ML20133C950

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Responds to NRC Re Violations Noted in Insp Rept 50-412/85-07.Corrective Actions:Memo DLC-SQCL- 1183 Issued on 850327 to Reemphasize Immediate Tagging of Unsatisfactory Condition During Cable Pulling
ML20133C950
Person / Time
Site: Beaver Valley
Issue date: 07/09/1985
From: Carey J
DUQUESNE LIGHT CO.
To: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
2NRC-5-099, 2NRC-5-99, NUDOCS 8507220049
Download: ML20133C950 (8)


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2NRC-5-099 (412) 787-5141 Nuclear Construction Division (412)923-1960 Robinson Plaza. Building 2, Suite 210 Telecopy (412) 787-2629 Pittsburgh, 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

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/85-07

REFERENCE:

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

Gentlemen:

The above-referenced letter transmit t ed a Not ice of Violation as Appendix A. Attachments A through C of this letter provide Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Violation.

The subject inspection reporc requested that DLC also inform the NRC of the actions taken or planned to addres s the two progr ammat ic weaknesses ident ified during ins pect ion 85-07. DLC is evaluat ing these conce rns in conjunction with related concerns ide nt ified in the BVPS-2 SALP. DLC will respond to these concerns by July 26, 1985.

DUQUESNE LIGHT COMPANY By ~ _f J (/Qarey V Vice President RW/wjs At tachment ec: Mr. B. K. Singh, Project Manager (w/a)

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

NRC Document Control Desk (w/a)

SUBS RIBED AND SWORN TO BEFORE ME THIS

_ DAY OF tik _ , 1985.

. A a 8507220049 850709 Notary Public PDR ADOCK 05000412 G PDR ANITA ELAINE REITER, NOTARY PUBUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPfRES OCTOBER 20,1985 I{\k

/WO(

i United States Nuclear Regulatory Commission Mr. Stewart D. Ebneter, Director inspection Report 50-412/85-07 Page 2 COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF ALLEGHENY )

On this M _ day of (.,[r _

, _/((6_,beforeme, a 6

Notary Public in and fo r said Comm/onwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Vice Pres ident 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 furth in the Submittal are true and correct to the best of his knowledge.

_. ?tNk- M'x.O _

Notary Public ANITA ELAINE REITER, NOTARY PUBUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986

m 7

    • 1 ATTACHMENT A I l

NOTICE OF VIOLATION 85-07-05, -06, and -11 10CFR50, Appendix B, Criterion V states in part that " Activities af fecting quality shall be prescribed by documented ins t ruct ions , pr oced ur es , or d rawings , of a type appropriate to the circumstances and shall be accom-plished in accordance with these ins t ruc t ions , procedures , or drawings. . ."

(1) 85-07-05 Duquesne Light Company (DLC) Site Quality Control (SQC) Manual Proce-dure No. 4.4, titled "Nonconformance and Disposition Reports,"

paragraph 5.3.3 states, " Work on a particular act ivity shall be discontinued upon the issuance of an N&D if continued work could cause damage, prevent further inspections, or prevent remedial action."

Contrary to the above, the inspector witnessed the continuation of a bulk cab le pull consisting of 23 c able s (2HCSADC606, 2QSSADC003, 2RSSAOC0ll, ...). This pull included seven cab les that were kinked and one which had three longitudinal cuts in the jacket. These eight cables were 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 Electrical Installation 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 2FPWA0K601 located in junction box 2JB*5012 were in violation of their minimum bend radius criteria of less than 2.1 inches. The measured value was approximately 1.0 inch.

(b) Cable 2SLSBPH301, which powers safety injection pump 2 SIS *P21B was coiled and hanging ove rhead by a rope, creating a minimum be nd radius violation of less than the speci fied it inches. The measured value was approximately ten inches.

(3) 85-07-11 The Electrical Installation Specification, 2BVS-931, page 3-35, lines 8 and 9, states in part, "all cables ins talled in trays shall be protected against mechanical damage."

Contrary to the above , cables we re damaged in cab le raceway No.

2TCl38P. These cables were not protected from mechanical damage as evidenced by - cables exiting the raceway at suppo rt No. QC93 were in contact. 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).

