IR 05000412/1985007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-412/85-07

ML20135A328
Person / Time
Site:	Beaver Valley
Issue date:	08/19/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carey J DUQUESNE LIGHT CO.
References
NUDOCS 8509100103
Download: ML20135A328 (2)

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AUG 191605

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Docket No. 50-412

! Duquesne Light Company ATTN: Mr. J. J. Carey Vice President

. Nuclear Group ,

. Post Office Box 4 Shippingport, Pennsylvania 15077

, Gentlemen:

l Subject: Inspection N /85-07

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This refers to your letter dated July 26, 1985, in response to our letter dated Jun'e 7, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of

) your licensed program.

l j Your cooperation with us is appreciated, i

Sincerely, l

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J Original Signed By 5 Jacque P. Durr

! Stewart D. Ebneter, Director 1 l Division of Reactor Safety l l ' cc w/ encl:

E. J. Woolever, Vice President, Nuclear Construction Division  :

l E. Ewing, Quality Assurance Manager j R. J. Swiderski, Manager, Startup Group i R. E. Martin, Manager, Engineering i E. F. Kurt::, Jr. , Manager, Regulatory Af fairs

P. RaySircar, Stone and Webster Engineering Corporation Public Document Room (PDR)

Local Public Document Room (LPDR)

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Nuclear Safety Information Center (NSIC)  ;

NRC Resident Inspector t Commonwealth of Pennsylvania  !

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l l OFFICIAL RECORD COPY RL BV2 65-07 - 0001. '

08/13/85

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Duquesne Light C ~

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Region I Docket Room (with concurrences)

Senior Operations Officer (w/o encl)

ORP Section Chief T. Rebelowski, SRI, Millstone 3 RI:0RS h

RI:DRS RI:0RS M Anderson /mnb' Durr Ebneterg 8//6/85 8// i/85 8// //85 W OFFICIAL RECORD COPY RL 8V2 85-07 - 0002. /13/85 L

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'Af n Duquesne L.idit ..,y,g,;,

Nuclear Construction Division (4121 923-1960 Rotnnson Plats. Budding 2. Suite 210 Telecopy 1412) 787 2629 Pittsburgh, PA 15205 July 26, 1985 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Stewart D. Ebneter, Director Division of Reactor Safety SUBJECT: Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/85-07 REFE RENCES : 1) Inspection Report No. 50-412/85-07, dated June 7, 1985 (S. Ebnetter, NRC Region 1, to J. J. Carey, DLC)

2) 2NRC-5-105, dated July 19, 1985 (J. J. Carey, DLC, to Dr. E. Murley, NRC Region 1)

Gentlemen:

Reference 1 requested that Duquesne Light Company (DLC) res po nd to two programmat ic weaknesses ident ified during Inspect ion 85-07. The fo llowing provides DLC response to the identified areas of concer Weakness 85-07-01: " Project Management Changes /NCD Procedures Manual (extract from Reference 1)

Duquesne Light Company (DLC) Project Management and the DLC Nuc le ar Construction Division have unde rgone fr eq ue nt changes during the past year. This is related to changes in the project from a construction-only phase to a construction-startup phase. Evidences of this are:

DLC organizational change s in the past year have resulted in three different individuals handling the duties of HCD Project Manage *

The DLC Nuclear Cons t ruc t ion Division Procedures Manual requires substantial revisions in the arens of Sect ion 1.0, " Management"; Sec-tion 5.0, " Construction"; and Sect ion 7.0, " Project Control."

Response 85-07-01:

All significant changes to the admi ni s t r at ive procedures have been complete Additional minor changes which involve correct ions to job titles and certain review and approval chains are in progress. We expect to complete this ef fort ove r the next several week All necessary revisions will be issued by September 15, 198 m.uDJPW' ,

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', Unitcd Sectos Muclocr Regulctsry Conraissien Mr. Stewart D. Ebn:;tcr. Dircetcr Inspection Report 50-412/85-07 Page 2 Tne changes to the organization, which were identified in the inspection report, reflect the transition of project leadership from our remote of fice's at Robinson Plaza location to the site where the major ef fort is taking plac .

