ML20126J618

Insp Rept 50-412/85-07 on 850318-29.Violation Noted:Cables Damaged in Cable Raceway 2TC138P & Quality Records Not Maintained for Calculations to Support Pulling of Electrical Cable

ML20126J618
Person / Time
Site:	Beaver Valley
Issue date:	05/31/1985
From:	Anderson C, Ebneer S, Ebneter S, Gray H, Paolino R, Prividy L, Raval J, Schaeffer M, Shaub T, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20126J563	List: ML20126J559 ML20126J614 ML20126J618
References
50-412-85-07, 50-412-85-7, NUDOCS 8506100649
Download: ML20126J618 (67)

See also: IR 05000412/1985007

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report No.

50-412/85-07

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Docket No.

50-412

License No. CPPR-105

Priority

Category

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Licensee: Duquesne Light Company

Robinson Plaza Building No. 2

Suite #210, PA, Route 60

Pittsburgh, Pennsylvania

Facility Name:

Beaver Valley Power Station, Unit 2

Inspection At:

Shippingport, Pennsylvania

Inspection Conducted: March 18 - 29, 1985

C #/ T[

Inspectors:

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C. Andhson,/ Chief, Plant Systems

date

Section

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H. Gray, LyReactor Engineer

date

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R. Paolino, ' Lead Reactor Engineer

date

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L. Prividy, Resident Inspector

date

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J. Raval, Wactor Engineer

date

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M. Scfiaef fer, Re' actor Engineer

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T. Sha\\b, Reactor Engineer

date

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L.' Tri) , Chief," Projects Section #3A

date

Approved by:

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S. D. Ebneter, Director, Division

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of Reactor Safety

date

' Inspection Summary: Inspection on March 18 - 29, 1985 (Report No. 50-412/85-07)

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Areas Inspected: An announced Regional Construction Team inspection of the

Beaver Valley Unit No. 2 facility by regional-based inspectors and the resident

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inspector. The areas of mar.agement, quality assurance, engineering /construc-

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tion interfaces, electrical / instrumentation construction, and installation of

piping, supports, and mechanical components were inspected.

The inspection

involved 928 hours0.0107 days <br />0.258 hours <br />0.00153 weeks <br />3.53104e-4 months <br /> of direct inspection effort (693 hours0.00802 days <br />0.193 hours <br />0.00115 weeks <br />2.636865e-4 months <br /> on-site and 235

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hours in the regional office).

Results: Three violations were identified in the five areas inspected. One

in the area of electrical construction with several examples of problems

resulted from failure to follow procedures. Another in the area of engineer-

ing construction interface (electrical) involving failure to retrieve

records. This violation related to considerations of side wall pressure in

cable pull calculations. The third violation related to numerous examples of

failure to follow procedures involving a lack of attation to detail in pro-

viding correct administrative information on documents.

No major problems were identified during this inspection. The licensee has

made significant overall progress in improving the engineering / construction

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interface with regard to addressing problems and weaknesses identified in the

1984 SALP. This involved the initiation and implementation of several

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programs to correct the problems and strengthening the Site Engineering Group

staff by the addition of key experienced personnel.

There are indications of

lingering problems in the engineering construction interface for electrical

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construction activities.

Several problems were noted in this area, leading us

to conclude that this area is a weakness. Changes in the project over the

past year from a construction only phase to a construction startup phase have

resulted in frequent changes in the DLC project management and the Nuclear

Construction Division with three different individuals handling the duties of

DLC Project Manager and the DLC Nuclear Construction Division procedures manual

in need of substantial revisions in several areas.

This has led us to conclude

that this area is also a weakness. However, no specific site construction

problems have been attributed to the DLC deficiencies in the project management

area.

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In general, the team concluded that the quality of construction is good. An

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intensive and coordinated examination of the. primary component cooling water

(CCP) system by the multi-disciplined engineering team members yielded no

significant negative findings.

Interviews by all team members of approximately

40 site personnel at random, including crafts and level 1 and 2 QC personnel

over a cross section of mechanical and electrical areas yielded no substantial

negative comments. The consistent view of these site personnel was that work

quality at the site is good,

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TABLE OF CONTENTS

Page No...

1.

Persons Contacted

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2.

Purpose and Scope.

3

. 3.

Project Management

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-3'1 -Organization.

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3.2 -Areas Inspected.

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3.3 ' Findings

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3.4 Conclusions

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4.

--Engineering / Construction Interfaces

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4.1 Background and Organization

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4.2 Areas Inspected and Findings

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4.3 . Conclusions

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5.

Quality Assurance (QA)

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5.1 Organization

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5.2 Areas _ Inspected

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5.3' Findings

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5.4 Conclusions

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5.5 Program Review-

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6.

Piping and Mechanical Components

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6 .- 1 Organization

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6.2 Areas Inspected

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6.3 Findings

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6.4 Conclusions

41

6.5 Documents Reviewed

41

7.

Electrical / Instrumentation Construction

42

7.1 Organization

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7.2. Areas Inspected

43

7.3 Findings

43

7.4. Conclusions

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8.

Status of Previously Identified Items

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9.

JInterviews

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10. Unresolved Items and Program Weeknesses

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11. Exit Interview

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DETAILS

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Persons Contacted

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1.1 .Duquesne Light company (DLC)

L. E. Arch, Senior QA Engineer

J. Arthur, Chairman of the Board of Directors

J. A. Bajuszik, Director Construction Engineering

J. J. Carey, Vice President, Nuclear Group

F. A. Cavalier, Manager Project Control

R. Coupland, Director QC

C. R. Davis, Director Quality Assurance

C. E. Ewing, Manager Quality Assurance

E. J. Horvath, Engineer

J. A. Hultz, Deputy Project Manager

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E. F. Kurtz, Manager Regulatory Affairs

C. Majumdar, Assistant Director, QC

T.-P. Noonan, Startup Group

D. F. Rohm, Assistant Director, QC

H. M. Siegel, Engineering Manager

R. J. Swiderski, Startup Manager

R. Wa11auer, Compliance Engineer

E. J. Woolever, Vice President Special Nuclear Projects

1.2 Stone and Webster Engineers Corporation (S&W)

W. Barancwski, Assistant Project Manager

W.' H. Bohlke, Senior Project Manager

A. A. Dasonbrock, Senior Construction Manager

H. F. Foley, Site Project Manager

A. C. McIntyre, Superintendent of Site Engineering

F. N.-Morrissey, QA Project Administrator

J. G. Novak, Superintendent of Construction

W. J. Parker, Assistant Project Engineer

J. H. Ronco, Assistant Superintendent of Construction

C. H. Wilbur, Assistant Project Engineer

J. E. Williams, Senior Construction Manager - Vice President

1.3

U.S. Nuclear Regulatory Commission (NRC)

C. J. Anderson, Chief Plant Systems Section

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S. D. Ebneter, Director, Reactor Safety Division

H. Gray, Reactor Engineer

R. J. Paolino, Reactor Engineer

L. Prividy, Resident Inspector

J. H. Raval, Reactor Engineer

M. J. Schaeffer, Reactor Engineer

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E. T. Shaub, Reactor Engineer

L. Tripp, Chief Projects Section 3A

G. A. Walton, Senior Resident Inspector

The above listed personnel attended exit meetings held on March 22

and/or March 29, 1985. Other managers, supervisors, engineers, quality

technicians and craftsmen were contacted during the inspection.

2.

Purpose and Scope of the Inspection

The purpose of this inspection was to determine the effectiveness of the

licensee's management in directing the construction of Beaver Valley 2 in

accordance with NRC requirements, licensee's commitments and industry

standards. This was accomplished by performing in-depth examinations in

the areas of management controls, design controls, quality assurance, and

construction. The construction area was further divided into the elec-

trical, mechanical, and piping disciplines.

The inspection spanned a six week period and was divided into two weeks

of preparation, two weeks on-site, and two weeks of report writing. The

inspection began with the two week preparation period in the regional

office reviewing the licensee's construction program documents and

familiarizing the inspectors with the organization. The document review

cansisted of the licensee's quality assurance program, construction

procedures, and the Final Safety Analysis Report.

During the inspection a coordinated examination was made of the component

cooling water system by all engineering discipline team members.

Portions of the system were selected and detailed examinations wera made

of the piping, supports, valves, heat exchangers, pumps, and electrical

components. The examinations consisted of visual observations to verify

that the equipment met the drawings and specifications. The quality

documentation was reviewed to confirm that appropriate inspections had

been performed. Other systems and components were examined as time

allowed utilizing similar inspection methods.

An area given special attention was that of the engineering construction

interface. During the past year the NRC had identified a weakness in the

area of the engineering / construction interface. The licensee committed to

take several initiatives to attempt to improve performance in this area.

An examination was made of these initiatives and their implementation.

Concurrent with the foregoing examinations, the remainder of the team

explored the broader aspects of management, quality assurance and

engineering / construction interfaces. There was continuous communication

between team members to identify common deficiencies or strengths. These

in-depth insights were supplemented by interviews of management staff,

engineers, quality assurance auditors and craftsmen.

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3.

Project Management

-3.1. Organization

Project management of Beaver Valley, Unit 2, where construction was

approximately.84*4 complete at the end of January,1985, is accomplished by

a team approach of Duquesne Light Company (DLC) and Stone and Webster

(S&W) personnel. S&W handles the daily activities as the construction

manager while DLC oversees the management of these activities.

The DLC

Vice-President, Nuclear Group, who is located at the site, has the total

responsibility for Beaver Valley, Unit 2. This responsibility includes the

supervision and control of S&W, all contractors, QA/QC work and startup

operations. To accomplish this responsibility, the DLC Vice-President,

Nuclear Group, has a staff of Engineering, Startup and Project Control

Groups which assist him in his decision-making. Also, the DLC QA Manager

reports.directly to the DLC Vice-President, Nuclear Group. The DLC

-Vice-President, Nuclear Group, and his staff interact closely with the S&W

Site Project Manager and his staff to stay abreast of the project's acti-

vities and to provide direction. The S&W Site Project Manager, who

reports directly to the DLC Vice-President, Nuclear Group, has overall

responsibility for all construction. To accomplish this responsibility

reporting.to the S&W Site Project Manager, are the SW Construction Manage-

ment, Cost, Scheduling and Site Engineering Groups which define, super-

vise, coordinate and control all site contractors. The actual construc-

tion work is accomplished by various contractors working for the S&W

Construction Manager. The major contractors currently on site are

Schneider Power Corp. (SPC) for the mechanical work and Sargent Electric

Co. (SECO) for-the electrical work.

3.2 Areas Inspected

The inspector reviewed the current organization charts of the project

management team. Approximately 20 members of the project management team

were interviewed and various meeting reports and procedures were reviewed.

Also, the inspector attended a Site Manager's Meeting. These interviews

and reviews were conducted to determine the impact of organizational

changes on the project management effort, the adequacy of management

ccmmunications and reports, the control of site contractors, management

involvement in the project, and management support of QA/QC activities.

3.3 Findings

3.3.1. Organizational Changes - Impact on Project Management

The current project management team has evolved after a series of major

changes in the DLC and S&W organizations in the past year.

In addition to

these organizational changes, the project has progressed in the past year

from the construction-only phase to the construction-startup phase. A

major factor that has provided continuity to the project in the midst of

these organizational changes and project transition has been the weekly

Site Manager's meeting which is attended by DLC and S&W Site managers and

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contractors as appropriate. At this meeting DLC and S&W management

discuss the status of significant problems and determine their impact on

project construction, thus providing the necessary direction to the

project.

The inspector reviewed the DLC Nuclear Construction Division Procedures

Manual to determine if it was consistent with the. current alignment of

personnel and their responsibilities.

From this review and the interviews

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of personnel, it was clear that the DLC Nuclear Construction Division

Procedures Manual required revisions in several areas as follows:

Section 1.0, Management - The organization chart for the DLC Nuclear

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Construction Division (NCD) needs to be changed to reflect the

designation in March, 1985, of the Vice-President, Nuclear Group as

the individual with the total responsibility for Beaver Valley, Unit

2.

The prior Vice-President of the NCD has been assigned a Special

Nuclear Projects function.

Nuclear Construction Division Procedure

1.2. Functional Organization and Responsibilities, must be revised to

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provide functions and responsibilities consistent with these DLC

organizational changes.

Section 5.0, Construction - Procedures 5.1, Organization, and 5.2,

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Construction Responsibility and Control, require substantial revision

to reflect a major reorganization of personnel who were previously in

the DLC Nuclear Construction Department. This department was dis-

banded around Mid-1984 as the DLC Startup Group was being formed.

Personnel who were previously in the DLC Nuclear Construction Depart-

ment were assigned to other departments while retaining many of

their construction department functions.

Section 7.0, Project Control - The DLC Project Control Organization

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is a relatively new group formed in late 1984. Various procedures in

this group were being revised by DLC to provide consistency with

changes to be made to Section 1.0, Management, and Section 5.0,

Construction, mentioned above.

Also, the inspector learned from various interviews that other DLC organi-

zational changes in the past year have resulted in three different indivi-

duils handling the duties of NCD Project Manager with the most recent

change being that the Vice-President, Nuclear Group, will handle these

. duties.

The frequent turnover of the NCD project manger duties to different per-

sonnel and the lack of current DLC organizational charts with consistent

procedures in the Nuclear Construction Division Procedures Manual are a

deficiency within the project management organization. Although DLC

management recognized the need to upgrade the Nuclear Construction

Division Procedures Manual in these areas and expected this effort to be

-completed by the end of April, 1985, the inspector considered this

deficiency in the DLC Nuclear Construction Division to be a weakness in

the project management organization.

(50-412/85-07-01)

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In contrast to the weakness noted above, the inspector recognized that

DLC and S&W Management had taken the initiative to strengthen the project

management organization by assigning a full time S&W Site Project Manager

and a full time S&W Site Engineering Sponsor. Both of these individuals

have been contributing to the project management effort since late 1984

and their contributions so far have had a positive influence on the

project.

In this regard, the S&W Site Project Manager has been instrumen-

tal in the development of the Quality Improvement Management Plan (QIMP)

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which is discussed further in Section 5.

3.3.2 Management Communication and Reports

Through interviews, reviews of reports and procedures, and general obser-

vation the inspector determined whether DLC and S&W project management

were communicating adequately with all project organizations concerning

the status of activities and problems of the project. The inspector found

that regular reports are distributed appropriately and regular meetings

are held.

Examples of these activities are listed below which indicates

that clear lines of authority and communication are present throughout the

project.

A Monthly Project Status Report is prepared by the DLC Nuclear Con-

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struction Division and distributed to the Central Area Power Coor-

dinating Group (CAPCO), the owner of the project which is comprised

of Ohio Edison Company, Cleveland Electric Illuminating Company,

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Toledo Edison Company, and Duquesne Light Company.

This report is a

comprehensive status of the project in the areas of cost / schedule,

engineering, construction, test /startup, and regulatory affairs.

A semi-annual report is provided by the DLC QA Manager to the DLC

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Vice-President, Nuclear Construction Division. This report gives a

detailed summary of QA/QC activities for the project during the last

six months.

An S&W Headquarters Summary Report is provided monthly to the DLC

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Nuclear Construction Division.

Included in this report is an NRC

Open Items Status List which tracks NRC inspection findings.

Monthly reports are provided by each member of the S&W Site Project

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Manager's staff and the DLC Vice-President, Nuclear Group's staff,

documenting the activities of the respective staffs.

Weekly construction meetings are held by the S&W Construction Manager

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and his building managers to review progress. Weekly progress

reports are issued by the S&W Site Project Manager concerning com-

modities installed and performance achieved.

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Both major contractors, SPC and SECO, report monthly to the S&W Site

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Project Manager concerning their performance toward achieving project

goals in 1985 in the areas of quality control, fiscal plan, schedule,

manpower and productivity.

As mentioned previously, a weekly Site Manager's meeting is held to

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discuss the status of significant problems and determine their impact

on construction. The DLC Vice-President, Nuclear Group, conducts

this meeting. DLC and S&W management and contractors, as appropri-

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ate, participate.

The inspector attended the meeting of March 27,

1985.

It was evident that good communication existed concerning the

16 major items that were discussed.

In addition to these regular forms of communication, the inspector noted

how a recent project issue was communicated within the project---namely,

the issuing of a stop work order on the installation of safety-related

instrumentation tubing.

The inspector reviewed letters issued by the S&W

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Construction Manager to the contractors and S&W Site Engineering Group to

the S&W Construction Manager on this subject.

Based on the review of

these letters and interviews conducted with the various DLC, S&W, and

contractor personnel, the inspector concluded that communications were

clear from the engineering to the contractor level from the time that this

stop work order was issued until approximately one month later when the

stop work order was completely lifted.

No violations were identified.

3.3.3

Control of Site Contractors

Based on interviews and reviews of various documentation, the inspector

assessed the current working relationships of the S&W Construction

Manager, his staff, and the various contractors. In these interviews and

reviews, the inspector also questioned the adequacy of the control of site

contractors in the past year and determined that project management had

recently taken some initiatives to improve the area where high rejection

rates of mechanical work and slow progress of electrical work were being

experienced.

The S&W Construction Manager, who reports to the S&W Site Project Manager,

has the immediate responsibility for project const:uction.

Reporting to

him are key S&W personnel who are managing the various contractor's work.

