ML20133B340
| ML20133B340 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/26/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-111, NUDOCS 8508060144 | |
| Download: ML20133B340 (4) | |
Text
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(412) 923 t960 Nuclear Construction Dmsson Telecopy (412) 787 2629 Robinson Piers Building 2. Suite 210 P.ttsburgh, PA 15205 July 26, 1985 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Stewart D. Ebneter Director Division of Reactor Safety
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/85-07 REFE RENCE S : 1) Inspection Report No. 50-412/85-07, dated June 7,1985 (S. D.
Ebnetter, NRC Region 1, to J. J. Carey, DLC)
- 2) 2NRC-5-105, dated July 19, 1985 (J. J. Carey, DLC, to D r. T.
E. Murley, NRC Region 1)
Centlemen:
Reference 1 requested that Duquesne Light Company (DLC) res pond to two programmatic weaknesses identified during Inspection 85-07. The following provides DLC response to the identified areas of concern.
Weakness 85-07-01: " Project Management Changes /NCD Procedures Manual (extract from Reference 1)
Duquesne Light Company (DLC) Proj ect Management and the DLC Nucle ar Construction Division have undergone frequent changes during the past year. This is related to changes in the project from a construct ion-only phase to a construction-startup phase. Evidences of this are:
DLC organizational changes in the past year have resulted in three different individuals handling the duties of NCD Project Manager.
The DLC Nuclear Construction Division Procedures Manual requires substantial revisions in the areas of Section 1.0, " Management"; Sec-tion 5.0, " Construction"; and Section 7.0, " Project Control."
Response 85-07-01:
All significant changes to the administrative procedures have been completed.
Additional minor changes which involve corrections to job titles and certain review and approval chains are in progress. We expect to complete this ef fort over the next several weeks.
All necessary revisions will be issued by September 15, 1985.
8508060144 850726 PDR ADOCK 05000412 O
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g tnitcd Stctco Nuclocr R:gulctory Cormnission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/85-07 Page 2 Tne changes to the organization, which were identified in the inspection report, reflect the trans it ion of project leade rship from our remote of fices at Robinson Plaza location to the site where the major ef fort is taking place.
The Construction Department has been eliminated as a distinct department with some duties trans fe rring to the Project Controls Depa rtme nt and othere to the Startup Group.
It is correct that three distinct individuals have served as the project manager.
However, the changes have reflected an upward mvement of these res ponsibilit ies to the Vice P res ident, Nuc le ar, who has been res pons ible for the project since December 1983.
This trans fe r of responsibilities was made subsequent to the delegation of the day-to-day res pons ibilities for BVPS-1 to the Senior Manager which e 4. bled the Vice President, Nuclear Group, to devote full time to the BVPS-2 Project.
It is considered that the organizational changes will facilitate the t rans fo rmat ion from the construction and startup mde to an operating plant at the time of fuel loading.
As described in our July 19, 1985, response to the SALP, we have retained a consultant to review our existing project o rganizat ion.
We shall keep you informed if additional changes are undertaken as a result of this review.
Weakness 85-07-13: " Engineering / Construction Interface in the Electrical Area (extract from Reference 1)
Significant overall progress has been made in improving the interface between engineering and construction within the last ye ar.
- However, there is evidence of lingering problems in the engineering construction interface for electrical construction activities. These include:
A cable pull violation resulting from interf ace dif ficulties between engineering, construction, and quality control.
During the ins pect ion, S&W engineering pe rsonnel could not demon-strate that cable sidewall pressure was included in cable pull c alculat ions.
For a period of 30 days following the inspection, S&W engineering personnel could not deir.onstrate that cable sidewall pres-sure was satisfactorily considered for all installed cable.
During the inspection S&W engineering personnel could not es tablish torquing requirements fo r bolted connections when terminating 4160 volt powe r cables to the load side of the circuit breaker stabs.
Inconsistencies exist between elecrical installation speci fication 2BVS-931, the cable terminating field construction procedure FCP-432, the inspection procedure IP 8.5.2, and the Sargent Electric Company (SECO) drawings concerning the tightening of hardware.
1 (Jnited Stctes Nuctsar R3gulctory Commission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/85-07 Page 3 Response 85-07-13:
The NRC's concerns for this area can be divided into two distinct cate-gories, speci fic concerns and general concerns.
The specific concerns have been identified as NRC Unresolved Items or Violations and are being tracked to ensure timely resolution and comple t ions.
Certain of the issues have precipitated changes in the procedures or processes govern-ing electrical activities within engineering, SQC, or the electrical contractor.
The general concern, while noting that significant ove rall progress has been made in the engineering / construction interf ace, indi-cates that additional attention is required in the speci fic area of electrical construction / engineering interface.
An integrated and detailed plan, entitled the Elect rical Plan Cuide (EPG) has been developed and was issued for of ficial project use on June 10, 1985.
It describes the plans for resolution of engineerig items ami completion of construction and inspection activities on tasks import ant to the electrical ef fort.
The plan will be kept up to date on a quar-terly basis.
The Project has recently undertaken an ove rall reiew of the BVPS-2 electrical installation specification, the electrical Field Construction Procedures, and the SQC electrical Inspection Procedures.
The objective of this review is to ensure consistency among these documents and to ensure each document is complete regarding its purpose.
The review of the electrical ins tallation specification will identify the bases used to develop the various numerical limits and requirements specified and will provide assurance that calculat ions, codes, or standards used as bases for the specification are properly documented.
These reviews and any necessary cor rect ive actions are scheduled to be completed by September 30, 1985.
Finally, the staffs of both the Site Engineering Group and the Inte-grated Cons truc t ion Support Group have been strengthened through the addition of senior experienced electrical engineers.
The introduc t ion of these individuals has improved the interface among engineering, construction, and quality control.
DUQUESNE LIGHT COMPANY iORN TO BEFORE ME TilIS SU SCR BED AND 5)Mi[
7 AY OF (__/
, 1985.
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By
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Notary Public J. Jf Carey
$#EliA u. FAfftet. #0TARY PUOLIC Vice President RW/wjs
$NIPPIASPOST B000. 0(Avit COUNTV WT C0mSIS$40# (EPlets $(PT.16.1985 Mr. B.Y' Sinkli, IrYeYtTNger cc:
Mr. G. Walton, NRC Resident Inspector NRC Document Control Desk (w/a)
dnited Stctes Nuclect Ragulctory Cotanission Mr. Stewart D. Ebneter, Director Incpection Report 50-412/85-07 Page 4 COMMONWEALTH OF PENNSYLVANIA )
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SS COUNTY OF BEAVER
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, before me, a On this M [/ d day of
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Notary Public in and for said Condonwedith and County, personally 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 the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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Notary Public sletlLA 5. fat 100(.110iARY P90LIC Sit lPMcGPORT 0000. SEAVEE COUNTT 57 C0selsl80s EXPteil SEPT.16.1985 Member. Pennsytesme Aseeristion of IIstaries I
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