Text

Forwards SALP Rept 50-412/85-98 on 860512.Addl Info for Functional Area 8 Re Preoperational/Startup Testing Noted in Util 860814 Response
	ML20206T006
Person / Time
Site:	Beaver Valley
Issue date:	09/15/1986
From:	Murley T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carey J; DUQUESNE LIGHT CO.
References
	NUDOCS 8609230072
	Download: ML20206T006 (5)
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SEP 151986

Docket No. 50-412

Duquesne Light Company

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ATTN: Mr. J. J. Carey

Vice President

Nuclear Group.

Post Office Box 4

Shippingport, Pennsylvania 15077

Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Report No.

50-412/85-98

This letter refers to the SALP evaluation of Beaver Valley Unit 2 conducted by the

NRC staff on May 12, 1986.

This report was discussed in a meeting held on July

9, 1986.at the Beaver Valley site.

The list of attendees is attached as Enclosure 1.

The NRC SALP Report is provided

as Enclosure 2.

Our letter dated July 2, 1986 (Enclosure 3) forwarded the SALP

Board Report and solicited comments within 30 days of the July 9 meeting.

Your

response of August 14, 1986 is attached as Enclosure 4.

Your August 14 response has been reviewed and your clarifications and additional

information for Functional Area No. 8, "Preoperational/Startup Testing," are ap-

preciated and have been noted.

Based on these responses and dialogue during the

July 9 meeting, no changes to the SALP Report are considered appropriate.

We also

noted your responses concerning actions taken or planned to be taken to address

several of our concerns in Functional Areas 2, 4, 5, 6, and 9.

Finally, in re-

sponse to our concern that review and control activities are too narrowly focused

on "back-end" activities rather than " front-end" activities, project initiatives

discussed in your letter should help to improve your aggressiveness in self-iden-

tification of problems during " front-end" activities.

Our overall assessment of your facility has n$ted improvement from our last SALP

assessment.

Licensee / contractor activities initiated in response to weaknesses

noted in previous SALP assessments have generally helped to resolve such problems.

Specifically, management attention and involvement have resulted in Category 1

assessments in four Functional Areas. We encourage your continued management at-

tention to provide for feedback and ongoing evaluation of your activities.

We believe that the interchange of information at our meeting was beneficial and

improved our mutual understanding of your activities and the regulatory program.

I

No reply to this letter is necessary.

Your actions in response to the NRC SALP-

program will be reviewed during future inspections of your facility.

8609230072 860915

PDR

ADOCK 05000412

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Duquesne Light Company

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SEP 151986

Your cooperation is appreciated.

Sincerely,

Original bigned by

Thomas E. Murley

Regional Administrator

Enclosures:

1.

SALP Management Meeting Attendees

2.

Region I SALP Report 50-412/85-98 dated May 12, 1986

3.

Region I Letter, T. Murley to J. Carey, dated July 2,1986

4.

Duquesne Light Company Letter, J. Carey to T. Murley, dated

August 14, 1986

cc w/encls:

E. J. Woolever, Vice President, Special Projects

E. Ewing, Quality Assurance Manager

R. J. Swiderski, Manager, Startup Group

J. P. Thomas, Manager, Engineering

R. E. Martin, Manager, Regulatory Affairs

C. O. Richardson, Stone and Webster Engineering Corporation

Chairman Zech

Commissioner Roberts

Commissioner Asselstine

Commissioner Bernthal

Commissioner Carr

Vandana Mathur, McGraw-Hill Publications (2 copies)

AP - News Desk (2 copies)

Ernest Tollerson, Inquirer-Trenton Bureau (2 copies)

Gabe Ireton, Pittsburgh Post-Gazette (2 copies)

Steve Weiss, Beaver County Times (2 copies)

Art McGuire, Construction Industry Litigation Reporter (2 copies)

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

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Duquesne Light Company

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SEP 151996

bec w/ enc 1:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief

W. Troskoski, SRI, BV-1

P. Tam, NRR

T. Martin, DRSS

S. Ebneter, DRS

Robert J. Bores, DRSS

T. Murley, RI

J. Allan, RI

K. Abraham, RI (2 copies)

Management Meeting Attendees

E. Wenzinger, DRP

W._Kane, DRP

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0FFICIAL RECORD COPY

SEE PREVIOUS CONCURRENCE PAGE.

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SEP 15 5

bec w/ encl:

Region I. Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief

W. Troskoski, SRI, BV-1

P. Tam, NRR

T. Martin, DRSS

S. Ebneter, DRS

Robert J. Bores, DRSS

T. Murley, RI

K. Abraham, RI (2 copies)

Management heet ng Attendees

E. Wenzinger, D

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W. Kane, DRP

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ENCLOSURE 1

SALP MANAGEMENT MEETING ATTENDEES

BEAVER VALLEY UNIT 2

JULY 9, 1986

1.

Licensee Attendees

Duquesne Light Company

J. Arthur, Chairman of the Board

J. Carey, Vice President, Nuclear Group

R. Coupland, Director, Site Quality Control

C. Ewing, Manager, Quality Assurance

J. Hultz, Technical Assistant to Vice President, Nuclear

J. Martin, Manager, Regulatory Affairs

J. Sasala, Director, Nuclear Communications

R. Swiderski, Manager, Startup Group

J. Thomas, Manager, Engineering

N. Tonet, Manager, Nuclear Engineering and Construction Unit

R. Wa11auer, Lead Compliance Engineer

Stone and Webster Engineerina Corporation

W. Bohlke, Manager, Projects

H. Durkin, Superintendent, Engineering

H. Foley, Project Manager

J. Purcell, Assistant Project Manager, Engineering

H. Rashid, Assistant Project Manager

C. Richardson, Project Engineer

P. Wild, Executive Vice President

2.

NRC Attendees

T. Murley, Regional Administrator

L. Tripp, Chief, Reactor Projects Section 3A

W. Troskoski, Senior Resident Inspector

L. Prividy, Resident Inspector

A. Asars, Resident Inspector

L. Rubenstein, Acting Deputy Director, PWR-A

P. Tam, Project Manager

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ENCLOSURE 2

- U.S.- NUCLEAR REGULATORY COMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

REPORT 50-412/85-98

DUQUESNE LIGHT COMPANY

BEAVER VALLEY POWER STATION, UNIT 2

(Construction Phase)

ASSESSMENT PERIOD:

APRIL 1, 1985 - MARCH 31, 1986

BOARD MEETING.DATE:

MAY 12, 1986

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TABLE OF CONTENTS

PAGE

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INTRODUCTION.........................................................

1

1.

Purpose and 0verview............................................

1

2.

SALP Board and Attendees........................................

1

3.

Background......................................................

1

II.

CRITERIA.............................................................

5

III. SUMMARY OF RESULTS...................................................

7

1.

Facility Performance............................................

7

2.

Overall Facility Evaluation.....................................

7

IV.

PERFORMANCE ANALYSIS.................................................

9

1.

Containment and Other Safety Related Structures.................

9

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2.

Piping Systems and Supports.....................................

11

3.

Safety Related Components.......................................

14

4.

Support Systems.................................................

16

5.

Electrical Power Supply and Distribution........................

18

6.

Instrumentation and Control

Systems.............................

21

7.

Licensing Activities............................................

23

8.

Preoperational/Startup Testing..................................

26

9.

Assurance of Quality............................................

29

V.

SUPPORTING DATA AND SUMMARIES........................................

32

1.

Construction Deficiency Reports (CDRs). . . . . . . . . . . . . . . . . . . . . . . . . .

32

2.

Investigation Activities........................................

32

3.

Escalated Enforcement Actions...................................

32

4.

Management Conferences..........................................

32

TABLES

Table 1 - Construction Deficiency Reports

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Table 2 - Violations (Summary)

Table 3 - Inspection Hours Summary

Table 4 - Inspection Activities

ATTACHMENT

Attachment 1 - Enforcement Data

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I.

INTRODUCTION

1.

Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an integrated

NRC staff effort to collect the available observations on a periodic

basis and evaluate licensee performance based on those observations with

the objectives of improving the NRC Regulatory Program and licensee per-

formance.

The assessment period is April 1, 1985 through March 31, 1986.

The prior

assessment period was April 1, 1984 through March 31, 1985.

Significant

findings from prior assessments are discussed in the applicable Perform-

ance Analysis (Section IV) functional areas.

Evaluation criteria used

during this assessment are discussed in Section II below.

Each criterion

was applied using the " Attributes for Assessment of Licensee Performance,"

contained in the NRC Manual Chapter 0516.

2.

SALP Board and Attendees

R. Starostecki, Director, Division of Reactor Projects (DRP) and SALP

Board Chairman

W. Johnston, Deputy Director, Division of Reactor Safety (DRS)

T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS)

W. Kane, Deputy Director, DRP

L. Rubenstein, Acting Deputy Director, PWR A, NRR

E. Wenzinger, Chief, Projects Branch No. 3, DRP

J. Durr, Chief, Engineering Branch, DRS

L. Tripp, Chief, Reactor Projects Section 3A, DRP

P. Tam, Licensing Project Manager, NRR

Other Attendees

L. Prividy, Resident Inspector, Beaver Valley Unit 2

R. Urban, Reactor Engineer, DRP

3.

Background

Duquesne Light Company was issued a Construction Permit (CPPR-105) to

build Beaver Valley, Unit 2, (Docket No. 50-412) on May 3, 1974.

The

Nuclear Steam Supply System (NSSS) is a 2660 MWt Westinghouse PWR with

three loops; the Architect / Engineer (A/E) is Stone and Webster.

At the

end of this assessment period, fuel load was scheduled for May 1987.

Construction was estimated by the licensee as 93.6 percent complete as

of March 31, 1986.

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a.

Licensee Activities

In general, the work force increased in all areas during the as-

sessment period.

On March 31, 1985, there were 2,338 craft workers,

compared to 2,845 eraft workers on March 31, 1986; an-increase of

21 percent. Total second and third shift activity increased from

570 to 630 during this period. Weekend activity increased from an

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average of 5 to 1050 workers total per day (mostly Saturdays).

The

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licensee's Quality Control Department staffing increased from 361

to 450, an increase of 24 percent.

Stone and Webster supervisory,

engineering and administrative personnel on site increased 5 percent;

from 650 to 683 people.