Since the project is now in the construction-startup phase, construction

management must closely coordinate the construction work with the DLC

startup personnel through an organized system release and turnover pro-

cess.

Various S&W building (e.g., Reactor Containment) managers coordi-

nate their activities consistent with the priorities as defined by the S&W

system release and milestone (e.g., steam generator hydro) managers.

After system turnover to the DLC Startup Group, any work that must be

performed is tracked by a post-turnover work tracking group.

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All cor. tractors report to the S&W Construction Manager and closely coor-

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dinate their work through his staff.

In addition to various engineering

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documents, the contractors' work is performed through S&W approved Field

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Construction Procedures.

SPC and SECO are the major contractors on site

performing the mechanical and electrical work. Other contractors are

present for the insulation, fire protection, structural / civil and painting

work.

The basic planning document that is used to sequence work is the 90-Day

Work Plan which is developed by the S&W Construction Planning Department.

This document is formulated consistent with achieving the major milestones

given in the Integrated Project Plan.

The Core Planning Groups in both

SPC and Seco develop 2-week work schedules to implement the 90-Day Work

Plan. These 2-week work scnedules receive input from the contractor area

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foremen, they govern the daily construction work and they are utilized by

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the S&W building managers for work tracking. The use of the 90-Day Work

Plan in this manner was recently initiated in October, 1984, in an attempt

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to improve the system release process.

In addition to developing this

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schedule document to monitor contractor performance, project management

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The "first time unsat" rate for piping, instrumentation, and HVAC

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Supports was undesirably high in late 1984. Since then great

emphasis has been placed by S&W on a " quality first" method of per-

forming work in the workplace i.e., making sure that the craftsman

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and his foreman build the product to the best of their ability before

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presenting it to QC for final inspection.

In parallel with this

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corrective measure, SPC replaced their Project Manager and Assistant

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Project Manager effective January 1, 1985. The combination of these

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actions has produced a positive turnaround for mechanical work in

early 1985 when the combine "first time unsat" rate for piping,

instrumentation and HVAC inspections decreased from 24% in December,

1984, to 21% in January 1985.

While the above item related to "first time unsat" concerned pri-

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marily mechanical work, control of the electrical work has not been

without problems. Numerous unresolved electrical issues (e.g.,

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unsupported cable length, cable separation to meet Regulatory Guide

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1.75, etc.) are hindering the progress of electrical work.

In an

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attempt to address these issues in a systematic way by blending the

problem resolution into the construction schedule, a Project Elec-

trical Plan identifying 24 outstanding electrical issues was

developed in February, 1985.

The potential benefit in the use of

this plan-is that S&W should be able to better evaluate and control

SEC0's work.

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While it is premature to assess the overall effectiveness of the above

actions taken by project management, these actions are positive and they

are indicative that management is aware of problem areas and is taking

steps to' correct them.

The inspector had additional observations concerning the control of site

contractors as follows:

Currently, there are approximately 2500 crafts performing work at the

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site and approximately 320 personnel engaged in Site Quality Control

(SQC) activities. The SQC personnel report to the DLC-QC Director.

Approximately 100 and 120 employees respectively are involved in the

electrical and mechanical inspection efforts.

The ratio of QC

inspectors to craftsmen is satisfactory.

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There are indications that SPC has strong document control. The

inspector verified that the latest revision (Issue No. 5) of Speci-

fication 2BVS-935, Installation cf Ventilation and Air Conditioning

Systems, was being used. The SPC Document Control Group issued this

latest revision internally to all SPC departments and the inspector

confirmed use of this latest revision in the field by interviewing

the Sheetmetal Superintendent.

No violations were identified.

3.3.4

Management Involvement in the Project

By interviews and review of various documentation, the inspector was able

to determine that DLC and S&W management were actively involved in the

construction of the project. This was demonstrated by the following

items:

The Chairman of the Board of Directors of DLC visits the site at

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least weekly and is briefed on the project status by the DLC Vice-

President, Nuclear Group, who is located on site and is beginning to

devote almost all of his time to the project. The DLC Vice-President

tours the plant several times a week.

The DLC Vice-President, Nuclear Group, conducts a weekly Site

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Managers meeting at the site to discuss the status of significant

problems and determine their impact on construction.

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In late 1984, S&W added two new members on site to the Project

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Management Team - the Site Project Manager and the Site Engineering

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Sponsor who are actively involved in the project.

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There are plans for substantial management participation in QIMP.

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This is a new management system for the regular review of construc-

tion quality performance indicators, clear assessment of the causes

for adverse performance trends, and institution of appropriate

corrective measures for performance improvement.

Senior management

on the QIMP management board are the DLC Vice-President, Nuclear

Group and the S&W Site Project Manager.

Senior management partici-

pation in QIMP has taken the place of a previous group, the Senior

Management Corrective Action Panel, which is being dissolved as

QIMP is being formed.

No violations identified.

3.3.5 Management Support of QA/QC

The inspector conducted interviews with DLC-QA/QC management to determine

if DLC, S&W and all contractors are committed to building a quality plant.

The following observations were made:

DLC has had in place for over a year a Quality Concerns Program that

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enables any employee to report their concerns directly to DLC if

unable to do so through their normal channels. A dedicated telephone

number is assigned to receive such calls. Any such calls and concern

are handled by the DLC-QA Department. This program is visibly

endorsed by the display on a memo signed by the Vice-President,

Nuclear Construction Division which describes the Quality Concerns

Program in detail on employee bulletin boards throughout the plant.

The staffing of the DLC-QA/0C organization appears to be adequate for

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its existing responsibilities.

In the past, there has been adequate

support from DLC management to support increased QA/QC responsibi-

lities with additional personnel.

It is anticipated that the

inspection load, especially in the electrical area, will increase

substantially in the next year which will present a cost considera-

tion for management.

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The recent (March '85) DLC reorganization, where the DLC Vice-Presi-

dent, Nuclear Group was given total responsibility for Beaver Valley,

Unit 2, has presented a unique set of circumstances not previously

encountered in the project concerning the independence of QA/QC from

the pressures of construction cost and schedule. The DLC-QA Manager

now reports directly to the DLC Vice-President, Nuclear Group.

If he

has any concerns that might be in conflict with the DLC Vice-

President, Nuclear Group, the DLC-QA Manager must now approach the

DLC Chairman of the Board. The inspector noted that this was a

potential concern toward future decision-making. However, it does

not reflect on the current or past QA/QC program of DLC, which has

provided evidence of adequate management support.

This potential

concern relates to the contrasting ongoing cost pressures on the pro-

ject as evidenced by a recent decision by CAPC0 to decrease project

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funding by 100 million dollars for 1985, and the above noted pro-

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jected future need for additional personnel to support the QA/QC

inspection effort. This is an unresolved item pending the NRC review

and evaluation of licensee information regarding the reorganization

to assure that QA/QC is independent from the pressure of construction

cost and schedule (50-412/85-07-02).

3.4 Conclusions

The current DLC and S&W Project Management Team has been determined to be

adequate for successfully completing the project.

Senior Management

. involvement in the project has increased and management communications and

reports for the various organizations are satisfactory. Other specific

positive measures have recently been taken which are signs of good project

management such as:

There have been recent additions to the project management team of

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the S&W Site Project Manager and the S&W Site Engineering Sponsor who

both have had prior extensive nuclear experience.

Senior management is placing heavy emphasis on quality as evidenced

-

by the " Quality First" method of performing work and the project

adoption of QIMP.

a Project Electrical Plan has been developed in an attempt to better

-

manage the solution of 24 major electrical issues and integrate the

resolution of these issues into the construction schedule.

While these measures are positive signs of good project management, they

'

have not been in place long enough to determine their overall effective-

ness. The area of DLC project management is considered a weakness. This

is because of the frequent changes within the DLC NCD organization during

1984 a: the project progressed from the construction-only phase to the

construction-startup phase. The weekly Site Managers meeting has been a

positive factor in maintaining project management control in the midst of

this. project transition and project management instability.

In view of the recent DLC NCD reorganization future decision making should

be monitored to ensure that the independence of QA/QC from the pressures

of construction cost and schedule is maintained.

4.

Engineering / Construction Interface

4.1 Background and Organization

4.1.1 Background

i

In the 1984 Systematic Assessment of Licensee Performance (SALP) Report,

weaknesses were identified in this functional area and it was assigned a

Category 3 rating.

In particular, concerns were expressed that engineer-

ing documents frequently failed to contain sufficient information and/or

-

- -

p

n.

.,

12

information that was clear and unambigous enough for field use by Con-

struction and QC personnel. The NRC expressed the view that several

engineering documents had apparently not received adequate " construct-

ability reviews" before they were used at the site, that resolution of

problems encountered in the field was often cumbersome, and that correc-

tive actions usually involved additional inspections but failed to

identify and correct the root cause(s) of such problems. The licensee was

requested to propose a program for resolution of engineering / construction

interface probleas.

In their response to the SALP report, the licensee committed to take

several initiatives to attempt to improve performance in this area.

These included:

-

Strengthening of the Site Er.gineering Group (SEG)

Establishing a constructability review group at the site to review

-

engineering documents before issuance.

Redrafting drawings to clarify details.

-

Improving construction supervision and engineering presence in the

-

plant.

These initiatives and their implementation were included within the

inspection scope in this area.

4.1.2 -Organization

' Stone and Webster (S&W) has the major overall engineering responsibilities

as the licensee's contracted architect engineer. These engineering

activities are primarily accomplished at Boston under the direction of the

S&W Project Engineer. The SEG reports to the S&W Senior Project Engineer

(as does the Project Engineer).

It is responsible to the Project Engineer

for performance of engineering functions as delegated to the SEG.

Primary

SEG responsibilities include:

Providing resolution of engineering problems encountered during

-

construction.

,

Controlling issuance of engineering drawings and field erection

-

drawings / isometrics.

Coordinating Contractor design activities in the areas of seismic

-

conduit, small bore piping, fire protection and HVAC.

(Most of the

Contractor design activities are accomplished by Schneider Power

Corporation and Sargent Electric Company as the primary mechanical

'

and electrical subcontractors respectively).

Interface with Construction and Site Quality Control to clarify

-

engineering requirements.

I

-

-

.

c

3

13

. Maintain close interface with Boston Project Engineering on all

-

field problems or piping / equipment deliveries requiring Boston

Engineering resolution

Provide responses to Requests for Information (RIs) and dispositions

-

for Nonconformance and Disposition (N&D) Reports.

Prepare and coordinate the development of field construction proce-

-

dures.

Evaluate all construction rework.

-

Most original engineering design and analysis activities are done in

Boston in addition to establishing design criteria, control and issuance

of first level type engineering documents, supporting calculations and

. analyses, etc. Sargent Electric Company (SECO) and Schneider Power Cor-

poration (SPC), maintain on-site engineering staffs.

In particular, the

Schneider on-site engineering efforts in translating S&W specification and

orthographic drawings for large and small bore piping were included in

this inspection. Site construction activities are accomplished by the

subcontractors such as SECO and SPC as a part of the site construction

organization under the control of the S&W Site Project Manager (the SEG

Superintendent also reports to the S&W Site Project Manager in addition to

reporting to the S&W Senior Project Engineer).

Since the SEG provides the key interface between off-site engineering and

on-site construction, much of the inspection of the engineering /construc-

tion interface was concentrated on SEG activities with some inspection of

the SPC engineering activities.

4.2 Areas Inspected and Findings

4.2.1 Strengthening of SEG

4.2.1.1 Areas Inspected

The inspector reviewed the organization-and manning levels within the

SEG by comparison of the present organization with that existing

before issuance of the 1984 SALP report on May 18, 1984.

In parti-

cular, the addition of key personnel in management level positions to

provide assistance and support to the SEG Superintendent was

reviewed.

4.2.1.2 Findings

The SEG staffing level was increased from 249 on 5/4/84 to 298 on

March 15, 1985. Of these 298 persons, approximately 76 were engineers,

151 were designers, 14 were model makers and 48 were designers from

Schneider and the S&W Toronto office incorporated into the SEG. Actual

strengths were nearly identical to planned strength. More significantly,

- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -

-

r

.

14

staffing of the SEG had been augmented with the addition of senior tech-

nical personnel. This included a doubling of the number of Assistant

Superintendents (from 3 to 6) by the addition of personnel with consider-

able project and field experience from the Shoreham, North Anna and River

Bend projects. A Site Engineering Sponsor has been added. Although not

in the direct supervisory chain or involved in the routine day-to-day

issues, the presence of this senior management level person provides evi-

dence of added upper S&W management level attention to the BV-2 project.

He acts as an advisor to the SEG Superintendent, is involved in major

policy and management issues, provides guidance for SEG activities, and

gives the SEG office a representative within upper level S&W management.

Finally, as an additional indication of increased staffing, the number of

principal piping engineers within SEG has gone from one to three, the

number of principal electrical engineers has gone from one to two, and a

licensing engineer and a planning group have been added. S&W has also

attempted to strengthen and better integrate the contractor design efforts

by putting two key people in the Schneider organization and a key person

in the Sargent organization and placing Sargent and Schneider construction

personnel into the Integrated Construction Support Group (ICSG); see

Section 4.2.3.

4.2.2

Constructability Reviews

4.2.2.1

Areas Inspected

A Mechanical Constructability Review Team (CRT) was established in early

June, 1984 to address concerns such as cluttered drawings for complex pipe

hangers, confusing and sometimes conflicting installation specifications,

and differences in interpretation between the engineers, crafts and QC

inspectors. Similarly, an Electrical CRT was established in early July,

1984 to address essentially the same types of problems in the electrical

area. These CRTs were composed of S&W, contractor and QC personnel.

Activities of these CRTs including responsibilities, reports, progress and

results were inspected.

4.2.2.2

Findings

By charter, each of the CRTs was limited to new or reissued drawings going

to Construction. Approximately 8-10 people were initially involved with

the Mechanical CRT and 4-5 with the Electrical CRT.

For the first three

months, this was essentially a full time activity for team members.

Initially, the drawing revision rate was high in both areas (approximately

50% and 75% in the mechanical and electrical areas respectively).

The

CRTs provided good feedback to the designers / engineers with respect to

the reasons for drawing rejection (including examples) and provided

training sessions.

The following progress was noted:

-

-

-

.

p

3

15'

The approximately 96 piping rack drawings which had been very complex

-

and cluttered, in that each rack drawing provided support for multiple

piping runs, were broken down to individual drawings for each pipe

support.

In the first three months, approximately 2500 mechanical drawings

-

were reviewed.

By December 1, 1984, 2111 Sargent electrical drawings

had been reviewed.

By late 1984, the drawing revision rate had leveled off to the 3 to

-

5% range in both areas indicating that the maximum impact of the

CRTs had been achieved.

Following the above successes in improving overall drawing quality, in

late 1984, the CRTs were redirected to review drawings only on an audit

basis as on-site and off-site design groups became more proficient at

constructability review during drawing preparation. CRT efforts were

focused on review of drawings for "installability".

Problems with instal-

lation feasibility (approximately 20-30% of support drawings) were identi-

fied in the initial sampling (primarily interferences). Corrective

actions included a mandatory model shop review (where applicable) and a

field check prior to submittal to the CRT. By early March,1985, the

Mechanical CRT was doing both "constructability" and "installability"

reviews on an auditing basis whereas the Electrical CRT was doing " Con-

structability" reviews on all new issue drawings and "installability"

,

reviews on an audit basis.

Plans were being developed to put.the field

"insta11 ability" reviews within the ICSG (see Section 4.2.3).

No deficiencies were noted by the inspector.

4.2.3

Integrated Construction Support Group (ICSG)

4.2.3.1

Areas Inspected

An ICSG was established in late 1984-early 1985 in the plant in a cen-

trally located area (top level of Auxiliary Building, adjacent to the

Reactor Building and Fuel, Service, Main Steam and Cable Vault areas). At

the time of this inspection, it consisted of 72 personnel.

The activities

of this group were inspected including its charter and procedures.

Inspection emphasis was on the functioning of this group including their

involvement and actions in processing and dispositioning Advanced Change

Engineering and Design Coordination Reports (E&DCRs), Construction

Revision. Notices (CRNs) and Nonconformance and Disposition reports (N&Ds).

Other activities of the ICSG were inspected by reviewing internal memos

describing field identified problems and the Field Problem Report (FPR)

log.

,

e _

___

_

_

_

_

I

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e

16

E

4.2.3.2

Findings

The charter and functioning of the ICSG are described in Field Con-

struction Procedure (FCP) 515, " Operations of the Integrated Con-

struction Support Group (ICSG)." This procedure was found to provide

appropriate guidelines and assigns well defined responsibilities for

ICSG field operations.

In particular, it describes the role of

,

ICSG personnel in initiating and processing CRNs, Advanced Change

E&DCRs and N&Ds.

The active role of the ICSG is defined as engineer-

ing involvement in all areas to aid in timely resolution of problems

affecting construction at BV-2.

Production engineering and original

design were not considered to be a part of the ICSG work scope, nor

are such activities being performed by ICSG or SEG.

The ICSG proce-

dure (FCP-515) was found to be consistent with other Project Manual

(2BVM), Field Construction Procedure (FCP), and DLC Site Quality

Control Procedures incorporating such procedures by reference as

appropriate.

l

A sample of twelve (12) CRNs processed by ICSG and applicable to systems

such as the Primary Component Cooling, Safety Injection, Emergency

Diesels, Main Steam System and Safety Injection System were inspected.

