ML20205J019

Responds to NRC Re Violations Noted in Insp Repts 50-412/86-47.Corrective Actions:Walkdown of Cable Reel Storage & Staging Areas Performed to Check Cable End Seal Integrity.Qc Insp Program for Storage Technically Adequate

ML20205J019
Person / Time
Site:	Beaver Valley
Issue date:	03/16/1987
From:	Carey J DUQUESNE LIGHT CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
2NRC-7-051, 2NRC-7-51, NUDOCS 8704010194
Download: ML20205J019 (9)

Text

'Af M 2NRC-7-051 Beaver Valley No. 2 Unit Project Organization S.E.G. Building Telecopy 4 64b 00 Ext.160 P.O. Box 328 March 16, 1987 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Steward D. Ebneter, Director Division of Reactor Safety

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/86-47

REFERENCE:

Letter dated February, 13,1987 (S. D. Ebr.eter to J. J. Carey)

Gentlemen:

The above referenced letter transmitted a Notice of Violation as Appendix A. Attachments 1 and 2 of this letter provide Duquesne Light Company's (DuC) response pursuant to the requiranents of 10CFR2.201 and the NRC's Notice of Vio-lation.

DUQUESNE LIGHT COMPANY By J. J. Carey Sr. Vice President LMR/ijt NR/lR/50412 Attachment cc: Mr. P. Tam, Project Manager (w/a)

Ms.

Mr. J. A.BealI, A. Asars, NRCNRC Senior Resident Residentinspector inspector(w/a)

(w /a)

NRC D0cument Control Desk (w/a) 8704010194 870316 PDH ADOCK 05000412 g.9 \

United States Nuclear Regulatory Conunission Mr. Steward D. Ebneter, DireGor Inspection Report 50-412/86-47 Page 2 COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF BEAVER )

On this /X, & day of I/ u < 4 > ,//9/ , before me, a Notary Public in and for said Commonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Senior 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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/ AA

/ / Notary Public ElVA G LESONDAK, NOTARY PUBLIC SUllVINGPORT, GEAVER COUNTY i

MY COMMISSION EXPIRES OCTOBER 20,1990 1

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f ATTACHMENT 1

! NOTICE OF VIOLATION 86-47-01 i  :

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{ 10 CFR 50, Appendix B, Cr iterion X111 states in part that " measures shall be

) established to control the handling, storage, shipping, cleaning and preservation  ;

i of material and equipment in accordance with work and inspection instructions to l prevent damage or deterioration."

Ouquesne Light Company Electrical Installation Specification, 2BVS 931, Sections  !

1.16.16 states in part that "All covers, caps, plugs or other closures shall be )

intact--covers or closures removed---shall be promptly replaced---preservatives j and coatings shall be in place and intact. If reapplication is requir ed only i' previously approved preservative material shall be used."

j Duquesne Light Company Field Construction Pr ocedure for Permanent Plant Cable }

Receiving, Storage, and Handling, FCP-430, Section 5.4.1 states in part that "All  :

- ends of insulated cable in storage---shall be sealed to exclude moisture and cut <

l ends shall be immediately resealed. Cable sealing shall be by taping with water- ,

i proof tapes and painting taped seal with insulating varnish, General Electric .

Company 'Glyptal', ' Scotch IVI Spray Sealer'. Heat shrinkable caps or tubing of ,

proper size may also be used for sealing."

Contrary to the above, a sanple inspection of 50 cable reels in outside Storage Location "P" disclosed that 18 of the reels either had exposed cut cable ends with no protective cap or the tape was frayed or gaping open to expose the cable i

end to moisture. Painting of the taped seals with "glyptal" or any other protec- l l tive var nish had been discontinued.  ;

This is a Severity Level IV violation (Supplement 11).