At the end of the assessment period, Stone

and Webster senior engineers in all disciplines were located on site.

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Early in the assessment period, the licensee retained the services

of the Management Analysis Corporation to review the project organi-

zation and to provide recommendations on the desirability of adding

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additional key personnel to assist in the completion of the project.

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As a result of this review, Duquesne Light Company made significant

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changes in the project organization in December, 1985.

Several

new positions were created and these positions were filled by ex-

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perienced individuals.

The Manager of Engineering and Construction

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was assigned to the site to report to the Vice President - Nuclear

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Group on all matters relating to Engineering, Construction Cost

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and Schedule. A Deputy Manager of Quality Assurance was assigned

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to the project with responsibility for QA/QC of startup activities

and reports to the Manager of Quality Assurance.

Coordinated with

these management changes was the relocation to the site of the

Duquesne Light Company Nuclear Construction Division.

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During this assessment period, the major construction activities

included installation, welding, examinations, flushing and hydro-

static testing of main steam, feedwater, residual heat removal,

safety injection systems, and other large and small bore piping and

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supports; heating, ventilation, and air conditioning and fire pro-

tection systems continued to be installed; pumps, motors, control

panels and residual heat removal pumps and motors were installed

and connected.

Electrical cable trays were installed and signifi-

cant amounts of cable were pulled and terminated plus instrumenta-

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tion sensing lines and associated hardware were installed.

Insula-

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tion of tanks and piping continued during this assessment period.

Painting / coating occurred throughout the site.

Closure of the tem-

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porary construction opening in the containment building's exterior

wall was accomplished in October 1985.

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Transition of the project from the construction to the testing phase

progressed steadily during the assessment period with system turn-

overs keyed to several major milestones - steam generator secondary

side hydrostatic test (December 1985), initial operation of diesel

generators (December 1985), and reactor coolant system cold hydro-

static test.

As of March 31, 1986, of the total 473 subsystems

required to be turned over, 292 subsystems have been turned over

and accepted by the Duquesne Light Company Startup Group for proof

testing.

Preparations were being made at the end of the assessment

period to conduct the reactor coolant system cold hydrostatic test

in April 1986,

b.

Inspection Activities

One NRC senior resident inspector and one resident inspector were

assigned to Beaver Valley Power S%ation, Unit 2, for the entire

assessment period.

Also, the t;PC senior resident inspector assigned

to Unit 1 devoted part of his inspection efforts to the test program

activities at Unit 2.

Resident inspector activities included the

accomplishment of assigned inspection requirements including obser-

vations of work in progress, follow-up of licensee events, reactive

inspections and evaluation of licensee responses to NRC identified

concerns.

Twenty-three inspections were performed during the assessment period;

eleven were independently conducted by resident inspectors and

twelve were conducted by region-based specialist inspectors.

There

were 2,444 hours0.00514 days 0.123 hours 7.34127e-4 weeks 1.68942e-4 months of inspection of which 1,775 were by the resident

inspectors and 669 were by region-based specialists.

The specialist

inspection activities were in the following areas: concrete con-

struction pertinent to the containment building's exterior wall,

preservice inspection program including welding and welder qualifi-

cation, structural supports, electrical and piping supports, in-

stallation of mechanical equipment, installation of instrumentation

and electrical equipment, installation of 125 V DC systems, preven-

tive maintenance program for the emergency diesel generators and

associated equipment, the quality assurance program for preopera-

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tional testing, and a review of the preoperational test programs.

c.

Licensing Activities

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The Safety Evaluation Report was issued in October, 1985, in advance

of the ACRS full committee hearing which was held on November 8,

1985.

Prior to the ACRS full committee hearing, the Beaver Valley,

Unit 2 Subcommittee met on October 31 and November 1, 1985.

At that

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time, the NRR staff had identified 11 open issues and 44 confirma-

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tory issues.

Since the ACRS meeting, NRR and DLC Licensing Division

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personnel have continued correspondence and meetings to resolve many

of these issues.

This included site visits made by NRR personnel

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to observe the actual installed condition of the hardware.

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II.

CRITERIA

Licensee performance is assessed in selected functional areas, depending on

whether the facility is.in a construction, preoperational or operating phase.

Each functional area normally~ represents areas significant to nuclear safety

and the environment, and are normal programmatic areas.

Special areas may

be added to highlight significant observations.

The following evaluation criteria were used to assess each functional area.

1.

Management involvement and control is assuring quality.

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2.

Approach to resolution of technical issues from a safety standpoint.

3.

Responsiveness to NRC initiatives.

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4.

Enforcement history.

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5.

Reporting and analysis of reportable events.

6.

Staffing (including management).

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Training and qualification effectiveness.

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Based upon the SALP Board assessment, each functional area evaluated is clas-

sified into one of three performance categories.

The definitions of these-

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performance _ categories are:

Category 1.

Reduced NRC attention may be appropriate.

Licensee management

attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used so that a high level of

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performance with respect to operational safety or construction is being

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achieved.

Category 2.

NRC attention should be maintained at normal levels.

Licensee

management attention and involvement are evident and are concerned with nuc-

lear safety; licensee resources are adequate and reasonably effective so that

satisfactory performance with respect to operational safety or construction

is being achieved.

Category 3.

Both NRC and licensee attention should be increased.

Licensee

management attention or involvement is acceptable and considers nuclear safety,

f-

but weaknesses are evident; licensee resources appear to be strained or not

effectively used so that minimally satisfactory performance with respect to

operational safety or construction is being achieved.

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The SALP Board also assessed each functional area to compare the licensee's

performance during the last quarter of the assessment period to that during

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the entire period in order to determine the recent trend for each functional

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area.

The trend categories used by the SALP Board are as follows:

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Improving:

Licensee performance has generally improved over the last quarter

of the current SALP assessment period.

Consistent:

Licensee performance has remained essentially constant over the

last quarter of the current SALP assessment period.

Declining:

Licensee performance has generally declined over the last quarter

of the current SALP assessment period.

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III. SupMARY OF RESULTS

1.

Facility Performance

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Category

Last Period

This Period

(4/1/84-

(4/1/85-

Recent

Functional Area

3/31/85)

3/31/86)

Trend

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1.

Containment and Other Safety-

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Related Structures

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Consistent-

2.

Piping Systems and Supports

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Consistent

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3.

Safety-Related Components

1

Consistent

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4.

Support Systems

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2

Consistent

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5.

Electrical Power Supply

and Distribution

2

Consistent

6.

Instrumentation and Control

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Systems

2

1

Consistent

7.

Licensing Activities

2

1

Improving

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8.

Preoperational/Startup

Insufficient

Testing

2

Basis

9.

Assurance of Quality

2

Consistent

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2.

Overall Facility Evaluation

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Some improvement in the overall level of performance was demonstrated

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during this assessment period.

Licensee / contractor activities initiated

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in response to weaknesses noted in previous SALP assessments have gener-

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ally helped achieve resolution of such problems.

These initiatives in-

clude the Integrated Construction Support Group (ICSG), Constructability

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Review Teams (CRTs), Engineering Confirmation Program, Qual!ty Improve-

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ment Management Program (QIMP), establishment of a separate Quality As-

surance Group responsible for QA/QC of startup activities, adding a new

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position to be responsible for Engineering and Construction, and use of

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an Electrical Plan to track and resolve outstanding electrical /instru-

mentation problems.

Such programs appear to have been successful in

responding to programmatic NRC concerns.

Notwithstanding the above, individual problems were noted in several

functional areas during this assessment period which indicate that more

attention to detail is needed by workers in many departments (i.e., En-

gineering, QC, craftsmen, etc.).

Collectively, these problems indicate

that additional attention and/or overview is needed before higher level

performance can be sustained in several functional areas.

Although the licensee has shown more initiative during this assessment

period in self-identification of problems, such as through the MAC re-

views, most licensee initiatives were triggered by NRC expressed con-

cerns.

NRC continues to identify problems that should have been identi-

fled and/or prevented by licensee controls.

Licensee evaluation, re-

solution, and followup in response to NRC identified concerns is typic-

ally very thorough.

However, licensee overall review and control acti-

vities are too narrowly focused on "backend" activities (i.e., QC in-

spection to assure that installation is in accordance with specifications

and drawings).

"Frontend" activities that are often the root causes of

problems do not always receive adequate review and management attention.

For example, more emphasis should be placed on whether design /installa-

tion meets criteria and is capable of performing its intended function

satisfactorily. More licensee aggressiveness in self-identification of

problems with "frontend" activities should improve performance.

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IV.

PERFORMANCE ANALYSES

1.

Containment and Other Safety-Related Structures (4%, 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months )

a.

Analysis

No significant problems were noted in this area during the prior

assessment period. Work on containment and other safety-related

structures was generally of good quality.

The licensee was thorough

in followup corrective actions to NRC concerns by making required

repairs to containment electrical penetration welds.

Three inspections were made in this area during this period.

The

major work activity performed during this assessment period was the

closing of the containment building temporary construction access

opening.

The opening (30 feet by 31 feet) required welding in the

containment liner and associated nondestructive examinations, in-

stallation of reinforcing bar and cadwelding to existing bars, and

pouring of the concrete to form the wall.

Concrete pours were com-

pleted in October 1985.

NRC found that excellent controls were

exercised during this assessment period with no major problems ex-

perienced.

The work activities in this area are now substantially-

complete.

One instance was identified which indicated a possible weakness in

the licensee's involvement in the design review process.

The NRC

expressed a concern that the 12-inch stagger of Cadweld mechanical

splices between adjacent rebar in the temporary construction opening

wall did not meet the more conservative stagger criteria given in

the FSAR and that this change should be supported by engineering

analysis.

The licensee is in the process of addressing this concern.

Licensee actions demonstrated responsibility and assured management

involvement and control.

This was evident in the effective licensee

action to oversee the quality of the remaining concrete used onsite.

An offsite batch plant was utilized for concrete placements to close

the containment building temporary construction access opening.

The licensee provided for proper qualification of this offsite batch

plant to supply concrete in accordance with engineering specifica-

tions.

Another indication of licensee involvement and control in

assuring quality was the licensee evaluation program relating to

loosened expansion anchors.

In a prior assessment period (December

1, 1982 through March 31, 1984), the NRC had identified a concern

in this area since there was a lack of a formal procedure for con-

trol of Hilti expansion anchors following a loosening or removal

of bolt nuts or baseplates during construction.