Development, review, issuance and control were found to be in accordance

with existing procedures.

A sample of six (6) N&Ds processed through ICSG were reviewed for proper

handling and dispositioning. This included N&Ds dispositioned " Accept as

Is," " Repair", and " Rework".

In all cases, ICSG activities were found to

be in accordance with, " Procedure for Handling of Nonconformance and Dis-

position Reports by Site Engineering Group," 2BVM-218.

A sample of thirteen (13) Advanced Change E&DCRs processed by the ICSG

including the supporting calculations for five (5) of the changes were

inspected.

Except for Calculation Z-16A-097, Rev. 3 in support of E&DCR

No. 2PA-7547 and minor administrative problems with Calculation Z-83A-

332, Rev. 1, involving revision of pages without so indicating and voiding

and adding a new page when there was no change, this sample was found to

have been properly initiated, processed, reviewed and controlled. Calcu-

lation Z-16A-097, Rev. 3, involving reanalysis of a support due to dimen-

sional changes to correct a drawing error (E&DCR No. 2PA-7547) was found

to contain several inconsistencies / deficiencies. Although new design

loads had been generated which, for example, increased the peak loading in

the Y' direction from -748 to -1483 lbs., the calculation preparer had con-

'

cluded that since the new design loads were only slightly more than the

old design loads and were relatively small, they would not affect the

structural integrity of the support (by engineering judgement). A state-

ment on page 7 of the calculation which indicated that the standard strap

used in the support was satisfactory because its capacity of 1000 lbs.

i

i

exceeded the peak load of 748 lbs. was unchanged from the previous calcu-

lation revision. The inspector found that the support design was adequate

despite the inadequate supporting calculation because a later revised

L

e

a

17

calculation for this standard support strap justified a design capacity of

1499 lbs. This inadequately performed and/or documented calculation has

not been cited since it was an isolated example. Neither the inspector

nor a detailed 1984 technical audit of similar cciculations-by a joint

S&W/DLC team found other examples of similar inadequate calculations (see

Section 4.2.4).

S&W committed to correct and revise the subject calcula-

tion.

Other activities of the ICSG were briefly reviewed by the inspector.

It

was noted that the ICSG is performing a field walkdown, Field Investiga-

tion of New Design (FIND), to identify possible problems in installation

such as interferences before the design is sent to Construction for

implementation.

(The Post Accident Sampling System and Emergency Response

Facility design packages are examples). The level of ICSG activity was

observed to be high; during the week of March 6, 1985, 577 problems were

received by ICSG and 555 were resolved. A review of field identified

problems during the week ending March 15, 1985 showed that ICSG personnel

were active in identification of other potential problems before they were

brought to their attention by construction or QC personnel. No other

discrepancies were noted.

.

4.2.4

SEG Activities

4.2.4.1

Areas Inspected

The inspector reviewed other activities involving the SEG (in addition to

the functioning of the ICSG) that pertain to the engineering /construc-

,,

tion interface. . This included SEG monthly reports of activities and joint

DLC/S&W audits of SEG activities. The inspector reviewed the SEG Reports

for January and February,1985 (No. 94 and 95). Two joint audits of the

SEG by DLC/SEG ("SWEC Engineering Assurance Audit of Site Engineering

Group," April 23 - June 20, 1984, EA-319, and "DLC QA and SWEC Engineering

Assurance Audit of BV Site Engineering Group", DLCQA-5571, 12/13/84),

including responses and resolution of selected audit findings, were

inspected.

4.2.4.2

Findings

The inspector determined that SEG activities were being closely

tracked and reported to the Project Engineer.

For each monthly time

period, this included specifications updated, FCPs that were issued or

revised, drawings revised and other site design activities.

In partic-

ular, it was determined that outstanding RI's and N&D's were being tracked

with respect to responsible office, whether or not they affected system

completion and turnover (on turnover lists) and whether or not timely

responses were being received.

Except in infrequent cases, it was noted

that timely' resolutions were being received.

_

_

.

r

18

The DLCQA-5571 SEG audit covered topics such as SEG revisions to drawings;

contractor's (Schneider) small bore piping isometrics; pipe support draw-

ings and calculations; contractor's (Sargent) seismic conduit layout

drawings; Advanced Change E&DCRs; and followup on selected SALP commit-

ments (constructability review and ICSG).

The inspector found that the

auditors used detailed checklists based upon procedural requirements con-

tained in applicable project 2BVM and FCP procedures. The inspector

determined that the audit established that the sampled drawings, calcula-

tions, Advanced Change E&DCRs, etc. were being processed, reviewed and

approved in accordance with existing procedural requirements. Outstanding

N&Ds and E&DCRs were found to be adequately monitored in computerized

tracking systems and incorporated within the prescribed 90 day time

period.

The EA-319 audit was found to be technical in nature involving several S&W

engineering specialists from the Engineering Mechanics, Materials

Engineering, Power and Control Systems Divisions / Departments to provide

additional scope and technical depth in addition to S&W Engineering Assur-

ance personnel. The audit involved approximately 2500 man hours including

two weeks on site (April 23 - May 4, 1984). The purpose of the audit was

to evaluate the design process by assessing the technical adequacy of

designs / design changes accomplished by the SEG.

The inspector reviewed

the audit results and found that they do not appear to be indicative of

any generic weaknesses in SEG. The audit findings demonstrated the

technical nature of the audit coverage. The inspector reviewed the

responses and resolution for the following audit findings: 12241-182-2,

12241-184-1, 12241-185-2 and 12241-187. Audit responses were found to be

required to identify cause, extent of condition, corrective actions and

actions to prevent recurrence. The lead auditor had evaluated the

responses, and determined if they were satisfactory or if additional

followup actions were required.

These audit findings had been closed.

The inspector found that audit responses were required to be thorough as

-

evidenced by the depth of response, evaluation and followup actions.

No deficiencies were noted. The EA-319 audit was found to be excep-

tionally technical in nature and scope.

4.2.5

Engineering /Ccnstruction Interface for the Component

Cooling Water Systems

4.2.5.1

Areas Inspected

The inspector reviewed documentation and held discussions with S&W and SPC

personnel to determine the adequacy of design change control measures

implemented on this system.

The documentation review consisted of a ran-

dom selection of Nonconformance and Disposition reports (N&Ds), Engineer-

ing and Design Coordination Reports (E&DCRs), Bolted Joint Data Sheets,

Flush Breaks, In-Process Check Lists and drawing control.

4.2.5.2

Findings

_- __

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0

19

Nonconformance and Disposition Reports (N&Ds)

SPC is not involved in approving N&Ds.

However, they have to incorporate

N&D resolutions into small and/or large bore IS0s.

The inspector reviewed

the N&Ds and affected documents, as listed in Table 4.2.1.

No violations were identified.

Engineering and Design Coordination Reports (E&DCRs)

SPC incorporates the required input per E&DCRs as approved by S&W into SPC

IS0s. The inspector reviewed the E&DCRs and affected documents listed in

Table 4.2.1.

No problems were observed in SPC's translation of E&DCR requirements into

affected SPC documents.

Bolt Joint Data Sheets (BJDSs)

The SPC-QA program requires BJDSs to be generated per FCP-208 for all

bolted joints in ASME III, Class 1, 2 and 3 piping systems. The SPC Chief

Site Engineer / designee prepares and processes a 3JDS for each bolted joint

in an ASME system. The SPC Building Manager /delignee assigns construction

hold points and presents the BJDS to the SPC Site QA Manager / designee for

review, approval and assignment of quality control hold points, as appro-

priate. Upon approval by the Site QA Manager / designee, the BJDS is

presented to the Authorized Nuclear Inspector (ANI) for review and appro-

val by the SPC Resident Engineer / designee. Once all involved parties have

concurred, the Chief Site Engineer places the BJDS in the traveler packet

and notifies the SPC Building Manager to execute the work. Once the

hydrostatic and flushing are completed, the SPC Construction Superinten-

dent / designee, the SPC-QC Inspector, and the ANI sign the " Bolted Joint

Accepted" portion of the BJDS. The original completed and accepted BJDS

is forwarded to the SPC ASME Engineer via the Chief Site Engineer for

retention.

If the joint is broken following final acceptance, the BJDS is

stamped " superseded" and a new BJDS is initiated as described above.

The inspector reviewed the following BJDSs and found them appropriately

executed:

1)

ISO 107218-0C, MJ-1, on line 2CCP-006-327-3

2)

ISO 107218-0C, MJ-2, on line 2CCP-006-327-3.

No violations were identified.

Flush Break Joints

The S&W project document 2BVM-340, " Procedures for Identification of Flush

Break Joint," requires Flush Break Joints to be identified for verifica-

tion of system cleanliness until the required testing has been completed.

-

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~

F

.

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20

The SEG issues the Flush Break Identification Forms (FBIFs) to SPC to

identify holds on specific joints, and these joints are not to be com-

pleted until the joints are released after cleanliness verification. SPC

follows FCP-208 to implement the Flush Break Joints requirements. The SPC

Building Manager, upon receipt of the FBIF, maintains Flush Break Points

in an uninstalled condition with the required minimum clearance require-

ments. The original FBIF is sent to DLC-SUG for post-turnover holds or

sent to the SPC - Test Superintendent for pre-turnover holds and is main-

tained by the holder until completion of the required testing for clean-

liness verification. Once cleanliness is verified, the FBIF holder

obtains the required restoration signatures and returns the completed

FBIF to SEG. When DLC/SVG initiates a Flush Break, the DLC Flush / Hydro

Supervisor is required to sign the FBIF and forward it to SEG via the

Principal Advisory Engineer. The SEG logs the status of the FBIF and

turns the completed FBIF over to the S&W Records Management Center for

distribution.

The inspector reviewed the following Flush Breaks and found them in

compliance with the identified procedures:

lSys.Rel l Cleanliness Verification l Flush

l Weld

l

No.1 No.

I Drawing

l Break No. I

No.

I

I

I

I

!

1 l 13A

lRSS-13A

l 106

l2RSS-064-F04

l

2 l

6

l SIS-11A

l 16

l2 SIS-289-F02

l

3 l 10

lRHS-10

l 12 & 13

l2RHS-013/006-F10l

4 l 10

lRHS-10

l

1

l2RHS-018-F11

l

No violations were identified.

In-Process Inspection Check List (IPCL)

The IPCL is part of the SPC-QA program and administered in accordance with

FCP-208 requirements. When special installation controls or inspections

are deemed necessary in addition to the weld and bolted joint control, the

SPC site QA Manager / designee prepares an IPCL based on inspection require-

ments in design specifications and work sequences in applicable project

procedures and control documents, e.g., CRNs, N&Ds, etc. The SPC QA

manager assigns QA hold points and forwards to the ANI for review and

assignment of hold points. Then, the IPCL is forwarded to the SPC Project

Manager for review and assignment of construction hold points. After the

above described process, the IPCL is sent to the SPC Chief site Engineer

for distribution to the appropriate construction departments for inclusion

in the traveler packet. The SPC-Chief Site Engineer maintains a log

controlling issuance and return of IPCLs. The work is not allowed to pro-

ceed beyond any hold points without the acceptance of the SPC-construction

representative, site QC Inspector or the ANI for their respective hold

points. Upon IPCL completion, the SPC-construction representative returns

the IPCL to the SPC-Chief Site engineer and then returns it to the SPC-QA

manager for closure. After closure of the IPCL, it is forwarded to the

ASME engineer for inclusion in the quality record file.

The inspector

reviewed the following IPCLs and verified compliance with the identified

requirements:

- -

-

-

.

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21

1)

IPCL No. 1332-I for Mark Piece No. 2CHS-TK21A, ISO No. 108352, 1C

2)

IPCL No. 324 for Mark Piece No. 2CCP-PSA077, ISO No. 107207, IF

No violations were identified.

Drawing Control

The inspector reviewed documentation and held discussions with the SEG

and SPC engineering personnel to determine the adequacy of drawing

control.

S&W is responsible for flow diagrams and piping ortho-

graphics. The SEG revises the onsite specifications, drawings and proce-

dures per resolutions of E&DCRs and N&Ds as applicable.

S&W prepares the

detailed orthographic drawings for large bore piping for SPC's preparation

of IS0s.

S&W does not provide the detailed orthographic drawings for

small bore piping, however, SPC prepares detailed IS0s for the small bore

piping. SPC Change and Reporting System Procedure, EDM-83-116 identifies

the requirements to incorporate the changes in their IS0s due to N&Ds,

E&DCRs and RP, RB, and RM drawings via SPC in house Engineering Change

Notifications (ECNs). Drawing control, development, review and approval,

distribution and revision-in process are accomplished by SPC in accordance

with the requirements of FCP-208, Control of Fabrication and Installation

Processes for Piping Systems.

The inspector selected the following PCCW

System drawings to verify against document control records for proper

revision:

Drawing

Revision

Drawing

Revision

109905

1G

110479-113-009

4

110702

3G

110479-113-008

4

110703

OH

110479-113-003

3

110704

OG

CI-410-631

2

110709

0F

CI-410-636

4

110711

IF

CI-410-626

5

109901

3H

CI-410-620

6

109902

2G

CI-410-629

3

107224

00

CI-410-639

4

107223

OG

CI-410-637

4

107225

IL

107222

1H

107206

IL

107203

OH

110756

20

107209

1G

110743

1C

110683

2

107210

1M

109907

2F

107211

1F

107214

OM

>

The above posting records were verified to be accurate.

No violations were identified.

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.

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.

.

.

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4.2.6

Trending and Design Change Control

4.2.6.1

Areas Inspected

Trending and change control at BV-2 has been monitored / evaluated by

several mechanisms. The inspector reviewed systems being used by the

ICSG for tracking / trending problems; E&DCRs and CRNs; DLC/S&W management

activities to determine the origin of engineering and design changes;

trend analyses of changes and the Duke Power May 30-31, 1984 evaluation

of BV-2 change control.

4.2.6.2

Findings

The ICSG was found to be tracking Advanced Change E&DCRs by cause codes.

Typical cause codes were rebar interference, support member interference,

incorrect / insufficient weld, and drawing errors.

Similarly, Problem

Reports and CRNs were being coded / tracked.

These efforts were too recent

(only since January 1, 1985) to provide bases for significant trending,

conclusions or feedback.

A five man team from Duke Power made a site assessment at BV-2 on May

30-31, 1984 including the overall design change process. The inspector

found that several concerns were expressed including lack of notification

to construction that design changes are coming, that the volume of changes

was excessive (criteria or bases for this ccnclusion were not given), that

the process required to make tb design changes was large and that a

review should be done to deterd ne the root cause of the large volume of

changes.

The inspector fousd that several of these concerns have received

additional evaluation and/or followup actions as discussed below.

The inspector found that DLC and S&W had held a series of management

meetings in mid-1984 to discuss the origin of engineering and design

changes and develop ways to trend them.

In the fall of 1984, meetings

were held to discuss the results of trend analysis over the first nine

months of 1984.

"Cause of Change Categories" were grouped into eight (8)

major categories and numerous subcategories. The inspector determined

that DLC/S&W had concluded that there were no appropriate major actions

that could be taken to reduce the number of changes beyond those already

planned.

Three causes of changes were identified where some actions were

already being planned / implemented and/or subsequent actions have been

initiated to attempt to address the problems. They were: (1) interfer-

ences - increased emphasis on use of model and in plant walkdowns before

design documents are finalized; (2) inconsistent documents -increased use

of Advanced Change Notice to identify affected documents when major

changes are made and a review of all FCPs and Inspection Plans against the

specifications which was accomplished in mid-1984; and (3) insufficient

information - CRT offorts have included this area.

.-

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23

The inspector reviewed the number and nature of the above design changes.

Although the number of changes appears to be high (for example more than

7000 design changes or changes in supporting design documentation were

made during January - Septeraber 1984), no definitive trends beyond those

previously identified by DLC/S&W could be ascertained. Trend analysis

summaries continue to be issued at three month intervals.

The inspector reviewed the causes for approximately 75 support calculation

changes.

This included 20 pipe stress recalculations due to changes such

as piping or support relocation, changed function and a licensing change

to provide for charging pump miniflow capabilities.

It was evident that

changes occur due to a wide range of causes.

When more restrictive changes are made to acceptance criteria, the inspec-

tor questioned how existing installations are treated (i.e. extent of

applicability of such changes to past work and/or justification for accep-

ting past work "as is").

The inspector found that the project had no

formal procedures for clearly delineating the methodology used for dis-

positioning previous work when such changes are made.

In some cases, t,e

inspector found Engineering issued instructions at the tin,e the change was

-made with respect to the need for rework, reinspection or justification

for " accept as is".

It was determined that QC often identifies such

changes during their review of revised documents (such as specificatlons)

to see if Inspection Plan changes are necessary. When such changes are

identified by QC, the inspector found that they write memos to Engineering

'

to get guidance with respect to whether backfitting of the change is

necessary. However, DLC/S&W personnel were unable to provide appropriate

assurance to the inspector that all past changes involving more restric-

tive criteria had been properly considered with respect to whether backfit

to existing work was required in that a systematic approach had not been

applied in the past for such changes. S&W personnel committed to revise

existing procedures dealing with changes by the SEG to Specifications (2

BVM-204) and Drawings (2V-BVM-203) and similar procedures applicable to

Boston Engineering to require engineering criteria changes to be evaluated

for scope of impact and implementation.

