ML20215G701
| ML20215G701 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/08/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-7-156, NUDOCS 8706230357 | |
| Download: ML20215G701 (5) | |
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2NRC-7-156 Beaver Valley No. 2 Unit Project Organization S.E.G. Building Telecopy 5
Ext.160 P,0, Box 328.
June 8, 1987 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Edward C. Wenzinger, Chief Division of Reactor Programs
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-18
REFERENCE:
1)
Letter dated May 6, 1987, (E. C. Wenzinger to J. J. Carey)
Gentlemen:
The above referenced letter transmitted a Notice of Violation as Appendix A.
Attachments 1 and 2 of this letter provide Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Violation.
DUQUESNE LIGHT COMPANY By
@'J. ffey v
Senior Vice President LMR/ijr NR/LMR/8718 Attachments cc:
Mr. P. Tam, Project Manager (w/a)
Mr. J. Beall, NRC Sr. Resident Inspector (w/a)
Mr. L. Prividy, NRC Resident Inspector (w/a)
NRC Document Control Desk (w/a) 8706230357 070608 3
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4 l United States' Nuclear Regulatory Commission Mr. Edward C. Wenzinger, Chief-Inspection Report 50-412/87-18 Page 2-COMMONWEALTH OF PENNSYLVANIA )
Ss:
COUNTY OF BEAVER.
On this [ O day of AX[
/ [/ [ _, before me, a Notary Public in and for said C[mmonwealth and County, personally appeared J.
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J. Carey, who being ' duly sworn, deposed and said that (1) he is Senior Vice.
i President of Duquesne -Light, (2) he is duly. authorized to execute and file the-foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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-ATTACHMENT:1 V lol at ion 87-18-02 10CFR50, Appendix 8. Criterion. III, -requires ' in part that measures' shall be established to assure that the design-basis;for those structures, systems and components to which Appendix B applies are correctly translated. into specifica-l tions, drawings, procedures ' and instructions.-
These ' design control measures shall provide for verifying' the adequacy ' of. the design such as by the performance of design reviews.
Design changes, including field ~ changes, shall' be subject to design' control. measures commensurate Lwith those applied,to the.
original design.
Contrary to the above, as of March 10,.1987,. the. redesigned power supply.-
circuitry for the Containment Isolation Phase B -(CIB) ' timers (S&W Drawing
. Specifically, this circuitry: was to have been 12241-E-600)~ was not correct.
revised to power the CIB timers from an uninterruptible power source (125 VDC -
battery).
.The redesigned, installed and accepted circuitry ' incorrectly provided power to the CIB timers from an interruptible power source (4160 V emergency bus).
This is a Severity Level IV Violation (Supplement II).
Response
-The ' reported erroneous assignment of the power supply to the CIB timers.
resulted from. incorrect interpretation' of the modified-system operational
' requirements that called for an uninterruptible power ' source.
' Review' of the BVPS-2 established engineering procedures and activities _ associ-ated with this design modification indicates that this incident represents an inadvertent human error rather than a procedural deficiency.
This is based on the fact that the " Administrative Procedure for Configuration the Advance Change Notice (y delineates the responsibilities associated with Control" (2BVM-56A), clearl ACN) system and that procedural requirements were 4
followed.
l These multidiscipline responsibilites include engineering review of the tech-nical content of the proposed changes prior to sign-out and field implementa-tion.
E&DCR No. 0-5169-S06 was issued to correct the power supply assignment.
No procedural changes were deemed necessary.
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r ATTACHMENT 2 Violation 87-18-03 10CFR50,. Appendix B, Criterion V. requires activities affecting quality to be prescribed by documented. instructions, procedures or drawings which. include appropriate quantitative. or qualitative acceptance ' criteria for determining that important. activities have been satisfactorily accomplished.
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In addition, 10 CFR 50, Appendix B,
Criterion X requires a program for-inspection of' activities affecting quality to: be established and executed to veri _fy conformance with documented ' instructions, procedures and drawings for accomplishing the activity.
Contrary to the above, as of March 23, 1987, Specification -2BVS-931 and Inspection Plan 8.1.4 did not contain appropriate qualitative' acceptance criteria and guidance to define and verify the correct installation of Detail "MT" style hold-down clamps at curved sections of cable trays.
Specifically, several -clamps which were installed,in the Control Building (cable tray support 1
(C136) QC-158 per Drawing No. QC4-710-055) were installed such that the clamp orientation with respect 'to the cable tray side tray side rail was not parallel.
This' configuration was unsatisfactory since it was not representa-tive of the installation for which the clamps were qualified.
This is a Severity Level IV Violation (Supplement II).
Response
The Class-IE cable tray support system at the Beaver _ Valley Power Station Unit No. 2 uses industry standard hardware for the majority of. its cable tray to support attachments.
The attachment. mechanism consists primarily of T. J.
Cope.Part Numbers 9017 and 9017A tray clips' (detail "AC" on SWEC Drawing No.
12241-RE-34HE).
The details as shown depict the tray clamp as being ' parallel to the tray siderail.
The engineering intention is that the clip should have full bearing on the siderail when torqued.
Cable tray support members are normally located perpendicular to the run of the tray for both straight sections and fittings.
This allows for routine instal-lation of the tray clips in their intended and proper position.
In the case where the orientation of the tray siderail is not completely perpendicular to its supporting strut and in certain unique curved sections of trays, skewed installation of the tray clip as necessary to achieve full bearing on the side-rail would satisfy the intent of the detail.
In instances where the T. J. Cope clip cannot be properly installed, an alter-native attachment method, also shown on detail "AC", may be utilized.
This consists of an inside tray clip which is thru-bolted to the siderail and then bolted to the support strut.
Other special case tray clips are shown as details "MT" on drawing RE-34KD; "GA",
"GB",
and "GC" on drawing RE-34HP and additional instructions are provided on the drawing to assist in the proper installation of these clips.
In each case, the clamping mechanism is detailed as being parallel to the tray siderail.
Page 1 of 2
y The specific clip installation of the 90* tray fitting at EL 707' of the Control Building, noted by the inspector, was subsequently re-examined by Site Quality Control and a non-conformance report was issued (N&D 39112).
The dis-position details required these clips to be reworked and orientated parallel to the tray siderail.
An engineering walkdown and review of all other 90*
fittings has confirmed proper clip installation.
We believe this was an isolated event. Additional concerns relative to the clip installation at " TEE" tray sections have been reviewed and reanalyzed by engineering (SWEC Calcula-tion #12241-SE34.247) and it was concluded that full bearing is not required at these unique locations.
To preclude the possibility of reccurence of this problem in the future, engineering has revised the applicable drawing to further define the proper method of clip installation in all confic,urations.
Site Quality Control will amend the appropriate Inspection Plans (IPs) to verify that the engineering intent is not compromised, this is schec ' led to be completed by June 12, 1987.
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