The Construction Department has been eliminated as a distinct departroent with some duties transferring to the Project Controls Departme nt and others to the Startup Grou It is correct that three distinct individuals have served as the project manage However, the changes have reflected an upward wovement of these res ponsibilit ies to the Vice P r es id ent , Nuc le a r , who has been res pons ible for the project since December 198 This trans f e r of responsibilities was made subsequent to the delegation of the day-to-day l responsibilities for BVPS-1 to the Senior Manager which enabled the Vtce j President, Nuclear Group, to devote full time to the BVPS-2 Projec It is considered that the organizat ional changes will facilitate the trans formation from the construction and startup made to an operating plant at the time of fuel loadin As described in our July 19, 1985, res ponse to the SALP, we have retained a consultant to review our existing project organizatio We shall keep you informed if additional changes are undertaken as a result of this revie Weakness 85-07-13: " Engineering / Construction Interf ace in the Electrical Area (extract from Reference 1) ,

Significant overall progress has been made in improving the interface between engineering and construction within the last ye ar . However, there is evidence of lingering problems in the engineering construction interface for electrical construction activities. These include:

A cable pull violation resulting from interf ace dif ficult ies be twe en engineering, construction, and quality contro *

During the inspection, S&W engineering pe rsonnel could not demon-strate that cable sidewall pressure was included in cable pull calculations. For a period of 30 days following the ins pe ct ion , S&W engineering personnel could not demenstrate that cable sidewall pres-sure was satisfactorily considered for all installed cabl *

During the inspection SW engineering personnel could not es t abli sh torquing requirements for bolted connections when terminating 4160 volt power cables to the load side of the circuit breaker stab Inconsistencies exist between electical installation spe ci ficat ion 2BVS-931, the cable terminating field construct ion procedure FCP-432, the inspection procedure IP 8.5.2, and the Sargent Electric Company (SECO) drawings concerning the tightening of hardwar .

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e Unitcd Stctos Nuclect Ragulctory Commission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/85-07 Pege 3 Response 85-07-13:

The NRC's concerns for this area can be divided into two distinct cate-gories, speci f ic concerns and general concerns. The speci fic concerns have been identified as NRC Unresolved items or Violations and are being tracked to ensure timely resolution and comple t ions . Certain of the issues have precipitated changes in the procedures or processes govern-ing electrical activities within engineering, SQC, or the elect rical contracto The general concern, while not ing that significant ove rall progress has been made in the engineering / construction interface, ind i-cates that addit ional attention is required in the speci fic area of electrical construction / engineering interf ac An integrated and detailed plan, entitled the Elect rical Plan Guide (EPG) has been developed and was issued for of ficial project use on June 10, 198 It describes the plans for resolution of engineerig items and

! completion of construct ion and inspect ion act ivities on tasks impo rt ant to the electrical ef for The plan will be kept up to date on a quar-

terly basi The Project has recently undertaken an overall reiew of the BVPS-2 electrical installation specification, the electrical Field Construction Procedures, and the SQC electrical Inspection Procedure The objective of this review is to ensure consistency among these documents aM to ensure each document is complete regarding its purpos The review of the electrical installation specification will identify the bases used to develop the various numerical limits and requirements speci fied and will provide assurance that calcula t ions , codes, or standa rds used as bases for the specification are properly documented. These reviews and any necessary corrective act ions are scheduled to be coisple t ed by September 30, 198 Finally, the staffs of both the Site Engineering Group and the I n t e-grated Construction Support Group have been strengthened through the addition of senior experienced electrical engineer The int roduc t ion of these individuals has improved the interface anong engineering, construction, and quality contro DUQUESNE LIGHT COMPANY SU SCR BED AND- RN TO BEFORE ME Tills a

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Notary Public

$ BY _ u f( Carey SainA u.FAffset.neteaf PeellC Vice President RW/wjs sellPriestost sees.etavia cousff afC0est$siteiIPlats38Pt.14,1905 cc: Mr. B krYeYtY er Mr. G. Walton, NRC Resident Inspector NRC Document Control Desk (w/a)

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United States Nuclost Reguletory Commission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/85-07 Page 4 COMMONWEALTH OF PENNSYLVANIA )

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COUNTY OF BEAVER )

On this M // d day of f/// , / , before me, a Notary Public in and for said Codnwdith and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Vice Preisident of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal' on behalf of said Company, and (3) the state:nent s set forth in the Submittal are true and correct to the best of his knowledg /

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- 1 Notary Public h6 nietna 5. F4 tith. setAtf Putt C lillPPIOGPett 8000. Stevia COUtif 57 C0estl560s Intests MPI 14. IMS Membee Passeyteesee Acestisteen of flotettet

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