Such evaluations will be required

to explicitly address specific rework, reinspection or justification to

" accept as is".

However, at the end of this inspection, final decisions

had not been made with respect to what to do to assure that past engineer-

ing criteria changes had been properly considered for existing work. This

item remains unresolved pending completion of procedural changes and

further review to determine if the effect/ impact of past chariges to

engineering criteria were properly considered for existing work

(50-412/85-07-03).

No other problems or discrepancies were identified by the inspector.

!

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,

.

24

.

I

4.2.7

Primary Component Cooling Water (CCP) Walkdown and Turnover

4.2.7.1

Areas Inspected

The inspector determined that the ICSG had performed an extensive walkdown

of the CCP system during the week of March 11, 1985 just prior to this

inspection.

It identified numerous discrepancies in the CCP system.

In

i

that most of the CCP system had been through system turnover, the inspec-

'

tor was concerned that several of the items identified in the CCP walkdown

might not be included in site work tracking systems. A review was made of

l

the findings of the ICSG CCP walkdown versus the site work tracking

systems.

4.2.7.2

Findings

It was found that the ICSG walkdown identified numerous items (approxi-

mately 31 total) in portions of the CCP system that had been through

turnovcr that should have already been identified and be in site work

tracking systems.

Typical items included interferences, loose bolts

i

and spacers, missing components and damaged equipment. At the inspector's

request, site personnel compared all items as identified during the walk-

down with existing turnover lists.

Licensee and S&W personnel were able

to demonstrate that, with the exception of minor discrepancies, all such

walkdown findings were previously either in the Exception Work Tracking

system or other site tracking systems such as the open items list, had

previously been identified and " accepted as is," or were scheduled to be

checked and/or adjusted at a later date (such as after hydro). The most

significant exception was a support that did not agree with cantilever

guidelines (7 foot cantilever versus guideline maximum of 4 feet).

Although the support was not overstressed, a change was made to add a

cross brace for stability. No other significant problems were noted.

The

inspector noted that this was a good test of the turnover inspection and

tracking system in that all ICSG identified walkdown itens that should

have been in a site work tracking system were so found.

4.3 Conclusions

All commitments made by the licensee in this area following the 1984 SALP

were found to be in place and fully implemented. The SEG has been sig-

nificantly strengthened by the addition of key experienced personnel.

Constructability reviews of Mechanical and Electrical drawings has led to

a marked increase in the quality of such documents. The ICSG has sig-

nificantly enhanced the engineering / construction /QC interface by improving

the availability and timeliness of engineering involvement in problem

resolution. Detailed systematic audits of SEG activities are being per-

formed including an audit in April - May 1984 that was exceptionally

thorough in terms of technical nature and scope. These audits provide

further assurance of the adequacy of design and design change work

accomplished by the SEG.

The engineering / construction interface was found

- -

-

-

.

- -

=0

O

25

to be effective for the component cooling water system in that a coherent

flow of correct up-to-date documents existed to support construction.

Extensive analyses and trending of changes and their causes is being

accomplished, however, only limited actions to attempt to reduce the

number of changes have been initiated. The number of design changes

l

and/or changes in supporting design documentation remains high.

The

turnover process appears to be successful in identifying and tracking

existing hardware discrepancies.

In summary, significant overall progress in improving the engineering /-

construction interface has been achieved within the last year. This

'

is particularly true of mechanical activities. However, in the electrical

area there are indications of some lingering engineering / construction

interface deficiencies. These deficiencies are discussed further in

Section 7.4.

In general, previous problems and weaknesses identified in

the 1984 SALP have been satisfactorily addressed. However, in light of

the electrical deficiencies identified in Section 7, additional attention

to the engineering / construction interface area is warranted in the

electrical area.

5.

Quality Assurance (QA)

5.1 Organization

The Duquesne Light Corporation (DLC) Quality Assurance Unit is located

onsite and reports directly to the Vice President, Nuclear Group. The QA

organization has four sections and the Site Quality Control (SQC) group.

The organization prcvides QA overview and independent inspection for both

units 1 and 2.

The QA unit provides review of the QA program and procedures; audit and

overview of construction related activities including procurement

engineering, (both on and off site) design, and installation; and quality

control independent inspections and surveillance.

The inspector discussed the QA organization and responsibilities with

QA/QC personnel and verified the organization was established and opera-

ting in accordance with the current QA program.

5.2 Areas Inspected

The DLC QA program, as applicable to engineering and construction of

Beaver Valley Unit 2, was inspected for conformance to the requirements

and procedures referenced in paragraphs 5.5.1 and 5.5.2.

The inspector

reviewed recent audits, the independent QA program assessment, audit

schedules, QA staffing, organizational interfaces, and training and quali-

fications.

SQC activities reviewed included organization; inspection,

I

4

,

"

26

sample reinspection and re-verification programs; system turnover /startup

'

activities; measuring and test equipment control; and, nonconformance and

deficiency trending (corrective actions).

5.3 Findings

5.3.1

QA/QC Organization and Interfaces

The inspector reviewed the QA/QC organization and interfaces with regard

to related attributes and concluded that:

QA/QC staff was as specified in the QA/QC program organizational

--

charts;

QA/QC staffing was sufficient to perform their responsibilities;

--

There were adequate interfaces with and audits of other

--

organizations;

QA/QC activities received adequate support from upper level

'

---

management;

Management of QA activities was effective; and,

--

QA/QC management was aware of and involved in resolution of site

--

quality concerns.

The inspector reviewed the minutes for the last five Wednesday weekly

site manager's meetings and the Friday staff meetings and verified QA

presence and involvement. QA does not participate in scheduling and

planning of activities but participation in the two weekly staff meetings

keeps QA aware of project schedules and problems.

Interfaces with other organizations consisted of periodic audits and

participation in contractor audits of construction and engineering

activities as well as participation in corrective action and quality

improvement programs.

The QA department has recently evaluated the staffing needs for unit

operations and is currently pursuing authorization to fill the projected

manpower needs.

No violations were identified.

5.3.2

Audit Program

The DLC quality assurance program requires a comprehensive system of

planned and periodic audits to verify compliance with all aspects of the

"

QA program as it implements 10 CFR 50 Appendix B, and to determine the

effectiveness of the program.

-

- -

- - -

.

-

q

w.

27

l

l

The following documents were reviewed to determine the depth and scope of

the audit program.

1985-86 audit schedule

--

12 audits

--

DC-2-85-02, Station Quality Control

DC-2-84-12, Protective Coatings

DC-2-84-25, Startup Group

DC-2-84-31, Electrical Installation

DC-2-84-23, Unit 2 System Release / Turnover

DC-2-84-33, Site Engineering Group (SEG)

DC-2-85-04, Engineering Assurance

DC-2-84-11, Procurement Quality Assurance

S&W Engineering Assurance Audit of SEG

DC-2-84-21, S&W Unit 2 Project Boston

DC-2-84-35, BV-2 Nuclear Construction Division

.DC-2-85-12, Nondestructive Examination

Training and Certification for Five Lead Auditors

--

Audit status files

--

Open item file and auditor " tickler" files

--

Cooperative Management Audit Program; 1984 audit and 1985 scoping

--

documents

From the review the inspector verified the following:

Audits were conducted by the licensee or by a joint effort with S&W to

--

assess all aspect of the QA program.

Audits performed were in depth and addressed audit effectiveness

--

Responses to audit findings and observations were timely and adequate

--

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _

_

e

s

28

Followup verification or re-audit was performed to verify

--

implementation of corrective action

Audits were performed as scheduled or modified according to plant

--

activities.

In addition to audits the QA unit performs surveillance of NDE activities

and plans to develop a surveillance program for the preoperational and

startup testing programs.

Based on the above review and discussions with QA personnel the inspector

determined that the audit program was being effectively implemented. Most

audits were not just programmatic but included field observations and

independent inspection. However, as discussed in paragraph 8.2, the

licensee has not formalized a method for assuring that all elements of the

quality program are considered or addressed in the audit schedule.

No violations were identified.

5.3.3

QC Inspection. Reinspection and Reverification

5.3.3.1

To develop an inspection program all specification and change documents

are submitted to QC engineering.

Inspection plans (IPs) are developed by

QC engineering for each specification and then reviewed by the design

organization to ensure proper interpretation of requirements.

Inspections

are then performed on safety related construction activities utilizing the

approved inspection attributes.

The inspector verified adequate implementation of the inspection program

by reviewing completed inspection reports generated for concrete anchor

bolts, cable terminations, welding and cable pulling activities; and

accompanying QC inspectors during inspections.

In addition the inspectors

witnessed in process cable pulling activities and independently verified

safety related cable terminations.

Problems were identified during the

cable pulling activities, refer to section 7.3.2.1 for detafis.

5.3.3.2

The sample reinspection and support weld reverification programs were

established by the licensee due to problems identified with the adequacy

of QC inspection.

IP7.1 " Sample Reinspection" and IP 10.4 " Support Weld

Reverification" were developed to administer these programs.

Records of reinspection for 10 inspections from various disciplines were

reviewed. The inspector discussed the reinspection program with QC lead

inspectors and engineers and noted that "unsats" identified during rein-

spection are documented and evaluated to identify any adverse trends,

necessary reinspection or inspector retraining. The inspector accompanied

QC supervisior on reinspections and verified adequate implementation of

the reinspection program.

.

. _ _ - _ - _ _ _ _ _ _ _ - _ - _ - _ _ - - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _

!.

29

.

Inspection reports SWR-C-307 through 315 were reviewed for support

!

reverification inspections. The inspector verified through discussions

l-

and direct observations that the QC inspector was aware of the inspection

l-

criteria and performed a thorough inspection for each welded support.

Based on the above review and observations the NRC inspector concluded

that the sample reinspection and welded support reverification programs

i

were being effectively implemented and provided a mechanism for QC

l

management to evaluate QC inspector performance,

i

5.3.4

System Release and Startup

To coordinate QC activities associated with equipment turnover and startup

activities the licensee has estabitshed a QC section for startup. The

i

group is responsible for the turnover documentation, ensuring all appli-

,

l

cable QC inspections have been performed and/or identified, surveillance

of some startup activities and control of reinspection for systems

released to the Startup Group. The inspector discussed the turnover pro-

cess with QC personnel and reviewed turnover package SR-15A-18, Component

Cooling Water. A random sample of drawings associated with the package

was selected and verified that documentation was available to support

Bolted Joints, QC inspections, and rework control.

In addition the in-

.

spector physically verified the installation of hanger RK-303-MA and the

!

accepted attributes from QC inspection MEMR-380.

Startup test procedures,

requiring lifted leads, were sampled and the inspector verified that these

leads were included in a QC tracking system for reinspection.

To date the QC Startup group has not formalized programs to provide track-

ing and reinspection, however the lifted leads discussed above are being

,

tracked and will be included in the formal program. Overall to this point

i

the QC startup group has provided an effective focal point for turnover

documentation, tracking, and scheduling of associated QC activities.

5.3.5

MeasuringandTestEquipment(M&TE),

'

SQC 1.0, General Procedure for OLC/SQC calibration; SQC 5.10 Control of

Measuring and Test Equipment; FCP-410, Calibration of Crimping Tool; and

FCP-501, Control of Measuring and Test Equipment establish the program for

control of measuring and test equipment. The inspector reviewed the docu-

ments listed above and verified that the program contained the following:

!

responsibility for control and calibration of M&TE was delineated

--

l

a calibration schedule was maintained

--

M&TE records were adequate and maintained

--

storage, labeling and issuance of M&TE were adequate

--

t

.

i

l

l

t

h

'

,

!

'

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-

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-

- .

- -

-

- - .

-

-

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. _ _ _ - - . _ _ _ _

o-

30

M&TE usage was traceable to evaluate the impact of out of

--

calibration equipment

calibration of M&TE was traceable to NBS standards, or adequate

--

justification was provided

M&TE was calibrated with standard or calibration equipment with 2 4

--

times the accuracy

Test equipment that was used by the crafts and QC inspectors was sampled

and the calibration and tracebility records were examined. The following

test equipment records were reviewed and the inspectors verified current

calibration on traceability of the calibration device:

S-26-117, clamp on ammeter

--

S-24-118, AC-DC voltmeter

--

E-43-2143, Tension Tester

--

E-25-2270, Megger

--

E-25-1488, Megger

---

E-25-1669, Megger

--

The inspector randomly selected the following laboratory calibration

equipment and verified <:urrent calibration and traceability to NBS

standards.

A-11-028 surface plate

--

A-11-026 Dead weight tester

--

A-12-029 Torque tester

--

A-11-964 & 967, Reference thermometer

--

B-16-1410, Absorption Spectrophotometer

--

B-12-25, Fluke 8000A Ditigal Multimeter

--

FCP - 410 controls the calibration and usage of crimping tools. Crimping

tools AY-2 and AY-59, identified on completed cable termination tickets,

were selected.

The inspector witnessed sample connections made with these

tools and the pull tests for each of the connections at the SECO tool

issue station.

The calibration data for the "go-no go" gauges used at the

tool issue station to calibrate the crimping tools was reviewed and found

acceptable.

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.

{

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e

31

No deficiencies were identified. The SECO M&TE issues station is consi-

dered to be a strength in this project in that it provides a comprehensive

and effective program for the control of SEC0 measuring and test equip-

,

ment.

5.3.6

Corrective Actions

The Site Quality Control Trend Analysis Committee (TAC) reviews Construc-

tion Deficiency Report, Nonconformance and Disposition Reports, Inspection

Reports, and NDE Reports to determine if there are any recurrent unsatis-

factory conditions. The committee meets on a monthly basis to discuss and

evaluate the findings for each discipline. Any trends identified are

reported to the Corrective Action Committee (CAC). The CAC meets monthly

to evaluate trends, determine the cause and recommend or request correc-

tive actions.

The CAC's scope is not limited to TAC trending, they

evaluate any site problem brought to their attention.

The inspector reviewed the minutes of the last 5 TAC and CAC committee

' meetings and verified that the recommendation were reviewed and acted on

accordingly by the CAC. The CAC corrective action log was reviewed and

discussed with the CAC chairman. The inspector verified that corrective

action was taken in a timely manner.

The inspector attended the March 22, 1985 TAC meeting and noted the

committee members provided reasonable evaluations for CORs and N&Ds,

including an assessment of the problems and proposed corrective actions.

Recently the licensee has taken the initiative to organize the Quality

Improvement Management Program (QIMP). QIMP will provide a management

system for reviewing and evaluating construction quality performance in-

dicators.

Initially QIMP will track installation data on five commodi-

ties; large and small bore supports; terminations; seismic conduit and

supports; stainless steel instrumentation tubing and supports. The

criteria for evaluating construction quality performance will be QC

acceptance / rejection (rejection rate) of installations submitted for

inspection.

These evaluations will be provided to the responsible con-

struction manager and will require corrective action.

The activities of the CAC will be incorporated in the QIMP Assessment

Panel. The inspector reviewed the first three weeks of data collected

and evaluated, and discussed the process with the QIMP coordinator.

Based on the above review of meeting minutes, records and discussion the

!

inspector determined that the TAC and CAC were functioning effectively.

At the time of the inspection the QIMP was just being formalized but

should provide DLC with a strong management tool to access the quality

of construction activities.

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.

3

.s.

32

5.4 Conclusion

The QA and QC programs are well defined and adequately implemented. QA/QC

personnel are cognizant of plant activities and involved in the site Cor-

rective Action and Quality Improvement Programs. The audit program was

well controlled and conducted in an effective manner by qualified person-

nel. The audits addressed programmatic concerns, implementation and in-

cluded independent verification or observation of the work activitias.

QC is effectively administered by DLC. QC has provided additional inspec-

tion efforts in identified problem areas and performed in a manner to

ensura a high level of quality.

The SECo Measuring and Test Equipment

Issues station is a strength of this site.

5.5 Program Review

5.5.1

References / Requirements

ANSI N45.2 - 1981, Quality Assurance Program Requirements for

--

Nuclear Power Plants.

ANSI N45.2.12, Draft 3, Revision 4 - 1974, Requirements for Auditing

--

of Quality Assurance Programs for Nuclear Power Plants.

ANSI N45.2.23 - 1978, Qualification of Quality Assurance Program

--

Audit Personnel for Nuclear Power Plants.

ANSI.N45.2.6 - 1971, Qualification of Nuclear Power Plant

--

Inspection, Examination and Testing Personnel

10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power

--

Plants ..."

5.5.2

Procedures

Duquesne Light' Company, Design and Construction Quality Assurance

--

Program.

DLC Quality Assurance Manual (procedures 1.1.1 through 18.3.2)

--

DLC Site Quality Control Manual, February 5, 1985 (sections 1, 3, 4,

--

6 and 7)

Stone & Webster (S&W) Field Construction Procedure FCP-13,

--

Corrective Action Program BVPS-2, Revision 2 August 29, 1984

Project Guidance-Quality Improvement Management Program (DRAFT)

--

Selected Inspected Plans (IPs) for re-inspection, re-verification

--

and surveillance

The inspector verified the above procedures conformed to the

requirements of references listed in section 5.5.1.

,

mm m

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.

.

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_.

.a

g

33

6.

