ML20206F936
| ML20206F936 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/03/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-7-060, 2NRC-7-60, TAC-62931, NUDOCS 8704140401 | |
| Download: ML20206F936 (8) | |
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2NRC-7-060 Telephone (412) 303-6003 April 3, 1987 Nuclear Group P.o. Box 4 Shippingport, PA 15077-0004 April 3, 1987 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Villiam V. Johnston, Acting Director Division of Reactor Safety
REFERENCE:
Beaver Valley Power Station, Unit No. 2 Docket No. 50-412, License No. CPPR-105 Inspection Report 87-03 Gentlemen:
In response to your letter of March 10, 1987, the attached reply addresses your inspectors' concerns regarding the effectiveness of our Quality Assurance overview efforts observed during the January 12.16, 1987 inspection.
Ve regard this concern as a very serious matter and are anticipating your written evaluation of our responsa.
DUQUESNE LIGilT COMPANY 4
J.VJ. G'arcy V
Sr. Vice President
/jh Attachment cc: Mr. P. Tam, Project Manager (w/a)
Mr. J. M. Taylor, Director (3) (w/a)
Mr. J. Beall, Sr. Resident Inspector (w/a)
Mr. L. Prividy, NRC Resident Ir spector (w/a) 8704140401 870403 PDR ADOCK 05000412 s\\
PDR g
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s Page 1 Inspection Report No. 50-412/87-03 This response provides the Duquesne Light Company comments on NRC Inspection Report 50-412/87-03 conducted from January 12-16, 1987. These comments place on record our official position regarding the items discussed in this report.
In general, we found that the inspectors' conclusion regarding the effectiveness of our Quality Assurance Program is not justified.
The following response provides objective evidence to support our position for each of the four observations:
1.
Audits do not include an adequate level of observation of on-going activities and physical conditions.
Extract from Inspection Report:
Audits are oriented almost entirely to the review of documents, records, schedules and fulfillment of administrative requirements.
Some audits by nature are review of " paper". Audits DC-2-85-33, Electrical Installations; DC-2-85-29, Material Control and Rigging; and DC-2-86-29, Material control and Rigging, contained approximately 17 attributes for observations of ongoing activities or physical conditions from a total of 183 checklist attributes. An extreme example was Audit BV-1-86-02, Operations OC.
All of the 91 checklist attributes were for " paper" reviews.
This latter audit was of Unit 1.
However, the licensee plans the same type of audits during the operating phase of Unit 2.
Such " paper review" audits of material control (i.e.
varehousing, laydown areas, and storage) are not capable of identifying the cable storage deficiencies discussed in Inspection Report 50-412/87-02.
Response
The Duquesne Light Company Quality Assurance Unit performs various activities to verify compliance to quality requirements.
These activities are performed by different organizations.
Quality Control and Surveillance perform detailed inspections and verification of implementation of procedures.
Audits are performed per a documented audit schedule to verify overall program compliance including some activity verification in progress during the audits.
Audit checklists per ANSI N45.2.12-1977 are intended for use as a guide.
The Duquesne Light Company audit checklists identify attributes to guide the auditor with results of compliance to procedure and program verification indicated.
The auditor may vitness or review more items than identified in the attributes on the checklist to verify compliance.
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Page 2 Audits DC-2-85-29, DC-2-86-29 and DC-2-85-33 which were reviewed during this inspection are audits which were performed near the end of construction activities of BV-2.
The number of activities being performed during,the performance of the audits was limited. These audit. reports did in fact include several activities which were reviewed. These were described in the abstract and body of the report and in a four page surveillance report attached to the report of DC-2-85-33.
The total number of attributes in these audit checklists were 198 and the number of attributes for observations of ongoing activities or physical conditions was 43.
The conclusion that audits are almost entirely a review of documents, records, schedules and fulfillment of administrative requirements is incorrect. The audits include programmatic reviews and verification of implementation. A thorough review of past audits would show that audits are more than a paper review.
The review of Operations QC Audit BV-1-86-02 cannot be used to evaluate the type of audit performed of material control activities.
To evaluate material control overview efforts the audit of material control must be reviewed.