The licensee in-

stituted a positive program to ensure that any future baseplates

which were loosened by construction would have anchor bolts re-

torqued and witnessed by QC.

Existing supports with associated

Hilti anchor bolts were evaluated by a systematic statistical

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sampling program with appropriate retorquing in selected areas.

The licensee performed a 100 percent reinspection of supports with

other types of bolting.

Licensee actions in this area have been

effective.

In summary, this area has shown consistent management involvement

and controls. The licensee has exercised proper controls as the

project has progressed such that no major problems occurred this

period.

b.

Conclusion

Category 1, Consistent.

c.

Board Recommendation

Licensee

None.

NRC

No further evaluations are needed in this functional area.

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Piping Systems and Supports (25%, 606 hours0.00701 days 0.168 hours 0.001 weeks 2.30583e-4 months )

a.

Background

During prior assessment periods, the licensee and Stone and Webster

implemented numerous programs in the engineering area to address

concerns identified in those assessments.

This included the forma-

tion by Stone and Webster Engineering of the " Integrated Construc-

tion Support Group (ICSG)" made up of engineers located in the Con-

struction Buildings to provide easier access and instructions to

the construction personnel. Another program implemented by Stone

and Webster Engineering was the "Constructability Review Team (CRT)",

to review mechanical and electrical drawings and assure they were

precise and clear. A third program titled " Engineering Confirmation

Program", involved both Stone and Webster Engineering and Duquesne

Light Engineering and was implemented to review engineering specifi-

cations, calculations and other technical concerns. A fourth pro-

gram titled " Quality Improvement Management Program (QIMP)" was im-

plemented to concentrate efforts and control on the_ amount of rework

on items such as piping and supports.

This effort was directed

toward items where trending indicated an increase in the reject rate.

The last SALP evaluation recognized these programs as strong cor-

rective actions that should be effective in eliminating past iden-

tified weaknesses.

However, at the time of that assessment, the

implementation was too recent to assess effectiveness of these in-

itiatives.

Implementation has now been in effect during this entire

assessment period.

During this assessment period, the licensee placed major emphasis

on the completion of piping and installation of the associated pipe

supports to support system turnover.

This effort has been effective

in the completion of many of the piping systems.

Some piping sup-

ports, however, still remain to be installed even though the pre-

liminary turnover of the system may have occurred.

Hydrostatic

testing has been completed on many of the major systems, including

the piping associated with the secondary side of the steam genera-

tors.

Flushing has also been routinely performed on many of the

piping systems,

b.

Analysis

This functional area received major inspection coverage.

NRC in-

spections placed particular emphasis on reviews of the ICSG, CRT,

QIMP, and Engineering Confirmation Program to assess their effec-

tiveness in resolving and eliminating the Engineering / Construction

interface problems discussed in prior SALP assessments.

4

l

,

- - . . _

-. -- --

.- -

--

-

.. - , ---- , , - _ _ _ . - - . , , _ ,

--

.

--

.

-

..-

-

.

- . -

- - .

{s-

-

12-

Major improvements have occurred as a result of the implementation

of the licensee and SWEC programs discussed above.

Generally, the

4

interpretation by construction of engineering drawings and specifi-

i

cations which could lead to construction problems was not a problem

'

this period.

This is attributed to the major past efforts of the

CRT, the strengthening of the Engineering / Construction interface

by ICSG personnel and updating of specifications.

Also, good con-

trols were exercised in the areas'of weld material controls, radi-

ography, design and installation of Category II seismic supports,

and hydrostatic testing. Overall, quality of workmanship was found

to be very good as noted during considerable NRC inspections /obser-

vations.

Records to support the installation were also found to

i

be acceptable.

Periodic interviews with the craftpersons have found

the workers morale positive regarding quality and no allegations

i

were made regarding piping and supports.

Overall management con-

trols in this functional area were considered to be acceptable.

,

Notwithstanding the above, some minor problems were identified by

,

i

NRC in this functional area which are attributed to lack of atten-

tion to detail to specific conditions or requirements rather than

<

programmatic problems as identified in earlier.SALP assessments.

A violation was issued after construction replaced a valve and, in

,

7

the replacement process, the piping was moved off location and per-

manently secured such that an installed, adjacent, and previously

-

}

quality control accepted pipe support failed to meet the drawing

requirements.

This problem was attributed to poor work control on

the part of the piping contractor.

Another problem involved in-

'

sta11ation of safety-related piping under and through non-seismic

designed stairs which was contrary to the commitments to Reg Guide 1.29.

It was attributed to lack of attention to detail to technical

requirements on the part of engineering.

This problem is similar

,

i

to the crane monorail issue discussed in Functional Area 4.

Other

!

concerns which further indicate a lack of attention to detail in

l

meeting quality standards are as follows: (1) there was failure to

.

specify or provide adequate clearance around the periphery of welds

i

subject to inservice examinations; and (2) loose clamps on piping,

'

loose lock nuts on rigid sway strut supports, and insufficient

'

tightening of lock washers.

Another example was the licensee sub-

l

mittal of a potential 50.55(e) item regarding installation of a

j

safety related piping elbow that was not fabricated from safety-

related material.

Although indicative of problems in material

identification and control, this item was subsequently determined

to be of little safety significance and not reportable.

The licen-

!

see has taken good corrective actions on each identified deficiency

by implementing reinspection programs, rework measures and/or addi-

'

tional engineering evaluations where necessary.

Collectively, the

above items indicate additional attention and/or overview is needed

!

)

to avoid these types of recurring problems.

\\

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.

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_

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'

13

Staffing for the PSI /ISI program was adequate for the existing

workload.

Individuals responsible for the program development were

noted to be competent and qualified to perform the assigned duties.

The licensee was actively involved in this area as evidenced by

their efforts to resolve problems associated with the ultrasonic

examination of weld overlays.

1

In sumt.ary, the licensee and Stone and Webster Engineering have im-

plemented programs which have effectively addressed the prior SALP

concerns regarding the Engineering / Construction interface problems.

However, better controls are needed by engineering, construction,

and QC to reduce the types of the concerns identified during this

assessment period. More management focus on "frontend" engineering

and installation activities is needed to achieve greater attention

to detail if such identified deficiencies are to be avoided.

b.

Conclusion

Category 2, recent trend consistent.

Overall improvement has been

shown in this functional area over the past several SALP assessments.

c.

Board Recommendation

Licensee

Continue emphasis on attention to detail during engineering, con-

struction, and inspection to further reduce deficiencies.

NRC

,

None.

!

,

.

1

b

i

_

_-

. _ - . - _ - _ _ ,

-

.

. . .

-

..

. -

-

- - - - -

.

6

..

14

3.

Safety Related Components (17%, 427 hours0.00494 days 0.119 hours 7.060185e-4 weeks 1.624735e-4 months )

a.

Analysis

No significant problems were noted in this area during the prior

assessment period. Work on safety-related components was found to

be well controlled; a Category 1 rating was assigned.

Most of the inspection activities in this area were by the resident

inspectors; six inspections performed by the resident inspectors

included coverage of several facets of safety-related components.

The licensee's work activities in this area included completion,

trial fitting, and cleaning of the reactor vessel internals; com-

pletion and start-up of the emergency diesel generators; valve and

pump installations, rework of the main steam isolation valves,

hydrostatic testing of the steam generators (secondary side), and

numerous other installations of safety-related components.

Good controls were in place for installation activities regarding

reactor vessel internals, preparation for start up of the diesel

generators, fastening of the diesel generator exhaust silencers and

fuel pool heat exchangers and shot peening and eddy-current testing

of steam generator tubes.

Records were complete and good controls

were in place for maintenance and protection of component cooling

pumps, pressurizer safety valves, and service water pumps.

No

violations were issued in this area.

The installation of safety-related mechanical equipment was well

planned and involved all levels of management.

For example, super-

vising personnel and crafts performing the work appeared well

trained and knowledgeable in the performance of the task which in-

volved extensive repair work in installing the main steam isolation

valves.

The work performed was effectively monitored by quality

control personnel.

The coordination and planning was evident in

the resulting high quality workmanship by capable crafts personnel.

Maintenance of installed equipment was being performed monthly as

scheduled.

Examination of diesel generator equipment areas indi-

cated specified maintenance requirements were being met.

Historically, there has been a reluctance to report deficiencies

i

when encountered at the construction site.

For example, the re-

portability per the requirements of 50.55(e) for limitorque operator

problems was questioned by the NRC which prompted the licensee to

subsequently issue such a report.

However, resolution of such de-

ficiencies has typically been thorough; at the end of the assessment

period, rework on the affected operators was being satisfactorily

addressed.

Another example of such thoroughness involved a previous

Construction Deficiency Report (85-00-02).

In this case, followup

activities were expanded to reflect additional problems that had

developed with the latching mechanisms for the main steam isolation

'

. - - - -

-

_

. . _ _ _ _

__

. -

o

.

15

valves (MSIVs). When two (2) bearings failed due to material de-

fects, the licensee was actively involved in problem resolution and

ultimately directed its vendor to provide new bearings which will

be proof-tested for acceptability.

One allegation was received in this area regarding the possibility

of dirt and dust contaminating pumps and valves located in the Con-

tainment Building.

NRC followup established that all equipment

sensitive to dust and dirt, such as pumps and valve operators, was

adequately protected by plastic covering to prevent entry of un-

desirable contaminants.

In summary, overall performance in this functional area was very

good.

The high performance levels noted in previous SALP assess-

ments were maintained.

b.

Conclusion

Category 1, Consistent.

c.

Board Recommendation

Licensee

None.

NRC

None.

25

16

4.

Support Systems (7%, 158 hours0.00183 days 0.0439 hours 2.612434e-4 weeks 6.0119e-5 months )

a.

Analysis

No significant fabrication problems were identified in this area

during the last assessment period.

The licensee had good controls;

a Category 1 rating was assigned.

The four inspections performed in this area were performed by the

resident inspectors and covered HVAC supports, design of crane

monorails and installation of HVAC fire dampers.

.

Good controls were found in these areas; however, some concerns were

identified regarding Quality Control inspector error and design of

crane monorails. A violation was issued when it was found by NRC

that a Q.C. inspection report that documented inspection results

of an HVAC support indicated no concrete anchors were installed in

the support baseplates, but sixteen anchor bolts were actually in-

stalled.