Piping and Mechanical Components

6.1 Organization

Piping, large and small bore, and mechanical components are installed by

the Schneider Power Corporation (SPC) in accordance with the requirements

of the Field Construction Procedures (FCPs) and drawings prepared and

controlled by the SPC and Stone and Webster Engineering Corporation

(SWEC). The quality control inspection of piping and mechanical equipment

is provided by Dusquene Light Company - Site Quality Control (DLC-SQC)

department in accordance with the identified inspection procedures.

6.2 Areas Inspected

The purpose of this inspection of the Primary Component Cooling Water

(CCP) system piping and components, which included motor operated, air

operated and hand control valves, and pumps, was to determine that the

piping and component installations were being performed in accordance with

FSAR commitments, design requirements, applicable codes, specifications

and procedures.

This inspection included verification of the correct

location of piping and components, use on proper inspection procedures and

review of the materials utilized for this piping system.

Completed work,

records of completed work including required QC inspections and work in

progress were included in the areas examined during this inspection.

6.3 Findings

The inspectors examined a portion of the CCP system; the program for

' controlling pipe and component installations;-qualification of personnel;

and selected weld records'and procedures.

Interviews were held with

crafts, craft supervisors and OLC-QC inspectors.

6.3.1 Piping

The inspector performed a walkdown inspection of a portion of the

CCP system identified below to compare the current as-built condi-

tions to the design drawings and ASME Code Section III requirements.

A CCP syst'em loop was selected as a representative sample of the

safety related piping systems. The extent of the walkdown performed

was from the CCP pump "A" discharge to the RHR system heat exchanger

"A" suction and from the RHR heat exchanger "A" discharge to the CCP

pump "A" suction. The chemical addition mode, pump recirculation

mode and surge tank mode for operational make-up were included in the

above walkdown.

This included the following Isometric Drawings

(IS0's):

.

- - -

. _ _ _ _ _ _ _ _ _ _ _

r

I

<

34

CI-410-631-2

107203-OH

110704-0G

CI-410-636-4

107206-1L

110709-0F

CI-410-626-5

107209-1G

110711-1F

CI-410-620-7

107210-1M

110712-2G

CI-410-629-3

107211-1F

109901-3H

CI-410-639-4

109905-1G

109902-2G

CI-410-637-4

110701-1G

107224-00

107225-1L

110702-3G

107223-0G

107222-1H

110703-0H

IS0's 109906-3D, 110701-1G, and 109901-3H have class 2 piping and compo-

nents which represented the inboard and outboard isolations valves and

piping at the interface of the auxiliary building and inside containment.

The inspectors performed a walk-down inspection for the above system and

examined the installed piping to verify the conformence with the SPC iso-

metric drawings, SWEC Flow Diagrams, SWEC piping engineering and design,

field fabrication and erection specifications for ASME III, Code classes 2

and 3 piping, and SPC spool drawings. The inspectors also reviewed the

design commitments in the FSAR and compared them with the output design

specifications and drawings to verify that they were consistent. Various

design parameters were selected such as pressure and temperature ratings

and these values were compared with the code plate data.

The inspectors made ovality checks at selected pipe spools and welds by

caliper measurements.

The visual inspection of the piping revealed no

creases, wrinkles, flat spots or any other defects that would have been

included by improper fitup. The ovality was within specification limits

and ASME III requirements.

The referenced documents and data are summar-

ized in Table 6.1 for CCP piping system parameters. The inspectors con-

curred that the installed piping was in compliance with the applicable

documents.

6.3.2 Mechanical Equipment

The inspectors performed a walkdown inspection for the piping loop of the

CCP system as identified under Sub-Section 6.3.1 and examined the in-

stallation of mechanical. equipment to verify conformance with the SWEC

flow diagrams, SPC IS0s, Vendor drawings including associated documents,

engineering specifications, and field Construction Procedures (FCPs).

The inspectors also reviewed the design commitments in the FSAR and

compared them with the output design specifications and drawings to verify

that they were consistent.

,.

.

_ _ _ - _ _ _ _ _ _ -

-_

?

35

The subsystems, piping isometrics, flow diagrams, specifications, vendor

data, field data, and FSAR requirements that were examined are listed in

Table 6.2.

Various design parameters were selected such as flow rates, pressure and

temperature ratings, motor HP/ rpm / voltage, pump NPSH and valve Cv values,

L/D ratios and their associated pressure drop data. These values were

compared with the nameplate data, procurement specifications and vendor

supplied documents.

The field component data were matched with the vendor and specification

data and found to be in agreement.

The equipment design data and FSAR

requirements were in conformance with the vendor data.

The inspectors concurred that the installed equipment was in compliance

.

with their associated document, design as well as FSAR requirements.

l

)

No violations were identified.

'

I

6.3.3 Specific CCP Components Inspected and Data Taken

The Tables 6.1 and 6.2 provide the scope of CCP walkdown inspection and

CCP equipment selected for design data review to establish conformance to

the FSAR, design documents and ASME Code requirements, as described in

paragraphs 6.3.1 and 6.3.2.

6.3.4

Independent Inspection - Piping and mechanical components other than

the CCP system.

The inspector observed work in progress and completed work in areas of the

plant and systems other than aspects of the primary component cooling

water system.

The presence of component identification, preparation of

welds for inservice inspection, welders symbols, records including quali-

fication of welders, condition of plastic lined valves and control of

equipment such as pumps and valves after construction turnover to plant

maintenance /startup/ testing groups were examined.

The details of certain

observations, examinations and records are summarized as below:

6.3.4.1

N&D 7446- A Q.C. hold tag was noted to be in place on the

degasifier tank nozzle shop welds.

The inspector found the N&D

7446 to be readily retrievable from the records and noted that

a problem of unsatisfactory radiographic reports was evaluated

and adequately dispositioned.

The records thoroughly described

the unacceptable condition and provided clear corrective action.

,

L-

. .

.

..

. . _

_ ..

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_ _ _ _ _ _ _

36

6.3.4.2

Jamesbury Valves

The SPC potential problem report of 3/6/84 stated that in evaluation of

the cause of a leak observed during pressure testing, signs of partial

melting of the teflon seat of one Jamesbury valve was noted.

The caution-

'

ary tag attached to each valve, option 2A, permits installation by welding

providing the temperature of 350 F at the valve center section is not

exceeded. On 3/6/84, construction craft were instructed to disassemble

Jamesbury valves prior to installation by welding, the 2B option to

-

prevent seat melting.

"

On July 6,1984, Engineering Field Action Report (EFAR) number 193A was

issued, as followup to the memos of March 6, 1984, requiring the actions

]

of location, disassembly and inspection of installed VBS-015-D4 (h"-2")

u

valves and certain motor operated valves for possible seat damage. The

inspector noted that SPC construction identified the valve seat problem,

provided a corrective action to prevent repetition and involved engineer-

ing for their review and statement of required action.

6.3.4.3

Tufline Valves

The installation manual and valve tag require a maximum temperature of

200 F during installation by welding to prevent damage to the valve

teflon / polyethylene liner components.

The inspectors reviewed documenta-

tion of the installation, observed disassembly / reassembly and inspected

the valve internals of the valves 110 and 112 on ISO 410-234.

The valve

number was 2 "VPW-015-AW-3 installed in conformance with the vendor's

manual No. 2506-380-091-001D.

No internal damage was observed.

6.3.4.4

Post Construction Equipment Control and Storage

The specification 2 BVS-981 defines the requirements and interval for

visual checking for conditions of storage and maintenance of permanent

plant equipment during the construction phase.

This specification is

referenced and is a part of the plant start-up manual chapters 4.2 and

5.4.

These chapters detail the scheduled maintenance / calibration program

and post construction turnover " superintendence" respectively of plant

equipment while in the testing, start-up and preoperational stages.

The

inspectors observed construction activity and startup test activity in-

=

cluding control of equipment to be occurring in the same areas simulta-

t

neously. Those components or equipment under control of construction were

$f

noted to be in conformance to specification 2BVS-981. Three components,

i

2CCP*TCV100C, 2CCP*MOV-150 and MOV-SIS *842, under control of the plant

g

maintenance or startup-test group were observed to be partially uncovered

$ ,

and not totasly protected from construction activity as testing was in

{

i

progress or recently completed. Although no damage was observed to

f

these components, the plant maintenance and startup groups were inter-

i

viewed to determine how components would be controlled after turnover by

j

SPC/SWEC construction. At the time of this inspection, control including

,

scheduled maintenance was baing performed by the plant maintenance section

i ;

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I h

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.

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_ _ _ _ _ _ _ _ _ _ _ _

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37

in accordance with the startup manual chapter 4.2.

The startup and main-

tenance groups had recognized the possible problems of having construction

and startup test activity occurring in the same areas and provided for

control through startup manual chapter 5.4 which defines the System

Operation Verification (SOV) test section system engineer as the indivi-

dual responsible for controlling periodic observation and activity

designed to ensure trouble-free operation of inactive permanent plant

j

equipment (superintendence). The startup manual' chapter 5.4 was scheduled

for implementation on 3/29/85. The inspector concluded that the program

for post construction equipment control and storage as presented in

chapters 4.2 and 5.4 of the startup manual and supporting references such

as 2BVS 981 would provide a programmed basis for effective superintendence

of equipment.

No violations were identified.

6.3.4.5-

Qualification Records of Welders

A sample' of welder qualification records primarily from the CCP system

welds were reviewed for comparison to the ASME Code Section IX or AWS

D1.1 welder qualification requirements.

Records for-the following welders

were reviewed:

F045

F232

F485

F076

F287

F524

!

i

F104

F291

F704

F130

F251

F848 (Instrument Tube)

F152

F341

F970 (Instrument Tube)

F213

F484

I-95 (AWS D 1.1)

No violations were identified.

6.3.4.6

Work in Progress

Work activity in progress on pipe hangers, piping and other mechanical

components was observed. Hilti bolt measurements, welding, heat treat-

ment, work station records, weld materials in use, instrument tube bending

i

and related activities or conditions were observed. These were compared

to the applicable ASME code, engineering specifications, procedures or

contractor isometric requirements.

The following were included in the

sample of work in progress inspected:

t..

-.

. . .

. . . .

. . .

.

..

.

..

.

..

..

.

_ _ _ _

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38

-- 2 MSS-032-35-2 Weld 2 MSS-035-F03 Preheat and Welding.

-- RCS-108-28 150-110909-3 RCS 242-2 Valve to Gate Valve.

-- Pressurizer top head, nozzles to piping - welds and welding in

progress.

-- RHR pump, heat exchanger and associated piping in

proximity.

-- 2FWS-016-22-2 Welds 2FWS-022-F501/F07 Weld root

tacking and preheat.

-- 2 DGS-PSA-030R ISO 410785-110-001 REV 2 - Pipe

hanger.

-- GWS-PSR-394R ISO 410515-089-012 REV 1 - Hilti.

-- 2 CHS-500-364-2 ISO 108306 - Welding.

-- 1 CHS-003-300-3 ISO 108335-003-300-3 - Valves and

welds.

-- 2 CHS-003-10-3 ISO 108334 - Welding (2CHS-010-F801).

-- Category II instrument tube bending station.

-- Instrument tubing - CI-410-320-1, tube bend diameter

control.

-- 2 CHS-21A and 218 at 755' elevation-tank and attached

piping.

-- 2 RCS-004-173-1 Weld 2RCS-173-F502 - welding.

-- Line 2 SIS-002-107-2 weld SA, Pce 3 to 7 - weld repair.

.

-- Line 2CCP-006-57-3

weld 2CCP-057-F505, ISO 11820-

welding.

-- Neutron shield expansion tank at elevation 750'.

-- Corrosion control tank at elevation 750'.

-- Incore instrumentation sump pump - stud welding

for mounting (DWG 10080 RV).

l

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_.

.-

p-

39

-- 2RHS-HCV 758A-SN N141141-3914 - storage of valve to

pipe assembly.

-- 2RCS-PSR-041, DWG-BZ109A-35-2B and E&DCR 2PA-8090,

hanger.

- -2WSS-410-233--003,- Weld FW6.

- 2CHS-FT 122 HP&LP Uelds 35/36/37/38 - instrument tubing.

-- Weld 2 MSS-043-F03, ISO 100211/2B - Heat treatment.

-- Weld 2FWS-012-F10, ISO 101702-6C - Heat treatment.

No violations, deviations or failures to follow appropriate procedures

were observed.

6.3.4.7

Proximity of Pipe Supports

The inspector noted that the supp' orts 2CCP-PSSH-326 (spring hanger) and

2CCP-PSSP-316 (snubber) at discharge side of pump 2CCP*P21A, on line

2CCP-020-463-3 were separated, center line to center line, by.1' -3 3/8".

The' inspector discussed the identified closeness of supports with the

SWEC - Boston and onsite personnel to clarify the issue.

It was concluded

that the support 2CCP-PSSH-326 was required to support the dead weight of

the valves 2CCP*V8 (20" check valve - 400 lbs) and valve 2CCP*V11 (20"

butterfly valve - 1147 lbs.). The lateral support 2CCP-PSSP-316 (snubber)

was required for seismic loading which has nothing to do with the carrying

of dead weight of the valves and corresponding flooded piping weight.

The

SWEC calculation No. 12241-1VPN-X72F, R.0 was reviewed to verify the per-

formed stress analysis on the piping system covering the discharge side of

the pump including the above identified valves.

The stress analysis

justified the need of a support 2CCP-PSSH-326, however,- it increased the

nozzle loading on the pump nozzle by 25% more than the vendor recommended

value. SWEC has requested Ingersoll Rand the pump vendor, to provide

their response to the increased nozzle loads. SWEC has formed a Stress

Reconciliation Program for the increased vendor allowable nozzle loading

for all pumps at BVPS-2, which also includes the identified pump. SWEC

and_0LC are tracking the identified program and once the stress reconci-

liation is performed, on a case by case basis, the support system design

will be updated, as required.

No violations were identified.

6.3.4.8-.

N5 Data Report Form

The ASME Code Section III, paragraph NA-1210 requires that the installer.

,

of'ASME components complete the Data Report Form N-5 which serves to in-

dicate that each component or associated appurtenances assembled into the

nuclear power plant and the installation meet the requirements of ASME

L

-

.

40

Section III. The inspector reviewed the following, discussed the N5

program with site personnel and examined records and documentation in

progress:

-- Letter dated 3/21/85, P. Ray Sircar to A. C. McIntyre

(SWEC).

--

2BVM-231 Review and certification of the Schneider Power

Corporation generated N-5 data reports

by SWEC.

-- FCP 211 N-5 data report and certification system.

-- N-5 Program Generic Schedule, Rev. 1, dated

1/25/85.

-- Documentation program status report, dated

March 7, 1985.

-- Computer report printouts of N5 data report attributes

by ISO number and N5 systems for specific CCP

components.

The computer reports reviewed provide for the status of the relevant

attributes to determine that code requirements have been met and that

components have been both installed and inspected to the latest engineer-

ing/ installation drawings. The computer report format is comprehensive in

that almost 100 attributes may be tracked with 35 data points showing on

those reports reviewed .

In related inspection activities, it was deter-

mined that welding and bolting data sheets, material test reports and

other records for specific pieces of equipment did exist, were readily

retrievable and had been reviewed or were scheduled for review.

Where a problem is identified in review of documentation, the problem is

described and tracked until resolved.

For example in review of the vendor

documentation, one material bend test was noted to have not been reported

by the material supplier. This condition was shown on N&D 7963 which

provided for engineering review, evaluation and disposition.

The inspec-

tor noted that as part of the disposition to N&D 7963, that the base line

FSAR document, BVM-179 and the subject pump specification BVS-010 would be

revised. Also, vendor recertification per the ASME 1974 code addenda, for

seal gland plate would be obtained.

No violations were identified.

On the CCP system, the inspector noted that the pipe support number

PSSP-929 was not in place. The N5 system data base computer printout was

reviewed for this specific support.

The printout did indicate the support

was not in place.

Subsequent steps in preparation of the N5 data sheet

for this component were on hold pending installation of the support and

inspection.

I

_ _ _ _ _ _ _ _ .

o

3

41

The inspector concluded that SWEC and Schneider have provided for and have

in place a systematic program to control and establish completion of ASME

requirements that will be summarized by the N5 data report documentation.

No violations were identified.

The SWEC N5 Data Report program that assures that components meet the

requirement of ASME Section III is considered to be a strength

at this project.

6.4 Conclusions

Piping Based on the review of procedures, observation of ongoing work

including welding, walkdown of portions of the plant piping and detailed

examination of the Primary Component Cooling Water system, examination of

3

specific welds and records, evaluation of weld filler metal control and

j

review of selected weld data sheets, the inspector concluded that the site

{

installation and welding function is under control by site supervision and

management utilizing a core of competent, qualified craftsmen. The

inspection functions of licensee site QC including NDE are in evidence as

is overcheck of the system by QA.

Mechanical Equipment The licensee has complied with the appropriate

specifications, FSAR, committed standards and codes, and regulatory

requirements for the installed equipment.

Other Inspected Areas Independent inspections were conducted of selected

l

components, activities and topics not specifically covered in the CCP

1

system.

N&D's, plastic lined valves, post construction equipment control

and storage, qualification records of welders, work in progress, expen-

dable products, proximity of pipe supports and preparations to complete

ASME code N5 data reports were examined.

The N5 data report generation and control system is considered to be

a strength of the project. A strong program has been established and

is being implemented effectively. Management is actively involved.

