ML20198H546
| ML20198H546 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/16/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-6-008, 2NRC-6-8, NUDOCS 8601310051 | |
| Download: ML20198H546 (7) | |
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2NRC-6-008 (412)787 5141 m
(4121923-f 960 Nucleer Construction Divtsion Telecopy (412) 787 2629 Robinson Plaza. Buildmg 2. Suite 210 Pittsburgh, PA 15205 January 16, 1986 United States Nuclear Regulatory Commission Region I 631 Park Aven"e 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 50-412/85-25 REFERENCE :
Inspectton Report No. 50-412/85-25, dated December 20, 1985 Gentl emen:
In a letter to Mr. J. J. Carey dated December 20, 1985, Region I transmitted a Notice of Violation as Appendix A and a Notice of Deviation as Appendix 8.
This is Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the Notice of Violation and the Notice of Deviation.
Notice of Violation (85-25-01):
10CFR50, Appendix B, Criterion III, Design Control, requires in part that measures shall be established to assure that applicable regul atory requirements and the design bases are correctly translated into specifica-tions, drawings, procedu as, and instructions.
Contrary to the above, on December 2,1985, it was determined that the design bases as contained in Specification 2BVS-931, Electrical Installa-tion, was not correctly translated into wiring diagram 10080-RE-18EC, Revision 2A concerning the type of terminal blocks acceptable for use in the wiring installation for the feedwater isolation val ve actuators.
Specifically, 2BVS-931 requires the use of nuclear grade terminal blocks (Marathon Type 1500-NUC and 142-NUC) in the Main Steam Valve House for Category I circuits. Wiring Diagram 10080-RE-18EC, Revision 2A, Hydraulic Feedwater Isolation Valves 2FWS*HYV157A, 1578, 157C permits the use of commercial grade Marathon 1500 terminal blocks.
The inspector determined that a commercial grade Marathon 1512 terminal block was installed in the junction box (2JB*3603) for 2FWS*HYV157C.
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l United States Nuclear Regulatory Commission l
Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 2
Response
In response to the case identified by the Notice of Violation, Nonconfor-aance and Disposition Report No. 16520 was issued on Decenber 6, 1985, against the referenced junction boxes and was dispositioned by requiring repl acenent of the conmercial grade tenninal blocks with nuclear grade tenninal blocks.
l In response to the general concerns, SWEC Engineering reviewed all elec-l trical drawings (RE series) for consistency with specification 2BVS-931 regarding tenninal blocks.
SWEC Engineering also reviewed the associated l
Field Construction Procedure (FCP-432, Electrical Tenni nations) and SQC Inspection Plan IP-8,5.2, (Scheduled Cable Tennination Acceptance).
The results of this review are as follows:
1.
FCP-432 and IP-8,5.2 accurately reflect the requirenents of 2BVS-931.
2.
26 conmercial grade tenninal blocks are shown on RE drawings for use in areas in which nuclear grade tenninal blocks are required.
l All affected RE drawings will be revised by March 31, 1986, to show the installation of the nuclear grade tenninal blocks in accordance with 2BVS-931.
Construction will repl ace any conmercial grade tenninal blocks previously installed with the nuclear grade tenninal blocks as required.
To prevent the recurrence of this situation, Engineering personnel have been infonned in writing that all future tenninal blocks for safety-related applications will be shown on RE drawings as nuclear grade regard-less of plant location.
Only a small number of new tenninal blocks are expected to be added at this time.
In addition to the actions noted, a problon report (EAP 16.1) and a reportability evaluation (EAP 16.2) have been initiated.
Notice _of_ Deviation (85_25-02):
FSAR, Table 1.8-1 conmits to follow the guidance of Regulatory Guide 1.29, Revision 3.
Regulatory Guide 1.29, Regulatory Position 2, requires those portions of structures, systens, or conponents whose f ailure could reduce the func-tioning of any safety-rel ated systen to an unacceptable safety level should be designed and constructed so that a Sefe Shutdown Earthquate (SSE) would not cause such failure. Regulatory Pos tion 4 further requires that the pertinent quality assurance requirenents if 10CFR50, Appendix B, be applied to all activities affecting the safery-related functions of those structures, systens, and conponents.
l
United States Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 3 Contrary to this, as of November 15, 1985, monorail systems were installed above sa fety-rel ated systems, such as the high head safety injection pumps, so that their failure could reduce the functioning of high head safety injection safety-related system to an unacceptable safety level.
These monorail systems were not designed and constructed so that a SSE would not cause a failure.
The pertinent quality assurance requirements of 10CFR50, Appendix B,
were not applied to construction activities affecting the safety-related functions of the monorail systems.
Visual inspection of certain portions of these monorail systems revealed ques-tionable construction practices, particularly in the quality of the welds.
Apparent porosity and undercut was observed.
Response
Two distinct concerns were identified by the NRC inspection, (1) monorail systems purchased under Specification 2BVS-17 to be utilized in Category I areas were not specifically designed to seismic requirements as required by FSAR Table 1.8-1 and (2) the pertinent portions of 10CFR50 Appendix 8 were not applied to activities in the manufacture and installation of the monorail systems. These concerns will be addressed separately.
(1) The design of the monorail systems with regard to seismic integ-rity is consistent with the commitment in FSAR Table 1.8-1 to Regulatory Guide 1.29, Rev. 3.
These monorails are not required to function after a SSE but their failure could reduce the func-tioning of other safety-rel ated equipment and therefore in accordance with Table 1.8-1 they are designated as Seismic Cate-gory II.
Table 1.8-1 states in part that Seismic Category II equipment "shall either be seismically designed, located to pre-clude interactions, further restrained, structurally upgraded or proven incapable of affecting safety."