Licensee followup actions were typically thorough in

checking work by this inspector to demonstrate that this error was

apparently an isolated incident in that the quality of his other

work was good.

During the previous SALP assessment period, a

50.55(e) item also dealt with QC inspector error on HVAC supports.

Although subsequently resolved through dismissal of personnel and

rework of deficient welds, these incidents collectively indicate

some continuing problems in this area.

NRC identified a problem with non-seismic designed and constructed

monorails which were installed above safety-related equipment in

various buildings. This indicated an engineering weakness in fail-

ing to ensure that potential adverse interaction between seismic

and non-seismic components is avoided.

This problem is similar to

the safety related piping through non-seismic stairwell issue dis-

cussed in Functional Area 2 and is another example of how NRC con-

tinues to find problems that should have been prevented and/or

identified by licensee controls.

In summary, the licensee has adequate controls in this area.

b.

Conclusion

Category 2, Consistent.

c.

Board Recommendation

Licensee

More attention is warranted to assure Q.C. inspectors adequately

perform their independent inspections.

Also, as stated in Func-

tional Area 2, engineering disciplines need to emphasize and provide

-

- _ _ -

. ,.

_

.

- - .

. _ - _ .

_ - _

. - .

.. -

6

more attention to detail including commitments and specification

requirements as well as-assuring that systems are able to provide

their intended functions under accident conditions.

NRC-

None.

.

,

I

.

l

I

4

.

18

5.

Electrical Power Supply and Distribution (15%, 362 hours0.00419 days 0.101 hours 5.98545e-4 weeks 1.37741e-4 months )

,

a.

Analysis

Construction and Quality Control inspection activities were con-

sidered to be under good control during the prior assessment periods.

However, numerous lingering engineering / construction interface

problems that affected hardware installation existed in this area

during the last assessment. A noted improvement had occurred from

the prior assessment period (December 1,1982 through March 31, 1984)

when a Category 3 rating was assigned.

Inspections during this evaluation period concentrated on the im-

plementation of the ICSG, CRT, QIMP and Engineering Confirmation

Program, described in Functional Area 2 (Piping Systems and Sup-

ports).

These program objectives were to eliminate the Engineering /

Construction interface concerns discussed in the previous SALP as-

sessment.

Other NRC inspections covered open items, storage of

electrical equipment, 125 Volt distribution system, cable pulling,

installation of condulets, installation of batteries and chargers,

rework controls and environmental qualification of electrical

equipment.

Cable trays, conduits and cable continued to be installed throughout

the assessment period with the major activities being cable pulling

and terminations.

Reinspection and rework activity on electrical

panels to meet Regulatory Guide 1.75 occurred throughout this period.

As of February 26, 1986, of a total of 311 electrical panels in the

program, 119 were final accepted by Quality Control inspections.

Staffing of technical and engineering positions related to the

electrical area was good.

QA personnel were adequately trained and

carried out the QA program relative to the installation of electrical

cables.

Management was obviously concerned with and involved in

assuring quality.

QC management was observed to be very active in

implementing good quality control of electrical related activities.

Good response was shown with regard to the resolution of problems

discussed in the previous SALP assessment.

Management took positive

steps to correct the previous problems in the areas of cable pulling,

cable separation, terminations and installation and to prevent the

recurrence of such problems.

Engineering installation and construc-

tion procedures were revised to provide more detailed instructions

in the areas of cable pulling (to properly calculate allowable pull

tensions), to provide for cable sheath protection and proper separa-

,

tion, and to properly insulate taped splices.

Installation and QC

!

personnel were trained in the procedures.

QC personnel were provided

with on the spot stop-work authority for improper cable pulls.

Management's aggressive efforts to revise construction and QA/QC

4

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procedures.to overcome problems in safety related cable inst

>

-tions, pull calculations and pull methods has resulted in improvedr -

3

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performance in these areas.

1

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Otheritemsdiscussedinthe.lastSALPeval

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ment' attention and progressed satisfactorily during this period;?

springnut retorquing was completed in 36 of a total of 47 seism'ic h ^n

areas; inspection for shims or the need to add shims, including tack

._

welding of same, installed under electrical baseplate supports) was

!l

completed in 2 of 15 areas; identification of. cable which exceeds)

the established criteria for unsupported length was performedtddring

this period, and wrapping of external cable and installation of, tray

covers to meet Regulatory Guide 1.75. commenced.

'

,,

One concern was identified by NRC that involved installation'o\\tf

'( a

commercial grade termination biccks in harsh environments where the

!

specification had specified installation of qualified termination

l'

blocks.

This. problem occurred due to failure on the part'of ergi .

A

neering to specify the correct termination block on field drawings.('

g

Other concerns identified during this period involved'the field in-

sta11ation of loose oversize non-seismic condulets on instraments;

planned installation of electrical cable splic'e's located beldw'the

flood plane in containment (in the event of a'LOCA) with s'plices

g;

that were unqualified for submergence; and installation of terminal

blocks in a vented termination box in containment located below the

' y

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floodplane(intheeventof'aLOCA)thatwasnotqualifiedq9p,1 p

,,

submergence.

Flex conduit containing electrical cables that were s

disengaged from their coupling was found installed and accepted byX

the licensee.

These hardware deficiencies indicate some continuing

problems in engineering in failing to provide specific and/or th6

correct instructions necessary for compliance with the re @ irements.

(

i

One item, installation of a termination block in Containmeitt that

was not environmentally qualified, indicated a problem in the con ()

'

s

tractor's cable pull ticket (termination) office in failing to fM*

plement a " check" system to assure rework was actually(p'erfornmdt F

in the field.

y\\T

y

'

.

The licensee established an electrical plan and is in the process

-

'

i

{

The ?,

of reworking the items discussed above in a systematic way. ,f man

numerous program implementations, along with strengthening o

-

l

agement generally resolved the Engineering / Construction interface ,

t

i

concerns,'although some problems existed with engineering' documents

,

j

which incorrectly translated requirements as discussed above.

li ( ;

i

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i

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l

In summary, Engineering / Construction interf,1ce concerns were re-

i

solved through new program implementation.

Management in the elec-

'

l

trical area was significantly stronger than was apparent in previous

assessments.

Engineering performed considerably better in most

areas, generally providing good technical direction to the field.

!

Disposition and corrective actions on deficient items were excellent.

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20

b.

Conclusion

,

Category 2, Consistent.

q

c.

Board Recommendation

Licensee

A strengthening of the program is needed which particularly addresses

more attention to detail by both the engineering and installation

contractors to eliminate the type of deficiencies discovered by NRC

inspections (similar to Functional Area 2).

Conduct additional in-

,

dependent overviews (design review) to eliminate these deficiencies

.

'

before the hardware is installed.

Need more aggressive self-iden-

tification of problems that could stop systems / components from per-

forming their' intended function (s).

NRC

None.

1

.,

t

,

I

t

!

i

!

'

,

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21

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.

,

.

6.

Instrumentation and Control Systems (15%, 364 hours0.00421 days 0.101 hours 6.018518e-4 weeks 1.38502e-4 months )

, s

t

a.

Analysis

, ,

_

.

'

During the'last assessment period, control of onsite, construction

and inspection activities intthls area was generally considered

satisfactory. A Category 2 rating was assigned.

.

Five inspections w'ere performed in this area during this assessment

period, two by the resident inspectors and three by Region-based

'

specialists.

The inspections covered reviews of open items,ispeci-

e

fication reviewc, welding and general installation of instruments,

' t

lines and associated supports.

.

The-licensee's installation of instrumentation and control systems

i

continued throughout the site during the evaluation period. Acti-

'

1vities in this area, with one exception as discussed below, were

-

conducted in a well controlled manner as contrasted to the previous

SALP assessmeht period when weaknesses were evident. Ongoing in-

~

stallation and problem recolution activities were tracked well in

the Project Electrical: Plan.

Good management and QC involvement

,

was evident. ';No major problems were encountered by the contractor

,

andno50.,55(e)].reportswereissued. The lack of any substantial

negative findines in this< functional area despite considerable NRC

attention is considered to be' indicative of improved performance.

-

One minor violation was identified by NRC relating to missing im-

pulse line slope requirements on instrument isometric drawings for

three safety related flow and level transmitters for the auxifiary

feed, component cooling water, and reactor coolant systems.

This

i

missing construction criterion and inadequate engineering design

review of construction drawings is another example of inadequate

attention to detail.

Previous initiatives to tighten engineering

controls appear to have been only partially effective as evidenced

4

by the violation noted above.

Subsequently, the licensee has con-

cluded that the as-installed conditions are acceptable without the

specified slope, but has clarified the specification to eliminate

any possible future misinterpretations.

Previously identified open items were resolved through active man-

agement involvement and concern for safety issues.

Licensee action

through revised procedures walkdown inspections and review of con-

c

struction drawings for all previously installed impulse lines were.

properly documented and findirigs were satisfactorily dispositioned.

No new significant concerns werv identified in this area.

i

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22

In summary, no major problems were identified in this area.

In-

stallation progressed well.

Management and Quality Control were

effective in assuring installation of a quality product.

This area

has shown a significant improvement during this assessment period.

Good controls by engineering and construction are generally in place,

b.

Conclusion

Category 1, Consistent.

t

c.

Board Recommendation

Licensee

None.

NRC

None.

__

__.

. _ _ - _

- _ _ _ _

- _ - - _ _

_

.

_.

y

'

!

23

'

7.

Licensina Activities

a.

Analysis

i

This area was categorized as Category 2, improving, in the last SALP

assessment.

Although ratings with respect to individual criteria

were variable, the licensee'_s performance in this area had been

adequate and reasonably effective in addressing nuclear safety

4

considerations.

.

Throughout the review process during this assessment period, DLC's

activities generally exhibited evidence of prior planning and as-

l

signment of priorities.

This was shown by the licensee's approach

1

to resolving numerous open items identified in the staff's draft

l

safety evaluation report (SER) to support issuance of the final SER.

'

The licensee's tracking program continued to identify and track the

'

status of each item and maintain internal schedules for_ resolving-

1

each open item.

Generally, DLC management assigned the necessary

technical people to develop complete, high quality responses.