6.5 Documents Reviewed

-- BVPS-2 FSAR, sections 3.2, 3.983.4, 3.9N.3.2 and 9.2.2.1

-- FCP-211, N-5 data report and certification system

-- 2BVM-231, review and certification of the SPC generated N-5 data

reports by SWEC

-- FCP-213, SPC QA records

-- ASME documentation program, February 1985

-- SPC nuclear site QA manual

-- FCP-5.1, requirements for establishing and maintaining

cleanness zones

-- 2BVS-920, Field fabrication and erection of piping; ASME section

III, classes 1, 2 and 3 and ANSI B31.1, CL.4

,

. . .

. . .

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,

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,

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42

+

~~

- '

-- FCP-208', control of fab'rication and installation processes for

piping systems

-- IP-7.2,EASME section III and VIII welding

,

--- 2BVM-163, licensing commitment / design criteria correlation, for

-

FSAR section 9.2.2

-

- --12BVS-981,' storage'ofmaintenanceduringstorageofpermanent

plant' equipment.during the construction phase

-- DLC.startup manual, chapter 5.4

post turnover superintendence

'

' - DLC startup manual, chapter 4.2.- schedule

l maintenance / calibration program

--- N&D 7446 andlDLC - radiographic ' interpretation _ report 2BVM-114,

'

" essential systems, components, and instrumentation required for

-safety functions. -- 2BVM-81, tabulation of S&W mark numbers for

valves, steam traps, and. strainers-

,

'

- 2BVM-12', instructions for preparation of flow diagrams

idiagrams-

--jN&Ds.

7495, 7184, 7184A,-7448, 7599, 7603, 7440A and 7963

+

'

-- ERDCRs

4381, 3396, 3717, 5034, 5049, 5050

--lSPC's ECNs - 1778, 2564,'1947, 1978, 1745, 1797, 2618, 1230,

1015, 2508, 2578, 2801, and 2805

-- FCP-302, removal or disassembly / reassembly of permanent plant

'

equipment

-- EDM-83-116, SPC change control and reporting system

- Tufline maintenance and repair instructions for 1" thru 4"

plug valves

-- SPC - ASME. weld data sheets

-- SPC - Bolted joint data sheets

-- NPV-1-forms'for CCP system equipment

-- BVPS-2,-stress analysis data package for SI-RM-77A-1

-- SPC IS0s:

109905, 110701/2/3/4/, 110709 through 110711, 109901'

'

.and 2, 107223~thru 107225, 107206,:110756', 110743,-109907 and 8,

107217,-107214, 110-683, 410-701

-- SPC spool' packages:

1141 - 2628, 2629 2625, 3159, 3160 2782,

3441,~3474,'3476, 3477, 3478,.3480, 3481, 3482, and 3486'

-- SWEC flow diagrams RM-77A and 77B

' -- Vendor drawings, SWEC ' file nos: 2007.630.209.092C,

2006.390.069.048C and 044G, 2006.390.069.065A,'.2006.435.022.004B,

2006.450.076.0038, 2006.450.076.0658,-~2006.450.076A.071E,

2002.260.010.001F, 2003.230.054.001F, 2004.110.012.001G,

2006.310.073.021F, 2006.510.073.0310, 2006.320.064.028E,

.

2006.320.064.0300, 2006.390.069.045C, 2006.390.069.047E,

~and 2007.630.651.050A.

~ 7 .'

Electrical / Instrumentation Construction

,

- 7.110rganization

'

.-Duquesne Light Power Company has delegated responsibility for design

-control during the engineering and construction phase to Stone and Webster

Engineering Corporation. -Duquesne Light, however, does conduct engineer-

ing reviews on a selective basis of the design of certain components,

l'

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43

systems and structures.

Similar reviews are conducted of significant

design changes which: occur during construction.

Installation of

electrical component s/ systems is done by Sargent Electric Company under

contract to the Stone and Webster Engineering Corporation.

Installation

of instrumentation systems,. components and tubing is done by the Schneider

Power Corporation, also, under contract to Stone and Webster Engineering

Corporation. The Quality Control function is performed by the Site

Quality Control (SQC) Group under the direction of the Duquesne Light

Power Company.

-7. 2 Areas Inspected

The objective of this portion of the inspection was to evaluate the ade-

quacy of the control of the design and installation of the electrical /-

instrumentation components / system pertaining to the safety-related

sections of the component cooling water system. The team examined the

degree of conformance to the FSAR, Regulatory Guides, Criteria, Standards,

and design input from other disciplines with emphasis on the handling and

control of interface information from these disciplines. The team also

reviewed the responsibilities of the organizations involved in the

Electrical / Instrumentation design and installation process, and various

applicable project, administrative and general engineering design proce-

dures.

7.3 Findings

7.3.1

Documentation

The team examined procurement documents, Material Certifications, speci-

fications and receipt inspection reports for selected materials and compo-

nents of the component cooling water system.

Components selected for the

quality assurance document review consisted of the following:

-- Primary Component Cooling Water Pump Nos. 2CCP*P21A, B, and C

-- 16" differential control valve Nos. 2CCP*DCV 101A, B,

and C

-- 1 " - 150# 1evel control valve Nos. 2CCP*CCV100A, B and C

-- Pressure Differential Transmitter Nos. 2CCP*PT150A,

~B and C and 2CCP*PT107A, B and C

-- Pressure Differential Transmitter Nos. 2CCP*DT100-1

and 2

-- Level Transmitter Nos. 2CCP*LT100A and B

-- Flow Transmitter Nos. 2CCP*FT117Al and B1

7.3.1.1

Quality Assurance documents reviewed for the above components

include:

-- Receiving Inspections Reports (RIR) Nos. RIR-E4-5725,

E-4-5732, P-3-6990s, P-3-649, P-3-7903-S

-- Purchase Order Nos. 2BV-648A, 2BV-10, 2BV-648A-32,

2BV-209A, 2BV-636 and 2BV-651

,

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.

,

-- Material' Receiving Report (MRR) Nos. II83-5052,

s

'

II83-1575, II84-4163 and II84-3940

Certificate of Conformance No. 354, dated

'

J--

January 6,1983 :for 16" level control valve

-

-- Inspection . Report'. (IR) No. IR-0036 for:2BV-10

-- Nonconformance and Disposition Report (N&D) No. 7963 pertaining to'

'

1

lack.of Seal Gland Bend Test Data for Component Cooling Pumps

,

-- Certified-Test Report for Heat Treat No. 802L80720

-- Seismic Test Report No. 17567-82N for 16 inch Butterfly Level

Control Valves.

.

-7.3.1.2

,

'

In reviewing the above_ documents, the inspector noted several deficiencies

-attributable ~to lack of attention to detail on the part of licensee per-

sonnel in complying with licensee project administrative procedures and

'

-

procurement specifications.

-

-The, inspectors' identified the'following examples:

,

E

a)-

Engineering documents in the Document Review Group were found with

" corrections and deletions that were not made in.accordance with.

.

established procedures in that they were not properly initialed and

'

.or dated.

,

.

. .

.

Section 4 of Procedure 2BVSM-83 requires thatLcorrections/-

errors, changes / additions be crossed with a line and initialed

,

and dated by the person making the notation.

i

'

'

b)

LSupplier documents (SDDF) were not annotated to show "NOT" in the

-

' returned to vendor block.

Section-F12, pg. 5-29 of Procedure 2BVSM-202 allows'the addition ofL

.

,

"the word "NOT"_on the SDDF form.- However, there is no requirement to

-

initial or date the notation. This is contrary to management inter-

,

,

'

office memo _(2BVSW-60874-CRB/M) of September 23, 1985 which does not

allow changes / additions without the. initial and date of the person

.

making the notation.

c).

Corrections and deletions were made by QC personnel on vendor docu-

~

mentation without initial or date by _ person making notation -(re:

requirement per item a)

d)

Vendor-test report accepted'with vendor Professional Engineer'(PE)'

statement that-test results " appear to conform to seismic require-

ment." . Procurement-Specification 2BVS-636, pg 2-6 line 38-43

requires that: _ " seller submit a certificate of compliance which will

_

-

be-stamped-and signed by a Registered PE with the statement'that he

.has;seen and revicwed the adequacy of the method for establishing

that the seismic design requirements have been met."

'

,

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---

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.

45

e)

Certification of two QC inspectors by an individual designated in

writing by the Director, QC to perform the administrative duties of

the. Assistant Director, QC during a 30 day vacation absence of the

' Assistant Director.

Section 4.3.of Procedure TP-2 for Qualification and Certification

states; "the Director or Assistant Director /QC shall certify inspec-

tion / testing personnel by his signature."

The Procedure does not permit a designee or alternate.

f)

Responsible Engineer approval stamp used on SDDF documents without

initial and date of person authorized to use the stamp.

Section

5.2.6.f of Procedure 2BVM-202 requires Responsible Engineer using

stamp to initial and date use of stamp on engineering documents.

7.3.1.3

Prior to. leaving the site, the licensee had taken specific action to

address the above deficiencies as follows:

'The site project manager issued a memorandum, dated March 26, 1985 to

--

project peesonnel reiterating requirements for document correction /-

deletions.

The licensee revised Procedure 2BVM-202 to require annotation of

--

"NOT" in the-return to vendor block of the SDDF form.

_The Director, QC will clearly define responsiblities of

--

designatec alternates.

7.3.1.4

The implementation'of the above licensee actions and the results will

-be reviewed in subsequent inspections, however, because of the number

of deficiencies identified the licensee is in violation of 10 CFR 50,

Appendix B, Criterion V, which states, in part, that:

" Activities

affecting quality shall be prescribed by documented instructions,

procedures ..... and shall be accomplished in accordance with these

instructions, procedures ...." (50-412/85-07-04)

7.3.2.

Electrical

The inspectors observed work performance, partially completed work and

completed work on selected cables, raceways and terminations to determine

whether the requirements of applicable specifications, work procedures and

inspection procedures are being accomplished in accordance with NRC

requirements and licensee commitments. Particular attention was given to

items in the component cooling water system. However, observations were

not limited to this system.

_.

...

46

Specifically, the inspector reviewed the safety-related electrical speci-

fications, witnessed in process cable pulling, verified cable termina-

tions, observed the use and calibration of Measuring and Test Equipment,

and assured that the M&TE recorded on the documentation was traceable back

to the site calibration facility.

7.3.2.1

Electrical Cable Pulling

The inspector reviewed the documents listed against the FSAR criteria

and for consistency with the applicable lower tier documents:

--- 2BVS-931, Specification for Electrical Installation,

--- Field Construction Procedure (FCP) 431, Cable Pulling, and

--- Inspection Procedure (IP) 8.4.1, Inspection for Cable Pulling.

On March 22, 1985 the inspectors witnessed the beginning of a bulk cable

pull consisting of twenty three (23) different size cables. These cables

were being pulled from their respective reels at elevation 730' in the

service-building to elevation 745' in preparation for final pulling to the

Safeguards area.

DLC Site Quality Control was present prior to pulling in

accordance with FCP-431.

While pulling the cables off the reels the inspector observed that several

of the cables were' damaged after reaching elevation 745'.

Specifically,

SQC _noted that Seven (7) cables were kinked and one (1) had three (3)

longitudinal cuts in it.

The cables affected were:

2HCSAOC606

2QSSAOC003

2QSSAOC801

2QSSB0C801

2RSSAOC002

2RSSAOC011

2RSSC0C010

2CESC0C010

On the same date the Site Engineering Group (SEG) was notified of the

-

discrepancies being noted by SQC and began taking corrective action.

After approximately one and one half hours, the Sargent Electric Company

foreman decided to discontinue the pull because of the numerous problems

that SQC was identifying on their cable pull inspection attribute sheets.

On March 25, 1985 the cable pull had resumed prior to the issuance and

written dispositioning of Nonconformance and Disposition Report (N&D)

number 15993 generated on March 25, 1985 and validated by SQC, March 26,

1985. Continuation of the pull resulted in violation of Site Qualilty

Control Manual procedure 4.4 titled "Nonconformance and Disposition

Reports", paragraph 5.3.3, page 7, which states, " Work on a particular

-

activity shall be discontinued upon the issuance of an N&D if continued

.

_.

-

,

47

work could cause damage, prevent further inspections, or prevent remedial

action". This activity is in violation of 10 CFR 50, Appendix B,

Criterion V, which states in part that " Activities affecting quality

shall be prescribed by documented instructions, procedures .... and shall

be accomplished in accordance with these instructions, procedures ...".

(50-412/85-07-05)

7.3.2.2

Minimum Bend Radius of Cables

The inspector observed that cables 2FPWA0K600 and 2FPWA0K601 located in

junction box 2JB*5012 were in violation of their minimum bend radius

requirement. This was confirmd by the Licensee's SQC engineer by direct

measurement of the two orange channel power cables. The SQC Inspection

Plan on Cable Pulling, IP-8.4.1, attachment 3.9, lists the cable manufac-

tures minimum bend radius criteria for this type of cable (NKZ-10) as 2.1

inches. The measured value was between 0.9 inches and 1.0 inch. The

SQC organization generated N&D 15969 identifying the nonconforming condi-

tions and in addition revised the cable pulling Inspection Plan IP-8.4.1,

inspection attribute E540, to inc1 Ae an additional statement:

"While witnessing cable pull inside e: closures, the Inspector shall verify

that previously installed coales, if retrained during the pulling process,

meet the minimum bend radius criteria specified for the applicable cable

mark number."

The inspector, accompanied by the Licensee's SQC Lead Cable pulling

inspector, selected three (3) additional junction boxes to determine if

additional cable bend radius problems existed. The inspector had the

covers removed and verified that in 2JB*5046, 2JB*8815, and 2JB*8817 there

were no minimum bend radius violations present.

The inspector observed an additional instance of a minimum bend radius

violation in the Safeguard building at elevation 718'.

Cable 2SISBPH301

which feeds the safety injection pump 2 SIS *P21B from the 4160 Volt switch-

gear 4KVS*2DF was coiled and hanging from overhead by a rope. The contact

point of the rope created the minimum bend radius violation. DLC SQC

verified the violation and issued N&D 16014.

The specified minimum bend

radius for this cable (NKB-09) is Eleven (11) inches.

However, the actual

radius measured was between nine (9) and ten (10) inches. The above

mentioned minimum bend radius violations is contrary to 2BVS-931, section

3.2.1.14 which states, "The minimum bending radii shall not be less than

the bending radius given in cable specifications for each cable". This

activity is in violation of 10 CFR 50, Appendix B, Criterion V, which

states in part that " Activities affecting quality shall be prescribed by

documented instructions, procedures .

nd shall be accomplished in

accordance with these instructions, pr

2dures ..." (50-412/85-07-06)

.

.

.

._.

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48

,

7.3.2.3

. Electrical' Cable Terminations

'

lThe . inspector verified the licensee's cable termination inspection program

by inspecting twenty six (26) cables in the CCP system to assure correct

termination. The cables verified and identified as complete by SQC are

tabulated below:

ORANGE TRAIN CABLES

PURPLE TRAIN CABLES

2CCPA0C300

2CCPBPC300

2CCPAOC305

2CCPBPC301

2CCPA0C801

2CCPBPC801

2CCPC0C300

2CCPCPC300

2CCPC0C305

2CCPCPC304

2CCPC0C801

2CCPCPC801

2CCPACC307

2CCPBPC306

2CCPC0C306

2CCPCPC306

2CCPN0C022

2CCPNPC022

I

2CCPNOC032

2CCPNPC032

L-

2CCPAOC390

2CCPBPC303

2CCPAOC304

2CCPBPC305

.

2CCPA0H301

2CCPBPH301

The inspector verified the following:

I

Cables were trairrd properly

---

'

--

Wiring diagrams consistent with actual termination

i

points

,

Cable minimum bend radius was not exceeded

f

---

m.

F.

..

is

f

49

!-

!

Termination ticket included crimping tool and megger

---

M&TE number.

Proper connecting hardware

---

No problems were identified with the terminations except the following:

While verifying the 4160 volt power cable terminations for cables

2CCPA0H301 and 2CCPBPH301, which feed the Component Cooling Water pumps A

r

and B, the inspector questioned the requirements for bolted connections

when terminating to the load side of the circuit breaker stabs.

There

exists inconsistencies between the electrical installation specification

<

2BVS-931, the cable terminating field construction procedure FCP-432, the

inspection procedure IP 8.5.2, and the Sargent Electric Company. drawing

concerning the tightening of hardware in making up these medium voltage

terminations.

Specifically, 2BVS-931, section 3, page 43 gives torque values as a guide

for medium voltage terminations.

In addition, the specification states

"Where lock washers or belleville washers are used, bolt shall be torqued

until washers become flat".

FCP-432, section 6.5.7, page 12 states " Lock

washers and Belleville washers shall be torqued until the washers become

flat".

In addition, section 6.5.7.1 states "When lock-washer or Belle-

ville washer is not visible at time of installation, bolts shall be

torqued to values shown on attachment 3.5".

This attachment in FCP-432

states the same requirements as the specification.

The SQC inspection plan IP-8.5.2, section 6.5.2, page 14 states " Verify

that the hardware used is in accordance with attachment 3.9."

This

attachment states only that for joint tightness " Lock /Belleville washers

are flattened".

Sargent Electric Company drawing " Wire and Cable Termination Details" No.

