ML20133C030
| ML20133C030 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/29/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-109, NUDOCS 8508060329 | |
| Download: ML20133C030 (5) | |
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'Af 2NRC-5-109 (412) 787-5141 (412)923-1960 Nuclear Construction Division Telecopy (412) 787 2629 Robinson Plaza. Building 2, Suite 210 Pittsburgh, PA 15205 July 29, 1985 United States Nuclear Regulatory Commission 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 Revised Response to USNRC IE Inspection Report 50-412/85-04
REFERENCE:
2NRC-5-078, dated May 30, 1985 Gentlemen:
The following is a revised response to the Notice of Violation cited in Inspection Report 50-412/85-04 for violation 85-04-02 and 85-04-04.. This is being submitted per NRC request in a telecon with Mr. Ralph Paolino (NRC),
Mr. Glen Walton (NRC), Mr. Les Arch (DLC), and Mr. Stanley Hall (DLC) on June 28, 1985.
Duquesne Light Company's (DLC) previous response to violation 85 02 (see above reference), relating to the third and fourth specific actions on Page 2, reads as follows:
- The instrument installation speci fic (2BVM-977) for separation criteria for instrument tubing was reviewed. This review determined that clarifications were required to distinguish between hazard and nonhazard areas; these clarifications were issued as E&DCR 2P4652B on February 27, 1985.
- All issued isometric drawings for QA Category I instrument tubing were reviewed.
Some 75 of over 900 reviewed required revisions by means of a note to indicate where speci fic deviations from the E&DCR 2P4652B were allowable pending confirmation by the Hazards Analysis Program.
However, the review in general confirmed that the intended design requirements were being fulfilled.
The info rmat ion presented above reaffirms the res pons es provided to Audit SPC-4 regarding SQC verification of adequate instrument tubing separa-tion.
The engineering and design process for instrument tubing isome tr ics,
coupled with SQC verification of tubing installation in accordance with the isometrics, provide sufficient controls to ensure compliance with separation criteria.
The following is DLC's revised response providing additional informa-tion regarding action taken:
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' Mr. Richard W. Starostecki Revised Response to USNRC IE Inspection Report No. 50-412/85-04 Page 2
- The instrument installation specific (2BVS-977) for separat ion criteria for instrument tubing was reviewed. This review determined that clarifications were required to distinguish between hazard and nonhazard areas; these clarifications were issued as E&DCR 2P4652B on February 27, 1985, and subsequently incorporated it into 2BVS-977, Rev. 2, dated April 29, 1985.
In order to ensure compliance with the modified separation require-ments contained in E&DCR 2P4652B, SWEC initiated and coupleted a review of all existing isometric drawings for QA Category I instru-ment tubing.
This review determined that noted instances where were not in accordance with relevant separa-separation distances t ion criteria were limited to those cases for which the le s ser distances were shown on applicable SWEC isometric drawings.
- Over 900 isometric drawings were examined during this rev iew, and approximately 75 were found to require revision.
These drawings have been revised by the addition of a note that ident ifies the specific deviation from the separation criteria for E&DCR 2P4652B and indicates that confirmation of the acceptance of the deviation will be verified and documented under the BVPS-2 IIazards Analysis Program, in accordance with 2BVM-165.
- Each of these deviations from the separation requirements of E&DCR 2P4652B were evaluated and it was determined that, in each case, the noted conditions represented an acceptable instrument tubing configuration with no rerouting of tubing required.
Hazards analy-sis confirmation of the acceptance of these conditions will be documented as part of the normal work activities and schedules comprising the Hazards Analysis Program.
- During the isome tric drawing review, approximately 18 conditions were noted that represented deviations from the original separation criteria of 2BVS-977.
Of these 18 deviations, 17 instances c o n-cerned redundant impulse lines separated by less than 4 feet in HELB hazard areas; one deviation represented redundant impulse lines on common supports in a nonhazard area.
Final documentation will be developed following hazards analysis of the conditions, as previously discussed.
- Because the original tubing separation criteria of 2BVS-977 had not been property implemented in certain isolated cases, and in order to strengthen the engineering and design process fo r ins trume nt tubing isomstrics, project procedure 2BVM-228 was revised as of Apell 24, 1985, to clearly translate the separation requirements of 2BVS-977 into detailed design procedures and design ve rificat ion steps. Training of appropriate personnel regarding the content and use of revised 2BVM-228 has been completed.
