ML20133K182
| ML20133K182 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/10/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-140, NUDOCS 8510210104 | |
| Download: ML20133K182 (3) | |
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October 10, 1985 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Edward C. Wenzinger, Chief Projects Branch 3 Division of Reactor Project
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC IE Inspection Repo',t 50-8.'12/85-16 Gentlemen:
In a letter to Mr. J. J. Carey dated September 10, 1985, Region I transmitted a Notice of Vlolation as Appendix A.
This is Duquesne Light Company's response pursuant to the requirements of 10CFR2.201 and that Notice of Violation.
Notice of Violation:
10CFR50, Appendix B, Criterion XVI requires that measures be established to assure that... nonconformances are promptly identified and corrected.
Contrary to the above, as of August 5,1985, the licensee had not estab-lished anci. implemented a program to assure that nonconformances are promptly corrected.
As a result, nonconformances remained outstanding on Nonconformance and Disposition (N&D) and Construction Deficiency Reports (COR) for such extended periods of time that potential damage has occurred to components and materials may have been installed before corrective actions occurred.
For example, N&D 6758 issued May 26, 1983, identified that non-approved fluorescent tape applied to the surf aces of stainless steel piping potentially contained chloricies, halogens, and sulf ur.
Although disposition of this N&D on June 30, 1983, required the tape to be removed and the areas buffed to remove possible surf ace contaminates followed by washing with demineralized water to renove residuals, as of July 18, 1985, no such corrective actions had been taken.
In another example, N&D 2009 issued February 24, 1982, identified angle iron contain-ing laminations ud scabs.
This N&D was not dispositioned for corrective action as of AugJst 2,1985, and as of August 6,1985, this material could not be located and may have been installed without any corrective actions being taken.
This is a Severity Level IV Violation (Supplement II).
8510210104 gspagg hDR ADOCK 05000412 PDR
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s United S;ates Nuclear Regulatory Commission Mr. Edwa d C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-16 Page 2
Response
The project's progran for closure of N4D Reports has been as follows:
- An N&D is issued by SQC, entered into Exception Work Tracking (FCP-29),
and assigned to an applicable system or area release.
- The N&D is reviewed by Stone & Webster (S&W) Engineering and a priority for disposition is establishec ' ased upon urgency (e.g. to support o
turnover, release materials from hold, etc.)
- The applicable contractor completes the closure actions with priority based upon systen and/or area turnover schedule and tasting requirements following turnover.
CURS have been closed in a similar manner but without engineering review.
This approach to N&D and CDR closure has been determined to be the nost efficient to meet all project requirements.
N&D and CDR closure is monitored by the various organization managers and action taken as appropriate.
strengthen our progr am, the following actions have been or will be To taken to ensure those conditions which require expeditious correction are assigned appropriate priority:
- The S&W Superintendent of Engineering has issued a directive to his personnel to identify N&Ds which require expeditious closure to minimize the adverse effects of a potentially deteriorating condition.
These will be included in the next revision cf 2BVM-218, requirements
" Handling of Nonconformance and Disposition Reports by Site Engineering Group" scheduled for November 1,1985.
- DLC-SQC will advise S&W Engineering when those N&Ds identified by S&W Engineering as requiring expeditious closure have not been closed in a specified time.
These conditions will also be brought to the attention r
of tne DLC-QA Manager.
- The Mechanical and Electrical contractors have instituted measures to have all N&Di and CDRs reviewed and to have designated personnel expi-dite N&Ds requiring timely closure.
- All NLDs not closed are being reviewed by S&W Engineering and the Elec-trical and Mechanical Contractors in accordance with the above require-ments to establish any revised priority for closure.
This review will be completed by October 18, 1985.
- The Quality Improvement Management Program (QIMP) has been t ' vised to include management reporting for N&Ds which will provide the ecument
l United States Nuclear. Regulatory Commission
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Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-16 Page 3 status from initiation until closure. A corresponding CDR Status Report will be incuded in the QIMP monthly report for September.
For specific N&Ds cited in the subject violation, the following is provided:
I
- N&D-6758 has been closed utilizing the original disposition which has
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- been reviewed and found satisf actory.
- N&D-2009 has been investigated and OLC has concluded that the stock angle steel could not have been installed with the condition - cited j
(scabs and laminiations) because FCP-804, " Inspection and Testing of l
Category I Coatings" requires all stock angle steel to be sandblasted and QC inspected prior to painting.
Thus, any unacceptable conditions would have resulted in steel rejection.
N&D-2009 has been voided.
J DUQUESNE LIGHT COMPANY W
By l
J. J. Carey.
Vice President RW/wjs Mr. B. K. Singh, Project Manager (w/a) j cc:
Mr. G. Walton, NRC Resident inspector (w/a) l 4
s I
COMMONWEALTH OF PENNSYLVANIA )
) *c..
COUNTY OF On this
/ddl day of
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, before me, a Notary Public in and for said Commonwealth and County, personally appeared who being duly sworn, deposed and said that (1) he is Vice J. J. Carey, President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statenents set forth. in the Submittal are true and correct to the.best of his knowledge.
4 J:bh
_h_ s as Notary Public ANITA ELAINE REITER, MOTARY PUGUC 1
l ROBINSON TOWNSHIP, At.LEGHENY COUNTY
- MY COMMISSION EXPIRES OCTOBER 20,1986 i
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