Also,

!

DLC management has taken significant additional initiative to assure

,

themselves that the design of the Beaver Valley Unit 2 station fully

'

complies with the NRC regulations and licensing commitments.

To

provide this assurance, DLC has performed a number of technical

design reviews using outside contractors, in-house DLC engineering

personnel, and Stone and Webster (SWEC) engineering personnel.

DLC's management demonstrated awareness of the licensing issues by

virtue of DLC's experience in the industry, technical expertise,

,

and active participation in owners groups.

The licensee's manage-

,

ment also consistently exercised firm control over its design con-

tractor's activities and maintained good communication between the

contractor, his own staff, and the NRC staff.

j.

Strong licensee management involvement at the Vice President level

who is stationed at the site and is responsible for managing the

,

design, construction, startup, operation, and maintenance of Unit

2, has produced positive results.

Also, the DLC Regulatory Affairs

and engineering staffs have recently been relocated to the site.

i

As a result, in regard to licensing activities, there has been in-

'

creasing evidence of a closer working relationship with the site

staff.

1

The licensee continued to use a tracking system for resolution of

licensing issues.

The tracking system includes all SER outstanding

,

and confirmatory issues, proposed license conditions, and TMI NUREG-

!

0737 issues.

In addition, any other major issues requiring resolu-

l-

tion (i.e., design and FSAR changes that require revisions to the

{

staff's safety evaluations) are also included.

This tracking system

has been very helpful in tracking and resolving the remaining lic-

ensing issues.

i

. - - -.

- .

- . - - - - - .

-.

. -

_ -

.

- - - -

.

24

BV-2 is the lead plant in application of leak-before-break assump-

tion to balance-of plant piping.

The licensee has held frequent

meetings with the staff on this issue and has demonstrated good

technical understanding and a cooperative attitude in these meetings.

The licensee, in cases where generic questions arise, has made use

of industry owners groups to develop acceptable resolution to

licensing issues, e.g. , resolution of Salem ATWS issues.

Open and effective communication exists between the NRC and DLC's

licensing staffs.

Effective dialog between both staffs usually

promotes prompt and technically sound responses to NRC initiatives.

Conference calls with the staff are promptly established and in-

cluded appropriate engineering, plant, and/or contractor personnel.

DLC staff demonstrated a good working knowledge of applicable regu-

lations, guides, standards, and generic issues pertaining to their

plant.

This was evidenced by their positive attitude and respon-

siveness to the NRC staff in addressing unresolved SER issues.

DLC

staff has always been prepared to meet with the NRC staff in a short

time frame to obtain the necessary understanding of NRC information

needs and has been successful, by preparedness and aggressiveness,

in expediting SER issue resolution in a timely manner.

During

meetings, the licensee demonstrated a thorough understanding of the

technical issues and effectively used the services of its architect-

engineer, SWEC, and other contractors as needed.

DLC's promptness

was especially demonstrated during its frequent meetings with the

staff.

The licensee kept the NRR project management generally in-

formed regarding plant completeness status and major milestones.

The Regulatory Affairs group appears to be adequately staffed.

Top

management has extensive experience in the area of nuclear tech-

nology.

The licensee has revised its organizational structure.

The new organization was designed to provide close working relation-

ship with Unit 1 staff, absorbing Unit l's experience as an operat-

ing plant.

In summary, overall strong performance was observed in the func-

tional area of Licensing Activities.

The licensee's trend toward

steady improvement in performance during the current rating period,

specifically, good performance in resolving several major issues,

increased responsiveness and cooperativeness with the staff, and

aggressive approach in resolving issues are the main factors in this

assessment.

b.

Conclusion

Category 1, Improving.

._

,

_.

m

25

c.

Board Recommendation

Licensee

None.

NRC

None.

.

- -

-

. _

-

.

' '

26

8.

Preoperational/Startup Testing (17%, 415 hours0.0048 days 0.115 hours 6.861772e-4 weeks 1.579075e-4 months )

a.

Analysis

In the last assessment, only programmatic and staffing aspects were

evaluated.

Some weaknesses relating to personnel qualification and

establishment of system turnover criteria were identified.

During this assessment, areas reviewed included preoperational pro-

gram development and implementation, QA/QC interface and overview

of test activities, development of test procedures, and conduct of

construction proof and preoperational tests.

During much of this

assessment period, Beaver Valley Unit 2 was in the process of re-

organizing from the construction phase to the preoperational phase.

All levels of management were involved in defining the scope of the

startup program, the organizational structure of the startup group,

and the QA/QC interface during testing. The startup group was re-

organized a second time.

At the end of the period, the organization

was well defined, but finalization of its line organization, divi-

sion of responsibilities, and development of support group inter-

faces were slow; performance in these areas was weak.

The startup manual (SUM), which is made up of individual test pro-

cedures, was not completed when first reviewed by NRC in January,

1985.

The SUM lacked an overall program description that would tie

the individual test procedures into a comprehensive format.

Pre-

sently, the individual test procedures tell the user how to execute

the test program, but a program description is needed to consolidate

the test program.

The absence of a program description was consi-

dered a weakness in management's involvement and control in develop-

ing the SUM.

The SUM did contain a good description of the startup

organization and responsibilities for individuals in the test program.

Earlier and greater management oversight of the SUM development

t

'

could have resulted in a stronger program in that several minor

problems were allowed to be created.

First, there was not a good

match between the preoperational tests listed by the licensee and

'

those committed to in the FSAR.

The procedures were not true sched-

uling elements because some were so large that they had to be sub-

divided and performed over an extended period of time.

Consequently,

significant effort was needed to form an integrated work schedule.

l

Secondly, some of the earlier procedures reviewed did not have good

system restoration sections or double verification of realignment

of critical components.

Jurisdictional control over pre-test con-

i

ditions appeared to lack definition.

However, by the end of the

assessment period, these concerns were receiving appropriate atten-

tion.

L

. ._ _ _ -

_

.

. . .

_.

__.

_ _ _

_

.

27

The QA/QC oversight of the early test program was not well defined

in regard to phasing out the construction site QC (SQC) function

and phasing in testing QC (TQC), or developing a QA surveillance

.

,

program for test activities.

The overlap between the two QC pro-

grams still needed management attention to override potential con-

flicts with regard to jurisdictional responsibilities for rework

items on subsystems undergoing testing in that the break between

the construction phase and proof test preop test phase was not well

'

defined.

A final, formal policy that defines this break for rework,

maintenance, and modifications needs to be developed and disseminated

>

i

to the startup. test engineers-and QC organizations.

The QA Sur-

veillance Group was just established at the beginning of 1986.

Development of an administrative manual and full staffing was not

yet complete.

The construction proof (including flushing and hydrostatic tests)

and preoperational tests were technically adequate and met FSAR

commitments.

Procedure developement proceeded at an acceptable pace

and was improving in quality.

The procedure review process to en-

sure that the latest commitments are forwarded to cognizant test

,

engineers for inclusion in the test, and reviewed by Joint Test Group

'

3[

before approval with final authorization for test conduct, was func-

tioning satisfactorily.

Program requirements and station policy

2

were well understood by the test engineers.

The interface between

construction and test groups during system flushes and hydros was

satisfactory.

The QA Surveillance Group actively observed much of

the safety related test activities in 1986 and identified meaningful

items dealing with both hardware and program controls.

In summary, the preoperational and startup testing program has now

arrived at the initial stages of implementation.

Delays in develop-

ing the final test organization and management controls hindered

the development of a strong program although the one in place was

satisfactory.

The overall program appears adequate and capable of

'

assuring that all required testing and performance requirements

are met.

,

b.

Conclusion

,

Category 2, no trend assigned (insufficient basis).

c.

Board Recommendation

'

Licensee

Assure the QA Surveillance Group is adequately staffed and that a

written policy is forwarded defining the division of responsibility

between SQC and TQC.

-

'

.

_

, _ . - - - _ . _ _ ..

. .

.

- -

. . .

. .

_

.-

.

28

NRC

Arrange management meeting to discuss planning for startup testing

including philosophy on surveillance testing, transition from pre-

operational testing to operations, and handling of test exceptions,

e

l

i

. . . . -

. - - - .

. - .

-

.-

.

_ .

- . - -

,. . - . . . .

. . .

.

.-.--.

.

29

9.

Assurance of Quality

a.

Analysis

During this assessment period, Assurance of Quality is being con-

sidered as a separate functional area for the first time although

a related area, Quality Assurance and Administrative Controls, was

included in the last SALP assessment. Management involvement and

control in assuring quality continues to be one evaluation criterion

for each functional area.

The various aspects of Quality Assurance Program requirements have

been considered and discussed as an integral part of each functional

area and the respective inspection hours are included in each one.

Consequently, this discussion is a synopsis of the assessments re-

lating to the assurance of the quality of work conducted in other

areas.

During this evaluation period, the licensee independently contracted

for a " Management Analysis Corporation" (MAC) audit to assess the

overall project status.

It should be noted that this audit was

partially prompted by an NRC concern that the DLC Quality Assurance

Unit might not have sufficient independence from the engineering

and construction activities.

Through these audit findings, the

licensee implemented several changes which effectively strengthened

the overall management program.

This includes the establishment

of the separate QA/QC group with a strong manager overseeing SVG

activities, the establishing and appointment of a senior person as

Manager of Construction and Engineering, and the relocation of the

DLC Nuclear Construction Division engineering and licensing staff

to the site.

Another effective program being implemented is the scheduled weekly

meeting which involves senior managers to ensure that potential

interface problems are identified and that appropriate corrective

actions are taken.

These face-to-face scheduled discussions have

been very effective in resolving problems.

The Quality Improvement

Management Program (QIMP) effort has also significantly strengthened

the licensee's management controls.

Implementation of the Electrical

Plan was another effective tool used to control the resolution of

problems; particularly, NRC identified concerns in the electrical

area.

i

l

The licensee has placed major emphasis on resolving NRC identified

items.

Through implementation of a program titled "Next Step List"

and appointment of senior management personnel to this task, many

of the items have been completed and are ready for NRC review and

closure.

This program was very effective and significantly reduced

I

the amount of NRC "open items."

l

!

i

l

.-

.

_

_.

