ML20136J464
| ML20136J464 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/27/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-156, NUDOCS 8601130390 | |
| Download: ML20136J464 (4) | |
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Pittsburgh, PA 15205 December 27, 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 Report 50-412/85-21 Gentlenen:
In a letter to Mr. J. J. Carey, dated Novenber 22, 1985, Region I transni tted a Notice of Violation as Appendix A.
This is Duquesne Light Company's (DLC) response pursuant to the requirenents of 10CFR2.201 and that Notice of Violation.
NoticeofViolation(85-21-01):
As a result of the inspection conducted on Septenber 17 through October 22, 1985, and in accordance with the NRC Enforcenent Policy (10CFR2, Appendix C), the following violation was identified:
10CFR50, Appendix B, Criterion X, Inspection, requires that a progran for inspection of quality shall be establi.;hed and executed to verify confonnance with documented instructions, procedures, and drawings for accomplishing the activity.
Contrary to the above, as of Septenber 27, 1985, a Quality Control Inspection Report f ailed to verify confonnance to specified attri-butes of the installed condition of the HVAC supports referenced on the report. Specifically, the inspection report stated that attribute 014 (verify the concrete expansion anchors are properly installed) was not applicable because no concrete expansion anchors were used.
On the supports inspected (2HVZ-DSA-048K, 2HCZ-DSA-051K),16 concrete expansion anchors actually existed. Reinspections of these 16 anchors revealed conditions on 12 of the anchors that exceeded the allowable drawing tolerances.
This is a Severity Level IV Violation (Supp1N.uat II).
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,5 United Stat:s Nuclear R:gulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-21 Page 2
Response
On receipt of the infonnation described in the Notice of Violation fron the Senior NRC Resident Inspector during Inspection #85-21, the following immediate action was taken:
a) The Hilti spacing dimensions were checked and found to be in error.
This action was immediately followed by the re-verification of the general support dimensions.
b) The QC Inspector's certification was suspended.
c) An investigation was initiated to establish the cause of the problen.
The initial re-verification of 90 dimensions on the support in question showed nine general dimension deficiencies ranging fron 1/8" to 1-3/4" outside of tolerances.-
These deficiencies, with the Hilti spacing deficiencies, were fonnally recorded on N&D #32136.
N&D #32136 has subsequently been dispositioned with appropriate technical justification and found to be acceptable in its as-built condition.
A review of the QC Inspector's previous Inspection Reports was perfonned.
This review denonstrated an active verification involvement by the Inspector, with unsatisfactory conditions and conments being recorded, including at least one Nonconfonnance and Deficiency Report on the sane subjects that had been the cause of this investigation.
In view of this, four supports were selected, approximately in the save time frane as the supports in question, where the Inspector had not made many inspection comments or recorded deficiencies.
This re-verification was perfonced by a QC Engineer and an Inspector who were not involved in the rcscine inspection and acceptance of HVAC supports and covered 176 separate dimensional checks.
This resulted in three minor errors; and, considering the detail of the re-verification, it was considered that this sanple denonstrated accurate previous work by the Inspector concerned.
Consideration was given to the possibility that the support in question may have been partially inaccessible and required effort to inspect thoroughly. A support was then selected that was considered to reflect a support that was difficult in reference to accessibility for inspection.
Thirty-six dimensions were re-verified on the selected support; and, of the 36 dimensions checked, one structural dimension was found 1/8" out of tolerance.
Similarly to our previous assessnent, it was considered that l
the support had been adequately inspected by the inspector concerned.
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United States Nuclear. Regulatory Commission
-Mr. Edward.C. Wenzinger, Chief
'USNRC IE Inspection Report 50-412/85-21 Page 3
- As the initial' concern related to the Inspector reporting "No Hilti Bolts Fitted" when, in f act, Hilti bolts were part of the support installation, 138 of the previous Inspection Reports that - contained the phrase "No Hilti Bolts - Fitted" were reviewed against the drawings to establish whether the statenent was accurate.
This review against the drawings
- revealed that apart fran the support in question, wherever the Inspector had indicated "No Hilti Bolts Fitted," none were required.
The actions taken at the time 'of BVPS-2's previous Inspector problen was also reviewed, and it was established that. the Inspector's record was reviewed at ^ the time of the previous problen by exanining the sanpling
- inspection results;. that review indicated satisfactory perfonnance.
Thus, at the time of BVPS-2's previous Inspector problen, this Inspector was considered satisfactory, and no action was taken at that. time with reference to his past perfonnance.
Interviews were initiated with the Inspector and his supervision, and it appeared that there was a lack of conmunication between the Lead Inspec-E tor and this Inspector during the period that' the support in question was accepted.
In view of. this and BVPS-2's previous problens in this area, the Lead Inspector has been denoted; and a new supervisor fran another site, who is currently under training, will De assigned.
Thus, the QC supervisory structure of the HVAC Inspection Group will be replaced.
Following BVPS-2's investigation. and interviews, the Inspector in ques-tion. was suspended fran the project for a minimun period of three weeks.
He has conpleted that suspension and has currently been re-assigned in a different discipline (Instrumentation) under another QC Supervisor on the
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site.- The NRC Resident Inspector was infonned of BVPS-2's decision and the' return of the Inspector.
Meetings have been held with the supervision of all disciplines, mechani-cal and electrical, to re-enphasize the need for an on-going and continu-ous comnunication between supervision and Inspectors to assure that any delays-in conpleting an inspection is known, understood, and controlled.
It is BVPS-2's view that one of the contributing causes to this event was the delay -in conpleting the inspection while the Inspector awaited an answer to a Request for Infonnation that he had generated relative to the support in question.
It is submitted that this case of QC acceptance of a support with dimen-sional errors by this Inspector is 'different fran our earlier problen.
. insofar that we believe this to be an isolated incident; whereas, in our ci I'c problen, we. did not.
We are continuing with our re-verification N y!ctor's work by an independent group and the randon sanpling of l
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. United Statis Nuclear R:gulatory Connission i
Mr. Edward C. -Wenzinger, Chief
' ;USNRC IE; Inspection Report 50-412/85-21
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..n attributes by supervision to prevent re-occurrence of this problen.
It
..is further submitted' that.the independent audits, including measurenents,
.perfonned by Quality Assurance and the re-verification pefonned by your own Specialist 'and Resident -Inspectors -plus our.re-verification and sanpling prograns give: anple assurance that the installations are. being installed in accordance with the required l specifications and drawings.
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'The acceptance of the as-built condition of the supports 'in question is indicative _.of.
there being no. safety significance relative to-the l
installation.
DUQUESNE LIGHT COMPANY By J. J' Varey Vice President SOH/wjs cc: :Mr. B. K. Singh, Project Manager Mr. ~G. Walton, NRC Resident Inspector.
COP 910NWEALTH'0F PENNSYLVANIA )
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, COUNTY OF
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i On-this M d [/i day of tejXlt
///[,- before me, a Notary Public in and for said. Commonwealth and County, personally appeared -
and said that (1) he is Vice J. Carey,. who ' being duly '(sworn, deposed J.
- 2) he is duly -authorized to execute and file President of - Duquesne Light, 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.
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