Any evaluation made of the Quality Assurance Program for effectiveness in assuring compliance to requirements must include a review of the entire program.
Both the auditing and surveillance activities and programs have to be reviewed.
A review of only one part of the program vill result in inaccurate conclusions.
2.
Corrective actions in one case did not extend beyond the immediate identified concerns.
Extract from Inspection Report The technical aspects of the corrective action associated with e
defect'ive velding of the heat exchangers was determined to be
' adequate. But it was noted that no effort was made by QA or other licensee technical groups to conduct a review of similar components at Unit 1 or of other components at Units 1 or 2 in order to determine if the vendor who had supplied the subject heat exchangers had manufactured similar items that were installed in the plants.
Response
A review of similar components provided. by the Vendor in question,
" Joseph Oats", was performed by Mr. A. F. Mosso, DLC/QA and Mr. T. C.
Heimel, DLC/ISI on 11/19/86.
Mr.
Mosso had consulted with
6 Page 3 Vestinghouse and was informed that only the Regenerative Heat Exchanger and Let Down Heat Exchanger had been supplied by " Joseph Oats" for BV2.
The review of radiographs for the Let Down Heat Exchanger found all velds to be satisfactory.
Subsequent to the review of the radiographs of the two heat exchangers purchased by Westinghouse from Joseph Oats, it was found that additional heat exchangers had been purchased from Joseph Oats by Stone & Vebster.
The vendor radiographs for these six heat exchangers, the four Recirculation Spray Coolers and the two Fuel Pool Heat Exchangers have been requested and vill be reviewed. It is anticipated that this review of the additional heat exchangers will be completed by April 10, 1987.
Review of Unit 1 equipment which was supplied by " Joseph Oats" was considered but it was decided that, due to the difference in manufacturing dates, code applicability, as well as 10 years of operating service, no further action was necessary.
3.
Quality Control surveillances in one case did not include review and verification of technical requirements.
Extract from Inspection Report The specific OC surveillance checklists that did' not include attributes addressing the protection and sealing of cable ends have been revised.
Discussions with cognizant personnel indicated that there is no intent to review other checklists, even on a sample basis, in order to determine if similar specification or technical requirements omissions exist elsewhere.
Response
Owing to the various types of items and attributes subject to BV2 storage requirements (Specification 2BVS-981 contains nearly 1,000 pages of storage requirements applicable to specific items) it is not practical to develop a OC inspection checklist which lists every specified attribute for each specific item in the program. The program concept for surveillance of this activity was designed to provide for " area inspections" and " item inspections" having certain generic attributes while, at the same time, providing the Inspector with the means to review and apply all attributes unique to individual items which are required by the specification.
In this respect, our program has been and remains technically adequate.
As noted by the Inspector, we did recognize the need to extend our program with respect to certain unique items such as cable end protection. This was due to our acknowledgment of the fact that the storage condition which must be maintained is subject to factors such as frequent disturbance during storage or deterioration with time I
Page 4 and, therefore, deserves increased attention as compared to the degree of surveillance which might be applied to other items.
In response to this we added a special attribute for " cable end protection" which is to be applied during " area inspection" of areas where cable reels are stored.
This revision was made while Inspection 50-412/86-47 was in progress.
It should be noted that inspection of cable end protection vill continue to be covered under-the " item inspection" portion of our program, as before.
As discussed with the Inspector during Inspection 50-412/87-03, it was our intention to review the listing and storage requirements of all other types of items in storage at BV2 in order to identify other unique items which require increased attention and should, therefore, be emphasized during " area inspections" similar to the cable end requirement. As a result of this review, Attribute MC-53, " Verify -
Motors", was added to the area inspection portion of our program.
Again it should be noted that motors will continue to be covered under the " item inspection" portion of our program, as before.
It is our assessment that the root cause of the failure of QC to identify the cable end deficiency problem in off-site storage areas was the philosophy of applying our program equally to all items in storage. We failed to recognize that certain unique items require increased attention as compared to the degree of surveillance which might be adequate for other items.
With respect to this assessment, we feel we have taken the necessary corrective action to correct the specific condition and have additionally reviewed the specification-and our program and have taken action to correct other omissions of similar nature.