.-

I

30

NRC inspection coverage concentrated on Quality Control inspections

during construction and for systems turned over to the Start-Up

Group, Qua.lity Assurance audits, timely disposition and' closure of

Nonconformance and Disposition (N&D) Reports, and responses to

Generic Letters, Part 21 Reports, Information Notices, and Bulletins.

Inspections also were performed of the licensee's activities regard-

ing the Engineering Confirmation Program.

Two violations were issued that reflected on this. functional area;

Quality Control inspector error (see Functional Area 4)-and failure

'

to promptly correct and close N&Ds. The licensee implemented strong

i

timely corrective actions for these violations.

1

NRC expressed concern during this period regarding QC inspection

of systems turned over to the Startup Group (SUG).

The licensee's

original plans only established a surveillance program for work

activities under control of SUG.

This area has been strengthened

by establishing a separate QA/QC group to perform audits, surveil-

lance and QC inspections and witness points.

This concern appears

to have been resolved; however, the program was only recently im-

plemented and therefore, it is premature to determine the effective-

ness of the new QA/QC group.

A concern discussed in the last SALP report regarded the organiza-

tional arrangement wherein the QA/QC manager reported to the Nuclear

Group Vice President, who also functioned as the DLC Project Manager.

The licensee has resolved this concern through appointment of a

Senior Manager as " Manager of Construction and Engineering" to re-

solve the daily onsite construction and engineering problems.

This

organizational structure eliminates any concern regarding Quality

Assurance independence.

Generally, the licensee has demonstrated an adequate program for

the assurance of quality.

QA audits are scheduled and performed

to cover all major activities.

Corrective actions for audit find-

ings are prompt and thorough, QA staffing is adequate; there is a

large QC staff.

QA/QC personnel are adequately qualified and re-

l

ceived good training through company sponsored training films and

'

lectures.

Quality Control management in the construction area is

strong and effective and responds in an effective manner to resolve

all issues affecting quality.

However, as illustrated above in the

various examples and in the analyses of previous functional areas,

problems continue to be identified by the NRC rather than by the

licensee.

This is indicative of a weakness in the direction of the

,

licensee programs for the assurance of quality and engineering pro-

grams which tend to be reactive rather than aggressively identifying

weaknesses in "frontend" activities which would help reduce the

number of such recurrent deficiencies.

!-

L

.

-

--

..

.

31

In summary, the various management changes which have occurred dur-

ing this evaluation period have significantly strengthened the

overall project and established a management team which is struc-

tured adequately to address safety issues. . Implementation of other

programs such as QIMP, CRT, the ICSG, and the Electrical Plan have

also contributed to good performance.

The self-initiated implemen-

tation of the MAC audit reflects the licensee's goal to build a

quality plant.

Implementation of a separate QA/QC group to inspect

turned-over systems was a positive program to assure adequate QA

attention after completion of construction.

With some exceptions,

such as QC inspector errors, untimely closure of N&Ds, and the need

for a more aggressive approach to problem self-identification, the

licensee's program has been effective. With the various management

changes implemented during this evaluation period, proper management

now is in place to systematically provide adequate assurance of

quality for remaining construction and testing activities.

b.

Conclusion

,

Category 2, Consistent.

c.

Board Recommendation

Licensee

None.

NRC

Discuss with licensee plans for transferring engineering information

to the site for use during plant operations.

. - .

-

.-

-

1

-

32

V.

SUPPORTING DATA AND SUMMARIES

1.

Construction Deficiency Reports (CDRs)

Nine CDRs were submitted by the licensee during the assessment period.

Six of the deficiencies were associated with vendor supplied hardware.

Two CORs (85-00-04 and 85-00-05) were associated with design deficien-

cies. One CDR resulted onsite due to installation of non-ASME material

in a safety related application.

One corrected CDR, 85-00-05, had ac-

ceptable corrective actions.

Construction deficiency reports are listed

in Table 1.

2.

Investigation Activities

One allegation was received during the assessment period regarding a

concern in the Containment Building about excessive dust and dirt.

The

allegation was evaluated.by the NRC, but not substantiated.

There were

no open allegations at the end of the assessment period.

3.

Escalated Enforcement Action

None.

4.

Management Conferences

June 19, 1985 - A special, announced management meeting at NRC's request

to discuss the results of the Region I SALP board convened to assess

licensee performance from April 1, 1984 to March 31, 1985.

October 8, 1985 - A special, announced management meeting at licensee's

request to specifically address the progress of corrective actions as-

sociated with the June 7, 1985, SALP Report and to discuss plans for

licensing of reactor operators.

,

-

,

.-

-.mm

-

--

_

,_

O

9

TABLE 1

CONSTRUCTION DEFICIENCY REPORT

(APRIL 1, 1,985 - MARCH 31, 1986)

BEAVER VALL'iY POWER STATION, UNIT 2

CDR NUMBER

DEFICIENCY

CAUSE CODE

85-00-03

Environmental qualification of core

B

exit thermccouple system.

85-00-04

Cable tray hold-down clamps.

B

85-00-05

Insufficient thickness of insulating

D

tape on SKV cable terminations and

(Closed)

splices.

l

85-00-06

Westinghouse manufactured SA-1 relay

B

problems.

85-00-07

Damage of BBC K-line circuit breakers.

B

86-00-01

Improperly rated cables terminated in

B

solenoid valves.

86-00-02

Non-ASME elbow installed.

Determined not

to be reportable.

86-00-03

Paul Monroe snubber material

defective.

B

86-00-04

Limitorque valve operator

B

deficiencies.

Cause Codes

,

A - Personnel Error

'

B - Design / Fabrication Error

C - External Cause

D - Defective Procedure

E - Component Failure

F - Site Construction Error

!

_

_ _ .

.

_ _

_

. . _ .

. .

. - -

...

..

TABLE 2

VIOLATIONS

(APRIL 1, 1985 - MARCH 31, 1986)

BEAVER VALLEY POWER STATION, UNIT 2

4

A.

Number and Severity Level of Violations

1.

Severity Level

O

0

5

l

Severity Level V

1

Deviations

_2

TOTAL

8

B.

Violation vs. Functional Area

Severity Level

-

Functional Area

Deviations

IV

V

1.

Containment and Other

Safety-Related Structures.

2.

Piping Systems and Supports

1

3.

Safety-Related Components

4.

Support Systems

1

'

5.

Electrical Power Supply

and Distribution

1

l

6.

Instrumentation and Control

L

Systems

1

l

7.

Licensing Activities

i

8.

Preoperational/Startup

l-

Testing

l

l~

9.

Assurance of Quality

2

TOTAL

2

5

1

- _ ,

- -.

. - . .

-. .. .

- ---.

. - - ..

- .---. - -..

. - -

. - . . -

. . -

.

TABLE 3

INSPECTION HOURS SUMMARY (4/1/85 - 3/31/86)

BEAVER VALLEY POWER STATION, UNIT 2

FUNCTIONAL AREA

HOURS

% OF TIME

1.

Containment and Other Safety-Related

Structures.

112

4

2.

Piping Systems and Supports

606

25

3.

Safety-Related Components

427

17

4.

Support Systems (HVAC)

158

7

5.

Electrical Power Supply and Distribution

362

15

6.

Instrumentation and Control Systems

364

15

7.

Licensing Activities

8.

Preoperational/Startup Testing

415

17

9.

Assurance of Quality

TOTAL

2444

100

Included in other functional areas.

- Does not include NRR time.

'

i

I

i

!

I

l

I

L

.

'e

TABLE 4

INSPECTION ACTIVITIES

BEAVER VALLEY POWER STATION, UNIT 2

Report

Number

Inspector

Areas Inspected

85-08

Specialist

Pre-operational test program

(36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months )

85-09

Resident

Reviews of information notices, electrical cable

(155 hours0.00179 days 0.0431 hours 2.562831e-4 weeks 5.89775e-5 months )

routing, cadwelding, instrumentation welding, welder

qualifications, excessive feedwater transient

analysis and daily site tours.

85-10

Specialist

Review of activities relating to installation of

(66 hours7.638889e-4 days 0.0183 hours 1.09127e-4 weeks 2.5113e-5 months )

electrical / instrumentation components and associated

circuits.

85-11

Specialist

Inspection cancelled.

(0 hours0 days 0 hours 0 weeks 0 months )

85-12

Specialist

Inspection of work in progress and completed work

(38 hours4.398148e-4 days 0.0106 hours 6.283069e-5 weeks 1.4459e-5 months )

associated with mechanical equipment, reviews of

previously identified items, QA/QC involvement, and

. discussions with supervisory and work force personnel.

.

85-13

Resident

Inspection of activities pertaining to previously

(195 hours0.00226 days 0.0542 hours 3.224206e-4 weeks 7.41975e-5 months )

identified items, 50.55(e) reports, information

notices, seismic design of items important to safety,

inspection of piping supports, rigid sway struts,

rework and/or disassembly control of components,

disposition of nonconformance and disposition reports,

review of welding and associated weld procedures,

and daily site tours.

85-14

Specialist

Inspection of licensee's action on previous inspec-

(36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months )

tion findings, and preservice inspection program

activities.

85-15

Specialist

Inspection of licensee's actions and status of pre-

(64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months )

vious inspection findings in the electrical area.

..

.

-_ _ _

-_

.

. __.

-

..

. . .

__

. . .

I

'*

T-4-2

Report

Number

Inspector

Areas Inspected

85-16

Resident

Inspection of activities pertaining to previously

(269 hours0.00311 days 0.0747 hours 4.447751e-4 weeks 1.023545e-4 months )

identified items, 50.55(e) reports, information

notices, inspection of piping supports, instrumen-

tation tubing installation, material and eq'uipment

control with associated training information, pre-

operational testing of station batteries, review of

licensee response to bulletins, information notices,

generic letters and Part 21 reports, corrective

action on nonconformance and disposition reports,

5 KV cable terminations, separation distance of cable

from hot piping, off-center socket bore on globe

valves, review of welding and associated weld pro-

cedures & daily site tours.

85-17

Specialist

Inspection Cancelled.

(0 hours0 days 0 hours 0 weeks 0 months )

,

i

85-18

Specialist

Inspection of Quality Assurance Program for Pre-

(77 hours8.912037e-4 days 0.0214 hours 1.273148e-4 weeks 2.92985e-5 months )

operational Testing.