RESPONSES (1) 85-07-05 This violation relates to the failure of site personnel to follow project procedures with respect to work af fected 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 violation, 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 o f - 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 iate tagging of such a condition is, in ef fect, a "Stop Work" on that activity until the N&D is formally issued, processed, and dispositioned.

(b) The. electrical contractor has reinstructed his supervisors regard-ing in-process inspection during cable pulling and has' imple:nented management measures for identification 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 i

procedures for N&D processing for cable pulling activities to the -

electrical personnel assigned to the Integrated Construction Support Group (ICSG).

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

- for the seven cables that were kinked and N&D 16057 for the cable that was cut. N&D 15993A has been dispositioned to accept the cables involved and N&D 16057 has been dispositioned 'to scrap the cable that was cut.
(2) 85-07-06 Item'"(a)":

This condition is believed to have occurred following the-installation of additional cables in the enclosure, violating previously accepted cable training radii. SQC performed a random re-inspection of 30 previously accepted installations within enclosures - and found no other similar violations. To preclude l~#

E 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 fulfilled.

. . _ _ . - _ _ _ - . ~ . . _ _ . _ _ _ _.- __ __ . . _ , __- __ - _ _ _ - , _ _ _ _ . _

. .~ - . -_ . - . . . . .. - .

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. 1 Item "(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 Electrical 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 Palling Foreman. To ensure temporary coiled cable is. stored in accordance with the require -

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 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.

For the specific cable cited, N6D 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. L ' 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

' NOTICE OF VlOLATION 85-07-09 10CFR50, Appendix B, Criterion XVll states in part, "... sufficient records shall be maintained to furnish evidence of act iv it ies af fect ing quality ... Records shall be identifiable and retrievable."

The DLC Quality Assurance Manual Section 17.3 states in part, "... records are required to be maintained ... for the life of a particular item ...".

Sect ion 17 .4 .2 states in part, "... the Arch itect Enginee r/ Cons truct ion shall develop and maintain a Records Management System wh ich will ...

store records in a readily ident ifiab le and easily ret rievab le manner Contrary to the above, records were not maint ained or ret rievable 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).

RESPONSE

SWEC has evaluated the circumstances surrounding the missing site gener--

ated elect r ic al calculat ion. Interviews with SWEC SEG personnel have indic ated that the subject calculation was the only generic electrical calculation prepared in the field. Other specific electrical calculations have been performed in the body of engineering documents or under E&DCRs, and are retrievable as part of those documents. To further ens ure the adequacy of any supporting calculations used in the development of elec-t rical 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, applicab le , retriev-able, and properly documented. To date, no additional cases of missing documentation have been identified. This review and any necessary correc-tive actions will be completed by 9/30/85.

To preve nt recurrence, measures have been implemented within the SEG to 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, "Ac t ivit ies 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, initiated and dated by the person making notation.

Contrary 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 documentation 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 "that 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 stamp 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

a similar memorandum dated 3/22/85 on the same subject to QC person-nel. Project Procedure 2BVM-202 was revised to correct SDDF annot a-t ion discrepancies, in addit ion, the Superintendent of the .SEG reiterated to his supe rviso ry pe rsonnel and the Supe rv iso r of the Document- Review Group their responsibility for ensuring that documents are administratively correct. To measure the ef fect iveness of the correct ive ac t ion, a - formal review of 500 of the approximately 1,200 documents.(N&Ds, E&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 assigned to the SEG. This rev iew identified ' 30 documents with minor administrative discrepancies and indicates the project action has reduced the number of administrative ..

discrepancies. -Site- project management will continue to nunitor performance in this area - aM take act ion as necessary to improve performance of personnel in following administrative procedures.

(2) Item "(2)":

One discrepancy cited by the NRC involved the seismic certificate of compliance statement, " appear to conform to seismic requirements" that was identified as not being in compliance with procurement Specifica-tion 2BVS-636 page 2-6, lines 38-43. A review of 30 additional seismic certificates of compliance indicated specification prescribed wording was correct. The seismic report for the cited certificate of compli-ance has ' been reviewed by engineering and found to be technically correct. Thus, no additional 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 has been revised to permit, when designated , a certified Level 111 in the appropriate discipline to certify ins pection/ tes ting personnel by his signature. Since the individual in ques t ion met these requirements, no further action will be taken.

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