS:
COUNTY OF ALLEGHENY
)
,,f[tQ,beforeme,
On this
8
day of
,
_ ,,,,
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
President of Duquesne Light, (2) he is duly authorized to execute and file
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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
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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 ,"
pa rt ic ula r ac t iv i ty shall be
paragraph 5.3.3
states, " Work on a
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
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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-
- 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
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was distributed to all Lead, Senior, and QC Inspectors certified
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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.
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(2) 85-07-06
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It em "( a)":
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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
A
enclosures and found no other similar violat.ons. 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
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define typical acceptable methods for temporary coiled cable
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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
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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.
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
was the only generic elect ric al
indicated that the subject calculat ion
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
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
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
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of~the person making the notation.
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(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
F hat he has seen and reviewed. the adequacy of the method for estab-
t
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
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
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'pe rfo rma nce in this area and t ake action as necessary to improve
performance of personnel in following administrative procedures.
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(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.