1.2.3.4.A6, revision 27, Note 1, states, "If Belleville or lock washers

are used, tighten only until flat, do not torque." However, note 10,

states, "Make sure all screws and bolts are tight. See recommended torque

chart. Do not overtighten."

The inspector had discussions with the licensee and S&W Engineering

concerning the above inconsistencies in the documents mentioned.

The

licensee stated that they would revise the documents and remove the

inconsistencies.

This item is considered unresolved pending licensee review of these

documents for ambiguities and making any needed changes in these

documents and pending NRC review and evaluation.

(50-412/85-07-07)

p

,

.

50

,

7.3.2.4

Cable Sidewall Pressure

The inspector reviewed the requirements for calculating the maximum

-allowable pull tension in the documents listed below:

--- 2BVS-931, Specification for Electrical Installation

FCP-431, Field Construction procedure for Cable

---

Pulling

IP-8.4.1, Inspection for Cable Pulling

---

The inspector discussed with the licensee and S&W representatives how

i-

cable sicewall pressure was factored into cable pulling calculations

prior to cable pulls. The Licensee and S&W representatives responded

that all cable pull calculations were done in accordance with the

above procedures prior to the pull. The licensee could not show how, side

wall pressure is considered when these calculations are performed.

The cable pull ticket, which has the maximum allowable pull tension, is

stamped on the ticket for a particular type of cable and used in the

calculatio.n. The inspector then asked the licensee and S&W representa-

tives if sidewall pressure is factored into this value on the pull ticket.

During the inspection, after awaiting three (3) days the A/E did not sat-

isfactorily provide the inspector with sufficient information to determine

if sidewall pressure is considered when the maximum allowable pull

tension value is given on the cable pull ticket.

I

Following the inspection, Region I pursued this issue in phone calls with

_

the licensee on April 25 and 30, 1985 and in a meeting with the licensee

!

at the NRC Region I office on Tuesday May 7, 1985.

It was determined that

sidewall pressure was factored into the cable pull calculations. An in-

direct method was used consisting of limits on the maximum pulling length.

While the licensee could not retrieve the original 1980 records document-

'

ing this method, the engineer who developed the method reconstructed the

p~

method. This method could not be shown to be conservative with regard to

sidewall pressure in all cases. As a result Stone and Webster proposed

replacement of the old method with a more rigorous calculational method

that explicitly considers side wall pressure limits.

It is a more

conservative method than the original method with side wall pressure

l

limits more easily demonstrated.

!

-The new method was applied to 5064 Class IE cable installations at

the site with the result that for 99 percent of the cables reviewed, it

could be shown that conductor strength and sidewall pressure limits are

not exceeded. Acceptability of the remaining 30 cables could not be

l'

readily shown using the new method with its conservatisms. Additional

j

refined analysis is ongoing. The licensee anticipates that most of these

remaining cables can be shown to be acceptable.

L

$

l

,

,

51

However, for a small number of cables they anticipate they may have some

difficulty in establishing cable pull acceptability. As a result the

licensee has requested cable testing from a cable vendor to provide addi-

tional data on cable limits.

The licensee plans to include the new method as an appendix to the Elec-

trical Installation Specification, 2BVS-931 in the near future.

In the

interim most pending cable pulls have been shown to be acceptable by the

new calculational method.

Furthermore, they have imposed a hold on

pulling of any unpulled cables in the 30 cables that have not been shown

to be acceptable.

Pending reso'ution of the acceptability of the installed cables and

acceptaoility and incorporation of the new method in station procedures

and specifications this issue is unresolved (50-412/85-07-08).

The licensee's inability to retrieve the documents showing how cable

sidewall pressure was factored into cable pulling calculations is a

violation of 10 CFR 50, Appendix B, Criterion XVII, which states in part

that " sufficient records shall be maintained to furnish evidence of

activities affecting quality .... Records shall be identifiable and

,

retrievable" (50-412/85-07-09).

7.3.2.5

Switchboard Wire Traceability

During the termination inspection with the licensee's SQC, the inspector

found several reels of orange, purple, green, and grey standard SIS

switchboard wire outside the control room. An indepth look at the wire

itself revealed that only the grey wire had the vendors name, wire type,

voltage rating, grade, and gauge marked on the insulation of the wire,

e.g; wire #14 AWG Rockbestos G Firewall Type SIS 600V (UL) Nuclear.

The reels of the SIS wire were properly identified and traceable back to

the Pre-Engineered Material specification which states the procurement

requirements. However, the inspectors concern was once the unmarked

orange, purple, and green wire left their respective reels, one could not

determine what type of wire it was because of the absence of marking. The

inspector asked the licensee and S&W representatives if they had ever

questioned the vendor as to why they did not mark the colored wire.

The

licensee replied that they had called the vendor about this concern,

however, the vendor could not give them an answer.

The inspector then verified that the only vendor presently supplying

the project with SIS wire is Rockbestos. The inspector raised the

concern to the licensee as to procurement of SIS wire in the future

from an unqualified vendor in that traceability may not be maintained

and what precautions the licensee would take to assure that this

would not occur.

1

.

i,

.;

52

This is an unresolved Item pending NRC review and evaluation of licensee

controls to assure traceability of SIS wire procured from other vendors

in the future. -(50-412/85-07-10)

7.3;2.6

Damaged Cable

During the course of this inspection the inspector identified multiple

cable damage in cable raceway no. 2TC138P, located in the Control Building

at elevation 725'-6", at the intersection of the cable vault and the Main

Steam _ Vault.

Cables exiting the raceway at support no. QC93 were in

contact with the sharp edge of a raceway siderail causing an indentation

in the cable cover to 50% of its thickness.

Failure to protect cable against mechanical damage is a violation of

licensee specification 2BVS-931 pg 3-35 lines 8 & 9 which states, in part:

"that all cable installed in trays shall be protected.against mechanical

.... damage." This item is a violation of 10 CFR 50, Appendix B,

Criterion V_which states, in part, that " Activities affecting quality

shall be prescribed by documented instruction .... and shall be accom-

.plished in accordance with those instruction ...." -(50-412/85-07-11)

7.3.3

Instrumentation

7.3.3.1

Component Cooling Water System Observations

The inspector observed work performance, completed work and partially

completed work pertaining to the installation of safety related instru-

mentation and control systems associated with the Component Cooling Water

System. .The objectives was to determine whether the instrumentation and

control systems were in conformance with established procedures, NRC

requirements and licensee commitments in the areas of routing, slope,

supports, instrument type, range, separation of redundant system and

inspection.

Instrumentation and Control Systems selected for examination include:

Electronic Differential Pressure Transmitter Nos. 2CCP*PT150A,-B

--

and C; 2CCP*DT 100-1 and 2, associated instrument lines and

supports.

Level Transmitter Nos. 2CCP*LT104A3 and 2CCP*LT100A and B,

--

associated instrument lines and supports.

Flow transmitter nos. 2CCP*FT107A and B, associated instrument

--

lines and supports.

Drawing Nos. RK-303-E, RK-303CW-1, RK-303-J-1 and 2, RK-303-H-1

--

i

.

c

b?

.

53

iSing1e Ifne drawings were used to walkdown each system verifying routing,

slope,- support-location and anchor type for each system.

No violations were identified.

7.3.3.2:

Instrument Tubin'g Marking Pens

'During observation of seismic Category II, non nuclear safety (NNS)

. instrument tube bending, the inspector noted the tube bend operator to be

marking the tube.with an unapproved marker. The marking pen in use was

-not.shown on.the expendable products approved 11st for materials that

contact' metallic' surfaces (Specification 2BVS-901).

Immediate action was.taken by SWEC construction to stop the use of

unauthorizedLpens. . Corrective actions included revised instructions to

the craft personnel and issuance of memorandums to appropriate site per -

sonnel.by_the SWEC site project manager. This re-emphasized requirements

for proper pipe-marking devices and prohibitions against use of other

materials which could adversely affs.ct plant components.

Q.C. issued N&D

19539;for engineering evaluation of the situation.

The NRC inspector reviewed specification 2BVS 901, the FSAR part 3.2.and-

the memo dated December 4, 1984 by H. Krafft (SWEC) which states that..

' expendable products such as inks are nonpermanent and are to be removed-

-after-use. The inspectors observed installed Category I and II tubing.in

the field and noted that expendable products including marking inks'were

generally removed from Category I instrument . tubing but not removed _ from

' Category II tubing. This is an unresolved item pending NRC review of the

disposition to N&D 19539 and the program controlling removal of expendable

~

products from metallic surfaces wherever removal is required.

(50-412/85-07-12)

7.4 Conclusions

Electrical

.Imnlementation of electrical construction activities is generally

acceptable. LConstruction supervision, craft and QC personnel are

generally knowledgeable of good construction practices.

Two' problem areas were identified. The first problem area was related to-

a. previous problem in the area of engineering / construction interfaces.

~

As discussed in Section 4.3, the licensee has made generally good progress

~

1towards correcting this problem, particularly in the mechanical area.

However, in the electrical area there are indications that the interface

'between engineering and construction include a few lingering problems.

These' include the interface difficulty between engineering / construction /QC

that lead to the cable pull violation and the difficulties involved in

establishing if sidewall pressure was satisfactorily considered in cable

pull calculations. The' cable sidewall issue also led to a violation. A

m

.

~

..

54

related difficulty was that of establishing torquing requirements for

bolted connections when terminating 4160 volt power cables to the load

side of the circuit breaker stabs.

The engineering / construction interface in

the electrical area is a weakness (50-412/85-07-13) and warrants further

attention.

The second problem relates to several cable installation deficiencies.

This included several examples of failure to maintain bend radius

requirements and multi-cable damage to cable covers resulting from cable

contact with the sharp edge of a raceway siderail.

Both of these

deficiencies resulted in a violation.

However, they appear to be

isolated events.

Instrumentation

The licensee appeared to be knowledgeable of site activities.

Documentation and records were current, signed by authorized personnel

and ledgeable.

Fabrication and construction of the component cooling water system

instrumentation and controls conforms to the construction drawings.

Documentation

A number of small adminstrative deficiencies were identified leading to a

violation. These deficiencies involved inadequate attention to detail

with regard to such matters as dating and signing document changes.

8.

Status of Previously Identified Items

8.1 (0 pen) Unresolved Item (50-412/83-05-06)

Hilti Concrete Expansion Anchors are required to be torqued during initial

installation.

If for any reason, the nut was removed, there was no formal

program to identify control and document the retorque activity.

The

licensee established FCP 103.1 and 2 and IP 1.39 to formalize this

program.

During a containment tour the inspector identified Hilti's that were only

finger tight, and no work was in process on that instrument tubing

support. The licensee stated that a final inspection had not been per-

formed on that support and the inspection should have identified the loose

nuts.

However, some confusion still exist about the meaning of the blue

paint " dabs" placed on hiltis to identify QC inspection, and when the

installer or QC is-to be notified for the retorquing and inspection.

The licensee acknowledged the inspectors finding and stated that the

appropriate FCPS and IPs will be revised by April 15, 1985 to state that

the blue paint " dabs" will indicate only that the Hilti bolt setting has

been accepted by QC, and that appropriate FCPs will be revised by

m

,

,

, .

. .

~

55

>

TApril 30,1985' to require construction to notify QC when a Hilti-bolt _ nut

.

is loosened. Additionally, QC and construction will establish a tracking

Lsystem-to ensure that Hilti-bolt have the final torque accepted by QC,

'

~

This item remains unresolved pending licensee actions as noted above and

, subsequent NRC review.

'

8.2i (0 pen) Unresolved Item '(50-412/83-05-01)

~

The licensee's audit scheduling procedure does not provide a method

~

to assure that all elements of the quality program are considered or

m

-addressed in the audit schedule. The licensee representative stated

that.a computer program would be prepared to provide documentation

of quality elements covered and assist in the overall planning and

scheduling of. audits.

To date the licensee has e' valuated each-audit and determined the

quality element / Appendix B criteria covered in each audit and entered

7this information into the computer._ system. However, the licensee has

not developed a~ formal output from the computer that can be used to

plan and schedule audits or assure coverage of all aspects of the

,

quality program.

Prior to the inspection exit the licensee'did provide to the inspector a

han'dwritten' matrix of the 1983-84 audits.versus quality element / appendix B-

cr.iteria.

This_ item remains unresolved pending licensee action to

formalize this computer system and subsequent NRC review.

'8.3 :(Open) Unresolved Item (50-412/85-04-04)

'The' inspector questioned the licensee with' regard to monitoring the

' separation criteria for redundant systems as specified in the Instrument

Installation Specification 2BVS-977. This characteristic is not included

in the. inspection plan as reported in IE Report No.-85-04 and noted in

item 85-04-04. The inspector.had several discussions with licensee and

' Architect / Engineer site representatives regarding this issue.

The

licensee has revised Specification 2BVM-228 providing tighter control on

engineering designs released to the site,'however, the licensee is relying

on the revised specification and the Hazards Walkdowns Program 2BVM-165 to

verify conformance to established procedures.

The licensee is still hesitant about QC involvement in monitoring the

separation criteria._ The issue of whether QC should be involved in

' assuring conformance to specification requirements for separation of

redundant instrument lines remains unresolved.

-.

U .

,

_

.:

.g

56

'9.

Interviews

The NRC inspectors conducted interviews of QC inspection personnel and

craft workers. Approximately 20 QC level I and II inspectors covering a

range'of electrical and mechanical activities were interviewed. Time on

site for these inspectors ranged from three months to 12 years.

Inter-

views'of site craft personnel included a cross section of 20 mechanical

and electrical craft with site times ranging from one month to seven

years.

~

QC inspectors were interviewed to determine effectiveness and quality of

training; views of site work quality and knowledge of situations where

work quality or safety was compromised to meet construction schedules;

. interactions with craft and engineering personnel; and knowledge of

threats or harassment in relation to the performance of their duties.

Inspectors interviewed agreed that training programs were adequate for

the job.

Views of work quality at the site were good.

No situations of

sacrificing work quality for construction schedule were identified.

Interations with craft workers and engineering were positive.

Engineering cooperation in resolving issues was noted. There were no

indications of harassment, intimidation or threats to ignore proper

procedure or quality checks.

Crafts interviews were similar covering the areas of orientation

training; site work quality and known problem areas; interaction with QC

and engineering personnel and DL presence on site. Orientation training

was reported to be adequate. Again the view of work quality at the site

was good. No previously unreported problem areas were identified.

Interactions with QC and engineering was reported to be good. DLC

presence on site and their interest in quality work was noted.

10. Unresolved Items and Program Weaknesses

Unresolved items are matters about which more information is required to

ascertain if it is acceptable, a violation, or a deviation.

Unresolved

items are discussed in sections 3.3.5, 4.2.6.2, 7.3.2.3, 7.3.2.4, 7.3.2.5

and 7.3.3.2.

A program weakness represents a condition which, if left uncorrected,

could lead to problems and/or contribute to the violation of a regulatory

requirement. Program weaknesses are discussed in sections 3.3.1 and 7.4.

11 1 . Exit Interview

The inspector met with licensee representatives (denoted in paragraph 1.0)

at the conclusion of the inspection on March 29, 1985 at the construction

site.

The inspector summarized the scope of the inspection, the inspection find-

ings and confirmed with the licensee that the documents reviewed by the

-

F.

i

'*:

r:.

57

team did not contain any proprietary information. . The licensee agreed

,

that the-inspection report may be_placed in the Public Document Room

I

without prior licensee- review for proprietary information (10 CFR 2.790).

' 'At no time during this inspection was written material provided to the

-

licensee by the team.-

!

fs

'

_

h

-

,

u

-

---

.-s- --- . x-x. - u--

. - - - -- - - -

---

- - - - -- - - -

---

- --- .------- - - - - - - - - - - - - - -

.-

--.

. .

-

- , - -

._.

V

TABLE No. 4.2.1

-

Review of N&Ds and E&DCRs

Document Description

SPC-ECN No.

SPC-CRN No.

SPC-1SO No,

Other Affected S&W Documents

Remark

I

I

I

J

1

-l

E&DCR No. (S&W)

i 1230

l 110743-1C

l 110743-1C

RM-778-14

l

No Finding

'l

2 P-4381

1

1 110756(1-2) l'

110756-2D

RM-77C-13

- l

l

i

I

(2-1)

i

I

I

I

I

I

I

I

I

EkDCR No. (S&W)

i 1015

l 109902

l 109902-2G I

RM-778-14

1

No Finding

2PS-3396

l

l 109908-23

l 109908-2D i

i

I

f

1

I

I

E&DCR No. (S&W)

i 2508

l 110-683-2

1 110-683-2 i

RM-778-14

l

- No finding

i

2PS-3717

l

l

l

l.

RP-107H

l

l

l

l

l

RP-107N

1

1

1

1

I

u

!