4.
Trending reports often do not highlight recurring problems.
Extract from Inspection Report The semi-annual trending report uses numerous graphs and tables containing numbers of happenings, such as identified deficiencies.
Vast amounts of data are also included.
This report appears to be more of an activity report than a trending analysis. Various other:
trending efforts exist within specific groups. The entire collection of trending efforts failed to highlight that the Site QC Surveillance-group was continuously identifying problems with the storage and protection of cable reels.
It is also doubtful that the existing trending effort is coordinated so as to accomplish a comprehensive trending analysis.
Licensee management indicated that the shortcomings of their trending effort had been recognized and a revised program was placed in effect January 9,
1987 with the issuance of Procedure SOC-1.5, Trend Analysis and Corrective Action, dated January 12, 1987.
r Page 5
Response
i During the course of his inspection, the Inspector criticized our semi-annual QC departmental report as an ineffective trending tool.
We advised him, at that time, that this report is not intended, nor is it used for trending purposes. It is, in fact, an activity report compiled for management's review of QC programs and activities.
Our Quality Control trending program is conducted in accordance with Procedure S00-1.5, " Trend Analysis and Corrective Action". As noted by the Inspector, we had recently revised this program in order to extend the scope of Oc trend involvement into the Start-Up and Operations areas of activity.
The QC program was also expanded to include assignment and tracking of corrective action taken by responsible parties to correct adverse quality trends. The previous QC trend program was limited to the construction phase and identification of trends only (follow-up corrective action was handled through Site Construction Management Committees).
In the interest of improving our program, we have made additional revisions to SOC-1.5 subsequent to Inspection 50-412/87-03. Our program now identifies and tracks " Items of Potential Impact". These are defined as items identified by site correspondence or documents which require further evaluation with the possibility of having significant effect on the quality status of site structures and/or equipment.
We have added an additional category of -problem identification, " Concerns", which are defined as items which may develop into " Trends". Only " Trends" require assignment of specific corrective action.
- However,
" Concerns" are tracked in Trend Committee Meeting Minutes and these are distributed to-project and contractor management for advisement. Additionally, we require trend committee members to establish the QC identified root cause of all-
" Concerns" and " Trends" reported.
Since the inception of our revised program, we have identified eight (8) Trends and nine (9) Concerns.
No Trends have been closed while three (3) Concerns have been deleted with two of these being elevated to Trends.
As noted by the Inspector, deficiencies with respect to cable end protection and cable storage have been identified by the Site QC Surveillance Group.
This group conducts surveillance of on-site storage areas located in and around the permanent plant buildings.
Cable reels have historically been stored in a number of these locations. This surveillance activity which involves daily valk-through inspections of all areas of the plant for items such as storage, general construction activities, clean zone maintenance and rework presently involves two Inspectors, but until early 1986,
P~1 1
e Page 6 routinely involved five or more Inspectors.
Storage of cable and cable end protection are frequently surveyed by this. group.
For the 24-month construction period, 1985 through 1986, 4,040 unsats were identified by this group.
Of these, only 6 unsats (0.1%) vere issued for deficient cable end. protection and a total of only 33 unsats (0.8%) were issued for cable storage deficiencies of all types (deficient end protection, reels not on dunnage, reels not covered).
In comparison to the frequency of surveillance applied to these items and the number of reels surveyed and found to be satisfactory, the percentage of unsats identified is additionally very lov.
In the opinion of the Inspectors and supervision responsible for this surveillance, the number of unsats identified did not require evaluation for root cause or reporting to the Trend Committee.
Based on the above facts, Duquesne Light does not agree with the NRC conclusion that the QA Program has serious weaknesses and is not fully effective. This conclusion was in no way' conveyed to the people who were-interviewed nor was it expressed at the exit meeting held January 16, 1987.
The statement made by the Inspector was that while some items would be followed up in future inspections, there was. nothing found that would adversely affect the Safety Evaluation Report that would be submitted to Region I management.
We request that this response be evaluated before the conclusions of this inspection are factored into the SALP evaluation.
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