85-19

Resident

Inspection of activities pertaining to previously

(126 hours0.00146 days 0.035 hours 2.083333e-4 weeks 4.7943e-5 months )

identified unresolved. items, Part 21 Reports, in-

spection of pipe supports, rework control on systems.

'

turned over to Start-Up Group, eddy-current inspec-

i

tion of steam generator tubes, review of Quality

j_

Assurance Audits and daily site tours.

)

85-20

Specialist

Inspection of construction requirements and controls

i

(37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months )

pertaining to concrete construction for closure of

the temporary construction opening in the containment

building exterior wall, of licensee response to NRC/

IE Bulletin 79-02 relating to the installation of

,

drilled-in concrete expansion anchors for pipe sup-

i

ports, review of previously identified inspection

'

items relating to the above bulletin and review of

settlement monitoring records. Additionally, the

licensee's QA/QC interactions pertaining to the first

two items identified above were reviewed.

85-21

Resident

Inspection of activities pertaining to previously

[

(175 hours0.00203 days 0.0486 hours 2.893519e-4 weeks 6.65875e-5 months )

identified unresolved items and violations, inspec-

!

tion of HVAC supports, flex conduit and condulet

!

installation, weld material control, concrete place-

ment in the reactor containment exterior wall and

daily site tours.

1

- . --

. -

- - - -

-.

.

- .

.. -

. - - - -

.

-

.s

.

~

T-4-3-

Report

Number

Inspector

Areas Inspected

85-22

. Specialist

Inspection of activities pertaining to previously

(35 hours4.050926e-4 days 0.00972 hours 5.787037e-5 weeks 1.33175e-5 months )

identified items, preventive maintenance program for

the emergency diesel generators and associated

equipment.

85-23

Specialist

Inspection of activities pertaining to previously

(73 hours8.449074e-4 days 0.0203 hours 1.207011e-4 weeks 2.77765e-5 months )

identified items, work observations and documentation

relative to the installation of instruments and

electrical equipment.

85-24

Specialist

Inspection of. licensee's action on unresolved items

(35 hours4.050926e-4 days 0.00972 hours 5.787037e-5 weeks 1.33175e-5 months )

and violations in the area of structural, piping and

,

electrical supports.

85-25

Resident and

Inspection of activities pertaining to previously

Project Engr.

identified unresolved items, inspection of electrical

(174 hours0.00201 days 0.0483 hours 2.876984e-4 weeks 6.6207e-5 months )

terminations and monorail systems, environmental

qualification of safety-related junction boxes,

electrical rework control, review of radiographic

films of main steam piping field welds and inservice

inspection procedures, review of licensee action on

Information Notices, Part 21 Reports, Bulletins and

disposition of Nonconformance and Disposition Reports -

and daily site tours.

85-26

Resident

Inspection of activities pertaining to previously

(188 hours0.00218 days 0.0522 hours 3.108466e-4 weeks 7.1534e-5 months )

identified unresolved items, 50.55(e) reports, de-

ficient limitorque operators, lay-up of installed

equipment, QA/QC program in proof-testing activities,

design / construction of main steam piping to auxiliary

feedwater turbine, preservice examinations, fire

protection system supports and daily site tours.

T

86-01

Resident

Inspection of licensee's activities pertaining to

(54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months )

Pre-operational testing.

86-02

Resident

Inspection of activities pertaining to previously

(253 hours0.00293 days 0.0703 hours 4.183201e-4 weeks 9.62665e-5 months )

identified unresolved items, environmental qualifi-

cation of electrical termination blocks and Raychem

splices, installation of flexible conduit, cleanli-

ness controls of equipment during flushing activities

,

'

measurement of pipe support clearances, reviews of

steam generator shot peening, rework controls, tech-

nical reviews of engineering disposition and daily

j

site tours.

1

- .. - - -

. -

-

.

T-4-4

.

Report

Number

Inspector

. Areas Inspected

86-03

Specialist

Inspection of activities pertaining to previously

(104 hours0.0012 days 0.0289 hours 1.719577e-4 weeks 3.9572e-5 months )

identified items, installation of instrumentation

tubing and reviews of voltage profiles.

86-04

Resident

Inspection of licensee actions on previous inspection

(62 hours7.175926e-4 days 0.0172 hours 1.025132e-4 weeks 2.3591e-5 months )

findings, preoperational test program implementation,

emergency diesel generator testing and review of

several preoperational test procedures.

86-05

Specialist

Inspection of licensee's action on previous inspec-

(68 hours7.87037e-4 days 0.0189 hours 1.124339e-4 weeks 2.5874e-5 months )

tion findings and Preservice Inspection activities.

86-06

Resident

Inspection of licensee actions on previous inspection

(124 hours0.00144 days 0.0344 hours 2.050265e-4 weeks 4.7182e-5 months )

findings, preoperational test program implementation,

and review of several preoperational test procedures

(CILRT and recirculation and quench spray).

,

1

I

_ _ _ _ _ . . - _ _

.._ . . ,

,. - ~ _ _ . , . . _ .

. , . _ . , - _ _ _ _ _ . _ . . _ _ _ _ - _ _ _ .

, . - - - _ . , , . , , _

-

E'

.-

a

,e-

ATTACHMENT 1

ENFORCEMENT DATA.

Report

Severity.

Functional

Number

Subject

Level

Area

85-13-01:

Safety-related piping

routed under and through

non-seise.ic stairs.

Dev.

2

85-13-02

Final Quality Control

inspected pipe off

location.

IV

2

85-14-01

Insufficient clearances

around welds for performing

-inservice inspection.

V

2

85-16-01

Promptly correcting and

closing Nonconformance.

and Disposition Reports.

IV.

9

85-21-01

Quality Control Inspector

Error.

IV

9 AND 4

85-23-01

Slope of instrumentation

tubing not in compliance

with requirements.

IV

6

85-25-01

Non-nuclear grade

terminal blocks installed

on feedwater isolation

valve.

IV

5

85-25-02

Non-seismic monorails

installed above safety-

related components.

Dev.

4

i-

1

h

f

'

.. . .

.

-,

. , _ . _ . . . .

. . _ . _ _ ,

- _ . . _ , ,

, _ , , . _

_ ,

_ , _ . _ _ . _ _ _ . . _ _ _ . _ , _ , . _ . , _ _

___

/pe =%,'#c

UNITED STATES

.

NUCLEAR REGULATORY COMMISSION

ENCLOSURE 3

j' '

, , . ,

.

s

REGION 1

631 PARK AVENUE

,

o,

j

%,

,e

KING OF PRUSSIA. PENNSYLVANIA 19406

02 M

Docket No. 50-412

Duquesn- Light Company

-

ATTN:

Mr. J. J. Carey

Vice President

,

Nuclear Group

Post Office Box 4

Shippingport, Pennsylvania 15077

_

'

Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Report No.

50-412/85-98

The NRC Region I SALP Board has assessed the performance of activities at the

Beaver Valley Power Station, Unit 2, for the period April 1,1985 - March 31,1986.

The SALP Board Report is enclosed.

A meeting to discuss this assessment has been

scheduled for July 9, 1986.

This meeting will be held at the Beaver Valley site,

Shippingport, Pennsylvania.

At the meeting, you should be prepared to discuss the SALP assessment and your

plans for managing the transition from completion of construction to preoperational

testing and operations.

The meeting is intended to be a candid dialogue wherein

any comments you may have regarding our report may be discussed.

Additionally,

you may provide written comments within 30 days after the meeting.

Your cooperation with us is appreciated.

Sincerely,

-

Thomas E. Murley

Regional Administrator

Enclosure:

Region I SALP Report 50-412/85-98

'

r

/

-

. - - - -

-

a

JUL 0 21996

Duquasne Light Ccmpany

2

cc w/ enc 1:

E. J. Woolever, Vice President, Special Projects

E. Ewing, Quality Assurance Manager

R. J. Swiderski, Manager, Startup Group

J. P. Thomas, Manager, Engineering

R. E. Martin, Manager, Regulatory Affairs

C. O. Richardson, Stone and Webster Engineering Corporation

Public Document Room (POR)

local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

HRC Resident Inspector

Commonwealth of Pennsylvania

i

l

,

!

l

>

.- ,-

,

. - . . .

. _ - . -

, ,- - - - . - , - . . . - -

, . , _ . , , . , - -

- ,

.

g.

.

ENCLOSURE 4

-

,

'Af

2NRC-6-089

gg

No. 2 Unit Project organization

jl1

Ext.160

P.O. Box 328

August 14, 1986

Shippingport. PA 15077

.

United States Nuclear Regulatory Comission

Region I

631 Park Avenue

King of Prussia, PA 19406

ATTENTION: Dr. Thomas E. Murley

Administrator

SUBJECT:

Beaver Valley Power Station - Unit No. 2

Docket No. 50-412

Systematic Assessment of Licensee Performance (SALP)

Report No. 50-412/85-98

Gentlemen:

Thank you for your meeting with us on July 9,1986 to discuss the

Beaver Valley Power Station Unit No. 2 SALP Report for the period of April

1, 1985 through March 31, 1986.

In

addition to the items discussed at the July 9th meeting, the

following items summarize the actions taken or planned to be taken to

address the concerns which were identified in your letter of July 2, 1986.

Functional Area No. 4, Support Systems and Functional Area No. 9, Assurance

of Quality

The incident of Inspector error is described in these functional

areas.

The project has always been concerned with the potential of

inspector error; but since the incident reported during the previous SALP

period (where we initiated a 10CFR50.55(e) report), we have increased our

attention to the re-verification and sampling of inspectors' work.

Formal

summaries of our results have been transmitted to Senior management for

their review and information.

We have re-inspected 7,601 attributes previously accepted by QC

Inspectors.

This re-inspection resulted in 7,511 acceptable conditions

and 90 unsatisf actory conditions. For information,1,832 of the attributes

given related to the complete re-inspection of supports for all welding

attributes.

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- United States Nuclear Regulatory Commission

Dr. Thomas E. Rarley, Regional Administrator

Systematic Assessment of Licensee Perfomance (SALP)

Report No. 50-412/85-98

Page 2

Each unsatisfactory condition is uniquely investigated by re-verifying-

the previous work accepted by that inspector.

Thus, we establish dether

or not we have an isolated error.