I R,esponse [

) Upon notification of this violation, the following actions were taken:

J l 1. Constr uction immediately per formed a walkdown of the cable v eel storage and

! staging areas to check cable end seal integrity. Those cables requiring new

! end seals or repairs were r eworked during the walkdown. A list of cable ,

reels not used since 1982 was given to the Engineers for review. Cable ends I wer e taken, on a random basis by cable type, from reels in the storage areas  ;

] and given to Engineering to be tested. Verbal instructions were given to '

i construction electrical supervision to caution their craf tsmen about the l required procedur e. To enphasize and r einforce the progran r equirenents,  ;

i changes to FCP-430 and FCP-431 were issued on January 15, 1987. Formal i j training classes were then given to the electrical craf tsmen and supervisors. I j A Cable End Surveillance Progran was established under which the Storage (

! Maintenance Coordinator, QC inspector, and an electrician regularly check i j cable end seal integrity and maintain a record log of those checks. [

l Since issuance of N&D-38863A, Construction has been reverifying compliance j to the N&D directions. This will be completed for all cable reels requir ed a for the emaining plant cable pulling activities by March 13, 1987.

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ATTACHMENT 1 (continued)

NOTICE OF VIOLATION 86-47-01

2. SQC per formed an independent verification of the cable end caps on cable reels in the storage yards. Unsatisf actory findings were identified on N&D-38863A.

3. Engineering evaluated the cable reel conditions, had the sample cable ends tested, and provided the Engineering position and technical analysis in the disposition to N&D-38863A.

ATTACHMENT 2 NOTICE OF VIOLATION 86-47-02 10 CFR 50, Appendix B, Criterion X, states in part, that "A progran for inspec-tion of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the document-ed instructions, proteoures and drawings for accomplishing the activity. Such inspections shall be performed by individuals other than those who performed the activity being inspected."

Duquesne Light Company Site Quality Control Procedure No. SQC-5.2 " Storage Inspection Program - Designated Storage Areas" paragraph 1.1 states in part that "This procedure shall establish methods by which SQC shall verify compliance with Project Engineering requirements for designated storage facilities and for itens stored in these areas."

Contrary to the above, Duquesne Light Company SQC Inspection Procedure, IP-5.2 currently in use for audit inspections of the outside cable storage area "P" does not provide sufficient visibility of the overall storage area to detect gross breakdowns in protection of the stored cable since it requires inspection of only one type of cable per inspection period.

This was confirmed by a review of recent Duquesne Light Company inspection of storage location "P" using SQC-IP-5.2 as the reference inspection procedure.

Inspection reports reviewed include MC-5394 dated Septenber 17, 1986 and MC-5462 dated October 30, 1986.

This is a Severity Level IV violation (Supplement 11).

Response

The QC pr ogi am of stor age inspection is one of sur veil lance. The program provides for three types of inspections: a) Area inspections; b) lten inspec-tions; and c) Storage system inspections. Two QC pr ocedures are involved in

implementing this sur veillance program, SQC-5.2, " Storage Inspection Progran -

! Designated Storage At eas," and Inspection Plan IP-5.2.1, " Storage Inspection -

Designated Storage Areas." As the NRC Inspector only references procedure SQC-5.2 in his comments, some question renains as to whether his inspection included a review of the instr uctions given in IP-5.2.1.

Pr ocedure SQC-5.2 provides generic instructions pertaining to the approach to performing the sur veillance of storage; i.e., Area, Iten and Systen inspections.

I Area inspection There ar e 22 designated stor age areas which are randomly assigned to be surveyed each day of the month. As storage inspection is presently conducted appioximate-ly 30 days each month, some areas are inspected more than once a month. IP-5.2.1 would pr ovide the attributes to be applied during an area inspection. At the time of the NRC inspection, the attr ibutes for area inspection dealt exclusively with ver ifying ielative ANSI storage iequirenents as well as other established housekeeping, material identification and safety requirenents, i

ATTACHKENT 2 (continued)

NOTICE OF VIOLATION 86-47-02 Item inspection i There are 24 generic iten categories which are randomly assigned to be surveyed a

in a similar manner to the area inspections noted previously. Examples of iten categories are Welding Materials, Motors and Generators, Pumps, Valves and Cable Raceway Components. IP-5.2.1 would provide the attributes to be applied during an iten inspection. Included in these attributes is MC-40, Verify - Tapes prop-i erly applied. Additionally, the' Inspector is required to review specific 4

storage / maintenance requirements for the item and apply them to his inspection.

i System inspection 3

A systen inspection involves a detailed review of all documentation associated

! with an item to verify that pertinent handling, storage and maintenance require-j ments have been identified and accomplished. These inspections are assigned periodically by supervision.