Design of the monorails and their supports conforms with Seismic Category II requirements, as follows:
(a) location of Trolleys to Preclude Interacti_on Of the 23 monorails that are installed in Category I areas, 8 are installed over safety-related equipment. These monorails are intended to be in use only during the mointenance of the equipment below them.
For tnose that art installed over safety-related equipment only, administrative controls (e.g.,
rail stops, locks, removal of trolleys, etc.) will be utti-ized to ensure that the monorail trolleys are stored to pre-clude postul ated fa il ure which may adversaly affect the safety-related components beneath them.
2BVM-165, " Hazards Analysis Program," which provides guidelines for systematic evaluation and disposition of potentially unacceptable seis-mic interactions, will be revised to document this eval u-atton.
L
United States Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 4 (b) Design of Embedment Plates By locating the trolleys to preclude interaction with safety-related components, only the weight of the monorail system (track and trolley) need be considered when designing the embedment plates to make them incapable of affecting safety.
Monorail 2MHP-CRN220A will be used as an example of the embed.aent plate design since it was cited as example by the NRC inspector in Appendix B of Inspection Report No. 50-412/
85-25.
The structural embedment pl ates that support the monorail system were designed to support the dead weight of the mono-rail track and trolley plus the full capacity rated load -of the hoist.
For 2MHP-CRN220A, the embedment plates have been sized to support 12,500 lbs.
(Ref. SWEC file No.
2002.580-Ol7-036J), of which 2,500 lbs.
is the dead weight of the monorail system and 10,000 lbs. is the total load (Ref.
Specification 28VS-17).
Each of the four embedment plates that support CRN220A is designed to support this entire load (Ref. SWEC calculation book SCF Volume I, page C36.93C-S).
With the trolley in its stored location, the embedment plate with the highest load will see 1/4 of the monorail track weight (1,000 lbs.) plus the weight of the trolley (1,500 lbs.).
Therefore, during operation of the charging pumps, this embedment plate has a safety factor of more than 7 to 1, and would withstand a seismic event without fail ure that could affect a safety-related component.
(c) Design o_f Mono _ rail Tracks In accordance with page 1-14 of Specification 23VS-17, all load carrying parts such as track, fittings, and hangers were designed by the manufacturer, so that the stress in the mat-erial does not exceed 20 percent of the ultimate strength of the material when lifting the rated loads.
This means that for CRN220A, each component of the vendor supplied monorail was designed to support 5 x 10,000 lbs. plus 2,500 lbs., or 52,500 lbs.
Again, considering the weight of the monorail system alone, with the trolley in its stored location, the monorail track has a safety factor of more than 29 to 1.
This ensures that the track will withstand a seismic event without a failure that would affect a safety-related compon-ent.
In addition, prior to erection, all monorails were dynamically loaded to 125 percent of their rated load by the manufacturer. Also, after installation and operational test-ing, all of these monorails have been or will be field tested to 125 percent of their rated load, i
}
United States Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 5 (2) Monorail designation of QA Category III is consistent with FSAR Section 3.2.2.3, since the monorails are not required for safe shutdown or the reliable generation of electrical power.
Pertinent portions of 10CFR50 Appendix B are addressed as follows:
(a)ApprovedVendors ACC0 Louden, the monorail manufacturer, was at the time of purchase an approved vendor for QA Category III Holst and Monorail Systems.
(b) Vendor's QA Program In accordance with the BVPS-2 project manual (Section D. Item
- 33) and page 1-30 of Specification 2BVS-17, ACC0 Louden was required to have an inspection, testing, and documentation program that ensured the monorails meet all of the require-ments of Specification 2BVS-17.
ACC0 Louden has previously bullt their equipment to various written documents which specified their quality requirements. Originally these docu-ments were known as "S tandard Practice Instructions" and
" Manufacturing Support Procedures."
In 1983, these instruc-tions and procedures were the basis for the " Quality Assur-ance Manual" of ACC0's Crane -and Monorail System Division, which included the Louden product line.
Presently, the mat-erial handling group of ACC0 Babcock, Inc., is the parent organization for the Louden products.
The Louden patented track and other ACC0 lines are covered under a single " Qual-ity Control and Inspection Manual " which meets the U.S.
Government's inspection system requirements, MIL I 45208.
QA records, which are maintained by SWEC, document the pro-curement and installation of the monorails.
These records are controlled in accordance with SWEC's Engineering Assur-ance Procedures.
(c) Inspection Requirements SQC will perform a 100 percent weld inspection of all mono-rails installed above safety-related equipment.
These par-ticular monorails will be identified in the committed revi-sion to 2BVM-165 mentioned earlier.
Any deviations from the applicable welding codes will be identified through the Non-conformance and Disposition Report System.
This action will be completed by March 28, 1986.
United States Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 6 In conclusion, the BVPS-2 monorail systems have been adequately designed to withstand a seismic event such that they are incapable of adversely affecting any safety-related components.
The quality assurance elements applied, in conjunction with the commitment to perform an inspection of the welds on monorails located above safety-rel ated equipment satisfy compliance with requirements of Regulatory Guide 1.29, Rev. 3.
DUQUESE LIGHT COMPANY f
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By J( f. G rby f'
l Vice President RWF/wjs cc: Mr. P. Tam, Project Manager Mr. G. Walton, NRC Resident Inspector
>S BSGRIBED ANpMORN TO BEFORE IE
/sfzDAY OF C hLyns,Y,1986.
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United States Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief USNRC IE Inspection Report 50-412/85-25 Page 7 I
COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF
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i On this ((.
day of d,1(tfurf_
_,/fh___,beforeme,a Notary Public in and for said (ommonwealt[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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