Dependent upon the type of error found,

we re-train the inspector, clarify our procedures / techniques, or if minor

and isolated, admonish and ranind the inspector of his duties.

In the specific incident mentioned in the SALP Report, (85-98) the

error was completely out of character with reference to the individual's

past perfomance as confimed by an extensive review of his past work.

We believe that this is the first time that an inspector error was reported

by the NRC during the 10 years of Duquesne Light. Company Site Quality

Control's existence.

The effectiveness of our actions to contain and correct potential

inspector error has recently been confimed by the independent site NRC

Inspection Group, June 1986, where 42 supports and 94 hilti installations

were re-inspected by random selection with no findings or errors being

reported. This confimed the previous independent NRC Inspection where 151

pipe welds, 30 supports and 97 hilti installations were also re-inspected

with no findings or errors being reported.

We regretfully accept that inspector error will occur, but we believe

that our training prograns, supervisory actions and re-verification /samp-

ling prograns are sufficient to contain this problem.

Functional Area 2 - Piping System and Supports,

Function Area 5 - Electrical Power Supply and Distribution,

Functional Area 6 - Instrumentation and Control System

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These three areas each discussed one or more inspector identified

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violations in which more attention to detail in either engineering or

construction

activities would have prevented

the occurrence of the

violation.

We acknowledge both the accuracy of the inspectors findings and the

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conclusion drawn by the SALP board.

As a result of these findings, we have taken steps to ensure that fu-

ture installations will be perfomed in such a manner that similar problems

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will not occur.

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United States Nuclear Regulat:ry Comission

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Dr. Thomas E. Murley, Administrator

Systematic Assessment of Licensee Performance (SALP)

Report No. 50-412/85-98

Page 3

We have also concluded that in some instances our field engineering

personnel have had a tendency to rely upon the Hazards Analysis Walkdown

group and the Environmental Qualification Survey tean to identify sit-

uations in which reliable operation of equipment could be threatened by

seismic events, piping failures, or high snbient temperatures, radiation,

moisture and submergence to which the installed equipment might be

exposed.

In addition to numerous procedural changes, we have taken steps to

improve our performance in these areas which are discussed in a sisnmary at

the end of this response.

Functional Area No. 8, Preoperational/ Start-up Testing

A)

Concerning the QA/QC Surveillance Group which was fomed in 1985

and was being staffed by the beginning of 1986, approximately 40

people had been assigned to the Quality Assurance Surveillance

Group by July 1, 1986. Additional personnel from the Operations

Quality Control Department will be incorporated in the Group

Septenber 1,1986, after completion of the Beaver Valley Unit I

refueling outage.

A written policy describing the division of

responsibility between Site Quality Control and Test Quality

Control was issued on May 16, 1986 by the Quality Assurance

Manager.

Additional clarification was provided in a subsequent

letter dated June 27, 1986, issued by the Director of Site Qual-

ity Control and the Deputy Quality Assurance Manager.

B)

The wording of Section 8, Preoperational Startup Testing implies

that many changes were made to the Startup Program and Manuals

due to NRC Audits.

However, most discrepancies were resolved by

further verbal discussions / clarifications with the various NRC

Inspectors. The following are exanples:

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United States Nuclear Regulatory Conunission

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Dr. Thomas E. Murley, Administrator

Systematic Assessment of Licensee Performance (SALP)

Report No. 50-412/85-98

Page 4

1.

Paragraph 3 states, "The Startup Manual (SUM), which is made up

of individual test procedures, was not completed when first

reviewed by NRC in January, 1985."

Comment:

While this statement is correct that the SUM was not

totally complete when the NRC first reviewed it, the statement

is incorrect in stating that the manual is made up of individual

test procedures.

This was subsequently discussed with the NRC

to explain that the SUM is not test procedures but the Admin-

istrative Program / Procedure for the Startup Group (i.e., how the

test procedures are written and performed, and other areas of

Startup Group activities, etc.).

2.

Paragraph 3 further states, "The SUM lacked an overall program

description that would tie the individual test procedures into a

comprehensive format.

Presently, the individual test procedures

tell the user how to execute the test program, but a program

description is needed to consolidate the test program."

Comment:

The intention of the SUM (not test procedures) is to

direct the individual on how to execute the test program and not

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to provide an overall program description.

The FSAR, Section

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14

Initial Test Program provides the overall program descrip-

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tion.

During subsequent meetings / discussions with the NRC

Inspectors it was agreed that since the FSAR provides the over-

all program description and the SUM (which references the FSAR)

are the Administrative Procedures used to comply with the FSAR,

no changes were needed.

3.

Paragraph 4 states, "The procedures were not true scheduling

elements because some were so large they had to be subdivided

and performed over an extended period of time.

Consequently

significant effort was needed to form an integrated work

schedule."

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Comment:

With the exception of a few test procedures (i.e. Hot

Functional Test Procedure, Power Ascension Test, etc.) the test

procedures were not intended to be scheduling documents.

Also,

it was further explained to the NRC Inspectors that the reason

for performance over an extended period of time was the need for

different plant conditions (i.e., initial system performance

cold and during hot plant conditions).

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United States Nucler Regulatcry Commissicn

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Dr. Thomas E. Murley

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Systematic Assassment of Licensee Performance (SALP)

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Report No. 50-412/85-98

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4.

Paragraph 4 further states, " Secondly, some nf the earlier' pro-

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cedures reviewed did not have good system restoration sections

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or double verification of realignment of critical components."

Coment: The NRC Inspector was looking at a specific section of

the procedure entitled " Restoration"i

It wai' demonstrated to

the Inspector that restoration was accomplished by the

procedures as written by either specific steps throughout the

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procedure, specific steps at the end of the procedure , or as

directed by Operational needs through other procedures.

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5.

Paragraph 4 also states, " Jurisdictional control over pre-test

activities appeared to lack definition."

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Coment: This appeared to have been an early concern of thd'NRC

that was subsequently closed through better understanding of'the

Startup Group Programs.

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6.

Paragraph 4 is ended by, "However, by the end of the assissment

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period, these concerns were receiving appropriate ,attentio'n."

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were ' esolved thro ~ ugh dis-

Coment:

Most items of concern

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cussions with or better understanding of the Startup Group

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Programs by the NRC Inspectors. Few changes were made.

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SUlWARY

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The SALP suggests that "overall review and control activities are ,too

narrowly focused on 'backend' activities" and that there should ,be "more

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licensee aggressiveness in self-identification of problems with 'frontend'

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activities." The NRC staff should be aware of numerous project initiatives

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which have been directed specifically to the early identification and

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resolution of problems.

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Configuration Control / Advance Change Notice Systems:

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Project Procedure 2BVM-56A has been developed to cbtain complete

configuration control through management of design change; to provide

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to construction, inspection, and test personnel information sufficient

to schedule implementation of changes; and to provide to test and

operations personnel, documents which are current and reflective of

as-built, as-tested conditions.

The program utilizes an engineering

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checklist which requires that the engineer consider the impact of the

change upon each discipline.

Thus, interface with other disciplines

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are identified "up-front".

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United States Nuclear Regulatory Commission

Dr. Thomas E. Murley, Regional Administrator

Systematic Assessment of Licensee Performance (SALP)

Report No.- 50-412/85-98

Page 6

Piping Systems and Supports:

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Examples of self initiated "frontend" engineering activities which

were _ directed towards concerns related to catalog hanger components

included: 1) testing of clamp anchors to evaluate the localized effect

of the clamping action ,11)

oversized clamp holes were identified

and a program was established to test and evaluate the condition, and

iii)

cracked spherical bearings were also identified as a potential

problem and a program has been implemented to examine the installed

condition.

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Pre-Cable Pull Walkdown:

The entire routing of -installed raceway for planned cable pulls is

walked prior to the issuance of cable pull tickets to craftsmen. This

step

supplements

the

documentation

research

in

identifying

and

correcting any deficient conditions prior to initiating the cable

pull.

Raceway Installation Support Program (RISP):

The RISP personnel are located in the buildings.

They interface di-

rectly with the craft to resolve interferences and questions related

to conduit installation.

In addition, the RISP reviews conduit

drawings for possible problems.

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Dry-Fit Programs:

Instrument tubing is fit up in the " dry" condition.

Thus, field

interferences

are

identified

and

corrected

prior

to

permanent

t

installation.

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Field Investigation of New Design (FIND):

Field personnel walkdown newly issued design drawings. This group was

utilized for both mechanical and electrical installations.

The group

identifies potential field problems with the drawings and resolves

these problems.

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Unit d Stat:s Nucl ar Regulatory Commission

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Dr. Thomas E. Murley, Regional Administrat:r

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Systematic Assessment of Licensee Performance (SALP)

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Report No. 50-412/85-98

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Page 7

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Start-Up Support Group (SUSG):

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These engineers have the responsiblity of providing engineering sup-

port to the DLC/SUG construction proof testing and Pre-Op/SOV testing

programs.

Working with the DLC/SUG test and system engineers,

SWEC-SUSG provides engineering direction and works with the SEG in

reviewing and resolv.ing OLC/SUG test program concerns. Once the test-

ing priorities are established, the SUSG will initiate or follcw

through with the -SEG on all issues which require engineering support

or action.

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Quality Improvement Management Programs:

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Under the QIMP, installttion inspection results are closely reviewed

to recognize the factors consistently contributing to inspection

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"unsats" and impletenting appropriate corrective measure to improve

the inspection acceptance of installations.

Since

the

program, initiation,

significant

improvement has

been

attained

in

the : final

inspectfon

acceptance, of

pipe

and

instrumentation raceways and terminations.

Also, under this' program compliance with the Rework Control Procedure

is closely monitored.

Any adverse trends are addressed at the

Construction Supervisor level for appropriate correction, including

termination of workers found disregarding the control procedural re-

quirements.

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In Conclusion

We are generally pleased with t.he SALP Board's assessment of. our per-

formance and have discussed with site personnel your observations

which

would be of benefit to the overall excellence of project activities.

DUQUESNE LIGHT COMPANY

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By

VJ. J.' Carey '

Vice President

RJW/ijr

cc:

Mr. P. Tam, NRC Projedt Manager

Mr. W. Troskoski, NRC Senior Resident inspector

Mr. L. Prividy, NRC Resident Inspector

NRC Document Contr31 Desk

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ML20206T006

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