ML20237G365
| ML20237G365 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/10/1987 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-7-192, NUDOCS 8708240064 | |
| Download: ML20237G365 (4) | |
Text
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,gpp Aug. 10,'1987 eb a
%Ib Duquesne Udit Beaver Valley No. 2 Unit Project Organization Telecopy 8
S E G. Building
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P.O Box 328 Shippingport. PA 15077 United States Nuclear Regulatory Commission Region I i
031 Park Avenue King of Prussia, PA 19406 i
ATTENTION:
Mr. Edvard C. Venzinger, Chief Division of Reactor Programs
SUBJECT:
Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-34, Final Response
REFERENCE:
- 1) Letter dated June 11, 1987, (E. C. Venzinger to J. J. Carey)
Gentlemen:
The above referenced letter transmitted the NRC contractor report of a comparison of draft Beaver Valley Power Station Unit No.
2 Technical Specifications and the Unit 2 facility.
Duquesne Light Company (DLC) provided an interim response to that report in letter 2NRC-7-176, dated July 15, 1987.
The attachment to this letter provides DLC's final response.
DUQUESNE LIGHT COMPANY L~
J. D. Sieber Vice President Nuclear DGS/ij r M11/DGS/NRC/8734 Attachment AR/NAR cc: Mr. P. Tam, Project Manager (v/a)
Mr. J. Beall, NRC Sr. Resident Inspector (w/a)
Mr. L. Prividy, NRC Resident Inspector (w/a)
INPO Records Center (v/a)
NRC Document Control Desk (v/a) 8708240064 870810 ADOCK0500g2 DR i(\\
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ATTACHMENT Final Response to Inspection Report 50-412/87-34 f
a' The following response is divided into sections corresponding to the sections.
presented in Inspection Report 50-412/87-34.
.This final response addresses those sections'of IR 50-412/87-34 not addressed in the Interim Report.
Section 2.5.c j
The One Line. Diagram, drawing RE-1AV, was revised in issue 10 to incorporate E&DCR D-0289-B0-2 which added the frequency meter.
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-Section 2.5.e.6 The referenced electrical ' panel is a security panel.
Security Equipment Information Tags are used on Security equipment during the startup and testing phases of the Security System.
The tags will be used until Security System i
. testing,is complete. Once the tags are removed, no permanent marking system vill be used to identify security related panels in the field. This will help protect the location of security related panels on a "need to know only" basis.
Section 2.5.f The subject panels, PNL-DC2-21 and PNL-DC2-22, are Category II panels (the inspection report incorrectly identified the panels as "PNL*DC2-21 and-22").
Via Construction Vork Request (CVR) 1008-0C the grounding conductors have been relocated and vill no longer be subject to mechanical damage.
Although Category II installations are not subject to OC inspection, observed instances of damage similar'to that noted would be reported by QC (and others) using the CVR vehicle, as was used in this instance.
It was determined that a special inspection, as a result of the NRC Inspection Report, is not necessary based on the following:
a.
The existing 100% inspection of Category I installations of this type which has been completed by OC.
b.
The site use of the CVR reporting system to identify observed instances of damage or other problems relating to Category II and III installations.
Page 1 of 3
'O c.
The established FCP-421 instructions for protecting exposed ground conductors.from damage.
Section 2.5.g Engineering was' requested to evaluate the identfied conditions via RI-3851 OC.
The results of that evaluation were that areas where cable exits from vertical conduit and then passes through floor penetrations which are offset from the-conduit are not located'in identified walkways or heavy traffic areas and that special protection need not be provided.
The basis for this response is as follows:
1.
The electrical design of the plant provides for careful consideration of precluding installations of exposed cables in identified walkvays and areas of heavy traffic.
In addition, kickplates have been added to protect'those. cable where required installation was unavoidable-adding a sound measure of mechanical protection.
2.
Inspections have been performed for any cable damage at the time that cables have been pulled, their raceways modified, protective or fire wraps added, or fire seals installed.
In this manner, these inspections provide for a controlled documented record of the cable conditions.
3.
As the systems that these cables support have been checked during the testing and startup modes, problems due to potential cable damage, if any,-would be documented, resolved and corrected.
For the reasons as stated above (i.e,
- design, inspection and testing) there exists a very high level of confidence in justifying the present installation and ensuring that these cables vill perform their intended safety function.
Section 2.5.h 1
Since March 1987, the site Records Management Center has implemented a
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" microfilm image quality check" on all Engineering drawings. This activity vill j
be continued by the Beaver Valley Records Center (permanent plant) in accordance
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with Records Management Program Instruction (RMPI) 10.01, step 6.3.
Per this procedure, the original drawing is microfilmed on 35mm film from which a half-site print is made.
This half-size is then scrutinized for legibility, and any unacceptable areas are reported on an Image Rejection Form (RMPI 10.01, attachment 8.6), which is then sent to engineering for enhancement or redrawing of the original as necessary.
Also, in this same time frame, SWEC SEG electrical Group, which reviews most of the design changes, has initiated a Reproducibility Analysis Review Program, which scrutinizes interim design change documents to ensure legibility.
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Through these two efforts, Engineering drawing and design change documents that have been issued or revised since March, 1987 have been specifically reviewed for legibility.
This covers both drawings used for construction and drawings used by the operations and maintenance personnel.
Note that as part of the turnover of Engineering Drawings to DLC (which is done to RMPI 10.01),
all Engineering Drawings vill be checked for legibility as previously described above.
Turnover of SVEC design drawings which began in June, 1987 should be completed in August, 1987.
Implementing these actions vill correct any existing instances of drawing illegibility and prevent future occurrences.
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