) The specific NRC comments for this violation are as follows:

1. The inspection procedure did not have any criteria which would provide an i overview of the entire storage area to detect such deficiencies as unprotect-ed cable ends on a substantial number of cable reels. ,

l 2. The QA inspection checklist implementing the Engineering specification omitt-ed the cable end seal requirenent.

3. Other deficiencies of identical cable storage deficiencies of other locations on site were identified by QA Inspectors without root cause follow-up. The 1.

Licensee's trending program did not capture the repeated identified deficien-l cies..

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4. QA audits did not confirm the technical adequacy of the QC checklists.

) Response to NRC Comments 1 and 2 I The QC inspection checklist (referenced as QA inspection checklist by the NRC i Inspector) did not provide a specific attribute for the cable end seal require-j ment as it is impractical to develop a checklist which includes every specified i attribute for each specific iten contained in BV-2 storage areas. Storage Speci-l fication 2BVS-981 contains nearly 1000 pages of storage requirenents applicable to specific items. IP-5.2.1, as it pertains to surveillance of storage itens, does provide Attribute MC-40, Verify - Tapes properly applied, as well as provid-

, ing for the inclusion of storage and maintenance requirenents specific to the j iten under inspection.

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ATTACHMENT 2 (continued)

NOTICE OF VIOLATION 86-47-02 Owing to the varied types of itens and attributes to be found in project storage, the QC program for surveil lance should provide attention to certain generic attributes for storage while at the same time providing the Inspector with the means to review and apply specific attributes unique to individual items, where applicable. It is our contention that the QC progran for storage inspection meets this description. However, we do agree that certain unique itens, such as cable end protection, deserve increased attention, as compared to the degree of surveillance which might be applied to other itens. This is due to the fact that the condition which must be maintained is subject to f actors such as frequent oisturbance during storage or deterior ation with time. In response to this recognition, we added Attribute MC-52, Verify - Cable end seals, to the area inspection portion of our progran during the course of the NRC inspection. This attribute provides for the inspection of a minimum of 5 cable reels for end pro-tection and is to be appplied during all area inspections of storage areas where cable reels are maintained. Cable reels will continue to be covered under item inspections.

Additionally, a review was perforned by QC in order to identify other unique itens which should be enphasized during area inspection similar to cable end protection. As a result of this review, IP-5.2.1 will be revised to add Attri-bute MC-63, Verify - Motors, to the area inspection of the program. This revi-sion will be issued by 3/13/87. As with cable reels, motors will continue to be cover ed under item inspections.

Response to NRC Comment #3 i The "other deficiencies of cable end protection identified by QC in other loca-tions" refers to deficiencies identified by the QC Sur veillance Group (referenced as QA Inspectors by the NRC Inspector) during inspection of on-site storage areas locates in and around the permanent plant buildings. Cable reels have histor ically been stored in a number of these locations. This surveillance which involves daily walk-through inspections of all areas of the plant for items such as s;orage, general construction activities, clean zone maintenance and rework

presently involves two inspector s, but until early 1986, routinely involved five

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or ; ore Inspectors. Storage of cable and cable end protection are frequently surveyed by this gi oup.

For the 24-month construction period,1985 through 1986, 4,040 unsats were iden-tifled by this group with only 6 unsats being issued for deficient cable end protection (0.1%). In comparison to the number of reels surveyed and found to be sa*.isf actory during this period, the per centage of unsats for cable end pr otec-tion is additionally very low, in the opinion of the Inspectors and supervision r esponsible for this surveillance, the 6 unsats for cable end protection did not requir e evaluation for root cause or reporting to the Trend Committee.

ATTACHMENT 2 (continued)

, NOTICE OF VIOLATION 86-47-02 Response to NRC Coment #4 As stated previously, it is our contention that the QC inspection progran for storage is technically adequate. We have recognized the need to expand the pro-gran in ces tain areas and have described the actions taken in this respect. We do not feel that previously conducted QA Audits should have identified the QC stor age inspection progran as being technically inadequate.

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