ML20215K460
| ML20215K460 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/13/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-7-081, 2NRC-7-81, NUDOCS 8705110206 | |
| Download: ML20215K460 (4) | |
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2NRC-7-08i Telecopy (
Ent.160 Bewe Vall No. 2 Unit Protect Organisation P.O. Box 328 April 13,1987 Shippingport, PA 15077 United States Nuclear Regulatory Comission Region 1 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Steward D. Ebneter, Director Division of Reactor Safety
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-02
REFERENCE:
Letter dated March 12,1987 (S. D. Ebneter to J. J. Carey)
Gentlemen:
l The above refer enced letter tv ansmitted a Notice of Violation as Appendix A.
Attacrvnent 1 of this letter provides Duquesne Light Company's (DLC) response pur suant to the requirunents of 10CFR2.201 and the NRC's Notice of Violation.
in addition, the concern identified in the Inspection Report with regard to the apparent weakness in QA over sight has been addressed.
1 UUQUESNE LIGliT COMPN 1Y ff By J. J. Carey l
Sr. Vice President LMR/ijr NR/lR/b0412 l
Attachment cc:
Mr. P. Tan, Project Manager (w/a)
Mr. L. Pr tvidy, NRC Resident Inspector (w/a)
Mr. J. Beall, NRC Senior Resident inspector (w/a)
NRC Document Control Desk (w/a) 8705110206 070413
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. United States Nuclear Regulatory Commission Mr. Steward D. Ebneter, Director inspection Report 50-412/87-02 Page 2 COMMONWEALTH OF PENNSYLVANIA )
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, before me, a On this Notary Public in and for said -CoffImonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (I) he is Senior Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statenents set forth in the Submittal are true and correct to the best of his knowledge.
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ATTACHMENT 1 N0flCE OF VIOLATION 87-02-02 10 CFR 50, Appendix B, Criterion V requires activities affecting quality to be prescribed by documented instructions, procedur es or drawings which include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisf actorily accomplished.
10 CFR 50, Appendix B, Criter ton X, inspection, requires that a progran for inspection of activities af fecting quality shall be established and executed to verify conformance with documented instructions, procedures and drawings for accomplishing the activity.
Contrary to the above, as of February 3,1987, Site Quality Control Inspection Plan 7.4.1 did not include approprlate quantitative or qualititive acceptance criteria for inspection of HVAC equipnent supports.
Specifically, the accept-ance criteria for such supports were not suf ficiently detailed in that they merely required verification that structur al steel supports wer e acceptable.
Inspection reports for both Diesel Generator Building Sorondary Supply Air Fans (2HVD*FN271A and B) stated that inspection attribute ME-M1-027 (verify structu-ral steel supports) is unsatisf actory since each support had a missing bolt as required by drawings SM-7 and RS-29C.
Reinspections of other HVAC equipnent supports ievealed other bolting nonconformances such as incorrect bolting materials.
This is a Severity Level IV Violation (Supplanent !!).
Response
HVAC f ans (2HVD*FN271A and 2ilVD*FN2718) did not have the cor rect number of bolts attaching than to their structural steel suports, in addition, tack welding of the A-194 nuts for support bolts had not been performed, installation inspections had been performed by QC for these f ans without the unsatisf actory condition of the support bolting being identified.
A review of QC Inspection Plan IP-7.4.1, " Inspection of QA Category I and Other Seismic Heating, Ventilation and Air Conditioning Systons Installation", disclosed that the inspection criteria did not include a specific instruction to verify the bolting of equipnent to supports.
An immediate change was made to IP-7.4.1 to provide instruction for the bolting of equipnent to supports.
A reinspection effort of aII QA Category I HVAC equipnent installations was conducted resulting in N&D's 34,507 and 34,508.
These N&D's identified prob-lens with equipnent bolting in 9 of the 7 7 installations subject to this inspection.
Additionally, a reinspection of all seismic HVAC equipnent instal-lations was conducted resulting in N&D's 34,512 and 34,513.
These NLO's iden-tified pr oblens with equipnent bolting in 3 of 39 installations subject to this inspection.
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l ATTACHMENT 1 (continued)
NOTICE OF VIOLATION 87-02-02 i
l The NRC discussion of Violation 87-02-02 cites similarities with previous Vio-lations 86-31-04 and 86-47 02. Our assessments relative to the nature and root cause of the pr obluns associated with these Violations differs fran that pr esented by the NRC in each case.
These differences have been reflected in our formal responses to these Violations and in the corrective actions we have l
instituted.
Irrespective of our assessments, the NRC description and suppositions presented for these Violations coupled with comments presented for Violation 87 02-02 have resulted in a concern as to the ef fectiveness of our QA oversight.
As a l
result, it has been requested that we address the review of QC inspection guidelines in our corrective action response.
Our process can be summarized as follows:
Formulation of Inspection Procedures is the responsibility of appropriate l
SQC Senior Engineers, inspection Procedures are developed in accordance
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with Procedure SQC-4.1, " Preparation of Inspection Plans".
This procedure includes instructions for the t eview and analysis of all pertinent approved drawings, specifications, referenced codes and standards, and the FSAR in order to establish the attributes to be applied to the inspection.
Guld-ance is also given for the development and issuance of QC Inspection Repor ts.
Formal approval of procedures is retained exclusively within the QC organi-zation.
Review of pr ocedur es, however, involves review by the QC Engineer /pr eparer, the Assistant Dir ector/ Director QC, a Reviewing Engineer frun the SWEC Site Engineering Group, and a Principal Engineer from the SWEC Site Engineering G*oup.
l As our review process pr ewently involves a series of reviews within the QC and j
SWEC Site Engineering Orgnizations, it is our assessment that additional i
review by others would not enhance the process.
Although our assessments have dif fered fran the NRC with respect to Violations 86-3104 and 86-47 02, we are in agreenent with r espect to NRC runarks presen-ted for Violation 87 02 02 in that the QC procedure failed to present to the Inspector the technical criteria provided in engineering drawings.
That our j
review of the procedure f ailed to identify this deficiency, is an oversight on the part of the reviewers and is not an indication of deficiency within the process structure.
As such, we view this as an isolated incident.
In order to determine whether or not additional err ors of this nature could I
exist, our plan for corrective action includes a sanpling review of QC inspec-tion pr ocedur es.
This sanpling includes procedures fran al l disciplines although the primary focus is directed in the Mechanical area.
The objective of this review is to verify technical adequacy as well as compliance with all other instructions as provided in Procedut e 54C-4.1, " Preparation of Inspection Plans."
It is anticipated that this review will be cy,pleted by 4/30/87.
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