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. Unit &d Stetas Nuclear-R guistory Conssission.
'Mr. Richard W.. Staroctecki.-
~ Revised Response' to USNRC IE Inspection
-Report No. 50-412/85-041 Page 3 In addition, DLC has re-evaluated the need for an SQC inspection for spatial separation of redundant safety-related instrument lines.
The following ' actions will be/have been taken to ensure SQC involve-
. ment in.the verification of separation criteria.
- 1) SEG has furnished SQC with a list of safety-related instruments which identifies the redundant-groups.
- 2) SQC is in the process of revising IP-7.2.9 to require ins pect ion for redundancy of such instruments. This inspection will be done at the time of the tubing configuration ins pect ion for future ins tallat ions. SQC will issue the required revision to IP-7.2.9 by July 19, 1985.
Those instruments which have previously been subject to a tubing configuration walkdown will be reinspected to ensure the redun-dancy requirements have been met.
SQC estimates that it will be able to complete the reinspection by August 15, 1985.
- 3) Violations to the redundancy criteria will be processed as indicated below:
a) Those which violate the redundancy criterla and installation drawing. These will be identified on N&D's, b) Those which violate the redundancy criterla but which are installed in accordance with the ins tallation drawing.
If they are not identified on the drawing as being reviewed by the Engineers then they will be reported on a " Redundant Separation Evaluation Request."
This " Request" will identify such violations to SEG.
SEG will evaluate these conditions and in the space provided, justify them if they meet the reduced separation criteria.
If the conditions do not meet the reduced separation criteria, or if the reduced separation criteria does not apply, SEG will indicate which drawings need to be revised to rework the condition.
The SQC inspection plan will be revised by July 26, 1985, to address the use of the Redundant Separation Evaluat ion Request.
c) Those which violate the redundancy criterla but which are installed in accordance with the installation drawing.
If they are identified on the drawing as being reviewed by the Engineers, no corrective action will be required.
In regards to Violation 85-04-04, the following revised response is provided. The revisions are identified by an underscore.
r-Unitid St&tes Nuciscr Regulatory Cormaission
. Mr. Richard W. Starostecki Revised Response to USNRC IE Inspection Report No. 50-412/85-04 Page 4
Response
The proper designations fo r the instruments and suppo rt s referred to indicated on drawings RK-303-AC-1 and RK-303-AA for elevation above, as 728 f t.-6 in, of the main steam and cable vault area, a3 2CCP-FT117B2, 2CCP-FT117A2, TSR-180, and TSR-189.
Neither these instruments nor their impulse lines are redundant s afe ty-related components.
For nonsafety-related instruments and impulse lines, the use of common supports is acceptable and is not prohibited by 2BVS-977. Therefore, the installations of concern noted in Violation 85-04-04 do not represent a deviation from applicable engineering requirements.
To provide further assurance that the requirements of 2BVS-977 regarding common supports have been properly implemented, SWEC initiated and com-pleted an engineering review of all BVPS-2 isometric drawings issued fo r QA Category I instrument tubing. This review confirmed that supports for all redundant, safety-related instrument impulse lines had been properly spe ci fied, with one exception.
This exception (redundant safe ty-rela ted tubing on a common suppo rt) has been evaluated and de termined to be accep t ab le.
In accordance with 2BVS-977, and as clarifled by E&DCR 2P4652B, the acceptability of this installation has been formally identi-fled as requiring final confirmation by the Hazards Analysis Program.
In order to provide general requirements for supports on safety-related and nonsafety-related instrument impulse lines, E&DCR 2P4652B was issued on February 27, 1985, against Specification 2BVS-977 and clarifies 2BvS-977 regarding requirements for supports.
DUQUESNE LIGliT COMPANY By f
J.
. Carey V*ce President SDH/wje Mr. J. M. Taylor, Director (3) cc:
Mr. B. K. Singh, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk g, DAY OF [fqWORN TO BEFORE ME Ti SUBSCRIBED AND
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before me, a Notary Pubile in and for said Codnweadh and County, personally appeared J.
J. Carey, dio 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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