E&DCR No. (S&W)

i 2578

l 107217-12-1

1

107217-0M i

RM-77E-13

I

-

No Finding

i

2 PT-5034

'I

h

l

l

RP-72A-7G

l

l

l

l

RP-72F-7J

l

i

I

E&DCR No. (S&W)

l 2801

1 410-701(2-1) l 410-701-3

I

RM-77A-14

No finding

2PT-5049

I

i 107210(10-1) I 107210-1H I

RM-778-14

l

l

1 109901 (4-1) 1 109901-3H l

RM-77E-13

l

l

l 109907 (3-1) I 109907-2G I

I

I

i 107214 (7-3) i 107214-ON I

i

1

1

1

1

l

E&DCR No. (S&W)

I 2805

107210(10-1) i 107210-1M 1

RP-72A-7G

No finding

i

'

2 PT-5050

I

i 109901(4-1) i 109901-3H I

R P-728-7 L

l

l

l

l 109907(3-1)

109907-2G I

RP-72F-7U

l

I

i 107214 (7-3)

107214-ON '

RP-990-5F

l

l

ll

RP-99F-3M

l

i

li

i

i

N&D No. (DLC-SQC)

i 1778

107226-1E

I 107226-1E

.

RP-72C-7F

No Finding

l

l

74;5

l

107222-1F

i 107222-1F I

R P-72 F-7J

l

'

i

1

i

RK-303J-1-6

i

l

I

BZ-72A-53/72/120

I

l

l

l

i

M&D No. (DLC-SQC)

i 2564

l 110712-2F

110712-2F l

RP-107C-8A

I

No Finding

'

7184A

i

l

l

RP-107Q-2AD

l

l

l

l

l

RP-107G-6Q

l

1

l

l

l

RS-52A-11B

l

l

l

1

i

i

1947

l 107225-1K

107225-1K

RP-72F-7J

l

No Finding

I

N&D No. (DLC-SQC)

i

7599

I

l

RP-72C-7F

1

l

l

l

.

i

BZ-72A-56-5C

1

I

BZ-72A-72-3D

l

l

l

'

I

I

1

N&D Mo. (DLC-SQC)

i 1978

107226-1E

107226-1E

RP-72C-7F

No Finding

I

7603

1

107222-1F

107222-1F

RP-72F-7J

l

l

RK-303J-1-6

I

l

l

l

,

,

BZ-72A-53/-72/120

l

1

1

l

Nk0 No. (DLC-SQC)

1 2618

1 410-622-5-6

1 410-622

i

BVS-64

No Finding

7448

I

l 410-427-1-2 . I 410-427

i

6/26/1984

I

I 410-636-2-3

1 410-636

l

l

l

l

l

1-

1

l

l

.

w-w

y

w

4

ww'4

pp..

w

&

.

'

c

Table 6-1

Page 1 or 3

l

PCCWS WALKDOWN INSPECTION

l

l

lSPC

ISWEC

Pipe

i

PIPING DATA !I

i

l

i SWEC Dwg. 11

(Piping

Flow Dia.

Spool

H

Mat &

Ovality

FSAR

Field I

!

Mode

Desiq.

De sc r i p .

ISO #

DWG.(SPCI

Class

Sch.

Ratino

Findino

Data

Findino..

Su rge

2-CCP-002- Tank T21A Cl-410-631,

RM-77A-12D 631-2/3

151

SMLS,SA106,

ANSI

None

ASME

ASME Ill

u636&626

i

'636-1 to 7

CR 8;SCH.80

150lb;

ident,

111/

CL-3; QA

T:nk

437-3

' D i scha rge

Cisch.l

to PCCW

l

l625-1/2

C.S.

CL-3;

CAT-l;

i

pumps

l

I

i

l Class

No Find-

I

lscr+ ion

l

l

1

lE

'ing

I

theader

l

l

l

l

l

l

\\

Chem. 12-CCP-001

lPCCW pump l CI-410-620,

1 620-1 to 4

l

l

"

"

"

"

"

"

"

Addit.l-465-3

Idisch.

629, 639

629-1 tg 6

1

l

l

Iheader to

.

637-1 to 7

I

-

l

tank TK22

'

l

1

.

I

Chem. 12-CCP-001-l

lCl-410-637

IRM-77A-120 637-1, 2&5

151

SMLS, SA106,

ANSI

None

ASME

ASME Ill

"

'

Addit.1444-3

l

l

ll

CR.B; SCH.80

150lb;

ident.

. Ill/

CL-3; QA

l

,1

1

1:

I

C.S.

CL-3;

CAT-l;

'

I

l

l

l

Class

No find-

1

I

I

IE

ing

h

l

L

L

'

Mini-

l 2-CC P-010- IIPCCW pumpn 107225

1

456-1/2A1

STD.WT SMLS

"

"

"

"

"

"

mum

'456-3

ll d i scha rge

l

SA 106 CRB

R circ

.

l oin. flow

.

I

l

l

l

line

!

l

l

l

1

l2-CCP-008-

l

lRM-77A-12D

455-1

1 151

ANSI

None

ASME

ASME

"

"

"

"

l455-3

i

l

l

l

150lb;

ident.

l lil/

lil/

l

l

!

l

l

!

C.S.

CL-3;

CL-3; QA

I

I

l

l

.

Class

CAT-1;

I

I

I

l

IE

NoFind-

'

1

I

q

l

ino

'

Mini- l2-CCP-008-

PCCW pump l 107225

1 454-18

STD.WT.SMLS

"

"

"

"

"

"

mum

1454-3

d i scha rge l

l

SA 106, GR.B

Raci rc i

min, flowl

I

l

l

line

l

l

l

l

R2-CCP-010-

To PCCW

ll RM-7 7A-12DI 453-1 A/2A l 151

L ANSl

H None

ASME

ASME lil

"

"

"

453-3

l pump

i

I

l

l

150lb;

i ident,

111/ . CL-3; QA

l suction

l

l

l

C.S.

CL-3;

CAT-1;

l

. header

l

l

l

l Class

No Find-

I

,

I

i

l

l

H

IE

ino

i

PCCW 1 2-CCP-010 lPCCW pump , 107203

i

N/A

ISTD.WI.,SMLSi

l

"

"

"

"

"

"

Pump

l-683-3

1"A" outlet

.

L

lSA 106, GR.Bl

l

"A"

l

l

l

l

l

l

Disch.I

I

I

H

i

'

'

12-CCP-020 ITo PCCW l

1463-1A1 & 2Al 151

ANSI

None

ASME

ASME Ill

"

"

"

"

l-463-3

lPumpDischl

l

150lb;

ident.

Ill/ lCL-3; QA

'

l

l Header

l

l

l C.S.

CL-3; l CAT-1;

i

l

l

!

I

ClasslNo Find-

l

l

l

l

l

l

IE

lino

'

i

-. --

.

-- - -

-

-

.

_,

i

5

t

l

Table 6-1

Page 2 of 3

f

PCCWS WALKDOWN INSPECT 10N

l

l

ISPC

llSWEC

l Pipe

PIPING DATA

I

I

.

1SWEC Dwg. l

l Piping

IFlow Dia. ll Spool

Mat &

Ovality

FSAR.

Field

14 ode

Desio.

IDescrip.

ISO #

DWC.fSPC)

Class

Sch.

Ratino

Findino

Data

Findino

PCCW

2-CCP-020 l F rom PCCW

10/206

RM-77A-120 473-1A, 2&3

151

STD.WT. SMLS

ANSI

None-

ASME

ASME ill

Pump

l-473-3

IPumpDischll

l

l

SA 106, GR.B i 150lb;

ident.

til/-

CL-3; QA

"A"

l

IHeader tol

I

l' C.S.

' CL-3;

CAT-1;

.

' Class ; NoFindng

,

Disch.1

IHeat exchl

l

l

l

l

"A"

I

i

H

IE

PCCW 12-CCP-016 iTo PCCW l

l

l 569-1 A1 A

"

"

"

"

"

"

"

"'

Pump

l-569-3

l Heat Exchl

l

"A"

l

l

"A"

l

l

Disch.l

l

j

l

l

12-CCP-016 l

l

107206

RM-77A-12DI 570-1 2&3Al151

SID.WT. SNLS

ANSI

None

ASME

ASME Ill

"

l-570-3

I

1

SA 106, GR.B.

150lb.

Ident.

lIll/

CL-3; QA

"

I

'

I

H

l

C.S.

CL-3;

CAT-8;

I

l

l

l

!

Class

NoFindng

i

l

l

l

IE

PCCW 12-CCP-020 : PCCW Heat , 107209

I

492-1,2,3A1 i

Pump

l-492-3

Exch "A"

l

l

-

"

"

"

"

"

"

"

Exch. I

Outlet

I

i

-

l

l

'

"A"

l

l

l

l

1

l

-1

l

Disch !

.I

I

l

l

12-CCP-020 i!PCCW Heatl 107210

lRM-77A-12D1 493-1A/2

151 ll ST D. W T . , SMLS ;

ANSI

None

ASME

ASME 111

l-493-3

lExchDischl

i

l

ISA 106, CR.B

150lb;

Ident.

Ill/-

CL-3; QA

"

l

Heade r

i

i

!

,

l

C.S.

CL-3;

CAT-1;

I

H

1;

I

I

i

Class

NoFindng

i

i

l

I

l

IE

PCCW

l2-CCP-018 (Header tol

.107210,

lRM-77-12D l 032-1 thru.

l

l

"

"

"

"

"

"

Pump

l-32-3

lcontain- l

107211,

& RM-77B- 1B

Exch. 1

iment

i 109905

1.12B

"A"

I

l

I

i

Disch.1

I

l

I

12-CCP-018 l

l 109905

RM-718-1281 30-1, 2&3A

151

STD.WI.,SMLS

ANSI

None

ASME

ASME lit,

"

"

l-030-2

1

I 110701

l

lSA 106, GR.B

150lb;

ident.

lill/

CL-2; QA

l

l

l

l

l

l C.S.

CL-2;

CAT-l;

l

I

l

l

l

l

Class

NoFindng

I

l

IE

i

i

,

l'

'

l

ll

PCCW

l2-CCP-018

Header

110702

1

31-2 thru

ASME

ASME Ii1

'

"

"

"

"

"

P :t

I-31-3

Inside

i

5

I

CL-3;

CL-3; QA

Ex 7

I

Contain-ll

I

ll

Class CAT-l;

"A"

i

i ment

I

i

IE

NoFindng

'

Disch.I

ll

l

l

Inlet 12-CCP-018 l Header i 110703

RM-778-128

95-1 th ru

151

'STD.WT.,SMLS

ANSI

None

l

"

"

to RHSI-95-3

I inside i 110704

1 5

' SA 106, CR.BL 150lb;

ident.

• E21A I

l Contain-l

i

I

C.S.

1

I ment to l

l

l

RHS Heat!

I

l

Exch "A"

11

12-CCP-024

110704

h

-

ASME

ASME lil

"

"

"

"

"

"

"

l-718-3

i

CL-3;

CL-3; QA'

l

l

Class CAT-I;

I

H

l

IE

NoFindna

~ ' ~ - ' ~

4.g 11

-

,

'a

- .

d-

' Table'6-1

Page -3 or 3

,

'

..PCCWS WALKDOWN' INSPECTION

.'

l'

l

l SPC

ISWEC

Pipe..

.I

) PIPING DATA:

. Ovality:

.FSAR'

Field.

ISWEC Dwg. l'

l Piping

Flow Dia.

Spool

.

Mat &

.

.

. Mode IDesia.

IDesc ri o.

ISO #

DWC.fSPC)

Class

Sch.

Ratina

Findina

Data'

Findina

Outlet l2-CCP-024 l0utlet to

110709

RM-77B-128

719-1

151

STD.WT; SMLS;

ANSI

None ..

ASME

ASME Ill

-t3 RHSI-719-3

IRHS Heat

SA 106, CR.B '.150lb; '

'ident.

CL-3;

CL-3;-QA

CE21A l

lExch."A"

C.S.

Class

CAT-1;No

l

l

IE -

Findina

Outlet l2-CCP-018 (Disch.

96-1, 2&3.

"

"

"

"

"'

"

"-

"

t1 .

l-96-3

loff RHS

GHS*

l

Heat Exch

[gjA

"A"

l

l

'

Retu rn 2-CC P-018

RHS Heat.

110711

RM-778-128

37-1 thru 7

151.

STD.WT;SMLS;

ANSI .

None

ASME--

ASME-lil

Header -37-3

Exch "A"

110712

'

SA 106, GR.B

150lb;

ident.

CL-3;

CL-3; QA

t2

LDisch to

C.S.

Class _

CAT-1;Ho

,

• '

PCCW

Return

IE-

Finding

Pump

Suct.

2-CCP-018

Retu rn

110701-

36-1A, 2

ASME

ASME.Ill

-

"

"'

"

"

"

"

l-36-2

' Hea de r

109901

CL-2;

CL-2; QA

l

inside.

Class

CAT-1;No

l

Contain-

I E.

Finding

i

ment

_

STD.WT;SMLS;

ANSI .

None

ASME

2-CCP-018

Retu rn

109902

RM-77A-12D 35-1 thru 4

151

"

"-

-035-3

Header

107222

& RM-778

SA 106, GR.B

150lb;

ident.

CL-3;

Outside

-12B

C.S.

Class-

l

Contain-

IE

I

l

ment

12-CCP-020

PCCW Pump

107224

RM-77A-12D 433-1 thru

ASME I l l

"

"

"

"

"

"

l-433-3

Suction

107222

3-

.

CL-2; QA

i

Header

i

CAT-1;No

Findina

PCCW

2-CCP-020

PCCW Pump

107222

436-1A & 18

151

STD.WT;SMLS;

ANSI

None

ASME

"

"

Pumps

-436-3

"A"

107223

SA 106, CR.B

150lb.

Ident,

CL-3;

i

Suct- I

Suction

C.S.

Class

ion

IE

To

107223

RM-77A-12D

530-500

PCCW

2-CCP-012

"A" pump

"

"

"

"

"

"

Pump

-530-3

Suc-

'A"

l

tion.

Suc-

l

tion i

r

~-'

~

'

,

O

TABLE 6.2

Page 1 of 3

PCCW SYSTEM EQUIPMENT SELECTED FOR DESIGN DATA REVIEW

',

I

ISWEC

SPC

lSPECI.

FSAR

FIELD NAME

VENDOR 000.& NPV-1

'

SWEC_ EQUIP #fDESCRIPT__ Gf ILW D A.

ISO

ipATA

DATA

PLATE DATA

_ DATA

2CCP*P21A

lPCCW Pump 1RM-77A-12D

, 107203

2BV-010

ASME lil/CL-3/ Class

ingersoli Ha nd, Came ron

Ingersoll Rand;

I"A"

l

-

2107223

'

IIE, Seismic CAT-1;

Div Pump; 400 psig 0

Cameron Div 6000gpm

l

l

,

lHoriz. CF Pump;

170F, ASME Ill/CL-3

0 200rt, Err. 78%,

'

I

i

~

16000gpm O 200ft.,

SN 574110, NB #97

400HP/1800 RPM motor;

1

I

-

H400psig dsgn, 400HP

casing (disch)

30ft NPSH, ASME Ill

I

}

1400HP motor

XX-10X18AA

1971 + W 1972

!

l

.

addenda, SH 574110;

I

f,

.

>

,

lNB #97, CL-3 DWC #

'

l __

__l*

l_.

1

D-10X-18AA

321X15

'

'RCCP*E21A

lPCCW Heat l

l 10 ? 2L% -

28V-128_ _ _ _ _ _ _

lASME lil/CL-3/Seis.

Struthers Wells,

Struthers Wells;

I

.

lExchancer

110/209

l C AT,- 1 ; 33x10 BTU /HR 225psig/200F-Shell;

225psig/200F - Ghell

,

'

"

l

"A"-

1

ITube SA-149 TP304

175 psig&Vac/100FTube;

175psig&Vac/100F

i%'

'

lShell 225psig/200F

ASME lil/CL-3; NB #

Tube; Shell capacity

i

ITube 175psig/;00F

14335 SN 1-73-06-

1627 gal.; Tube

-1

L

I,

31643-1

capacity 940 gal ASME

'

I

l'

lil/CL-3 1971 +W1972

,

>

?

/

l

H

I

ADD NB #14355, GN 1-

'

___

-

l

.

H

1

H

73-06-31643-1

RCC P* T ,'21 A l PCCW Surge l RM-7 7A-120 (Cl-410

.

ASME 141/CL-3/ CAT-l;l

Not AccesslDie

ASME lil/CL-3 -1974;

2BV-054

l Tank "A"

l

.1-637

,1650' gal; 50psig 0 I

. SN 6206,SA 285-GR.C

i

i

I

d300F, SA-285-CR.C

'

Nat. Annealing

l

!

-

1

50psig 0 300F; 1650

'

.

l

'l

gal, cagac. SA-285-

,__ l

l

.

_

CRC.:72 ODX 12'higtL

2CCP*Ik2P

IPGCW CNem.l

l 2BV-058

-

l F ield fabrica ted; 12" gb

ASME lil/CL-3; Field

.

(Addition l

Tank x 4' H: ASME Ill l Fabricated; Ngminal

"

"

/CL-3; SA-105

capacity; 12"4 x 4H;

ITank

l

_

____l

IMaterial

SA-234-WPB. STD.WT

'

l

OCV- 10p- 1

l D i f fe ren- ; RM-77A-120

1107225

2BV-209

ASME lil/CL-3; Class l Copes Vulcan, 165 psig Copes Vulcan;

8"

Itlal

IE

10 180F; SN 8320-594 .

Class 150#, D-100

l p re s su re I

'53-1-1; ASME l i i/CL-3~

va lve v/Borg Wa rner

! control

NB #2462

Ac tua to r, ASME l i l/

Ivalve on

Cl-3 1980 + S1981

12-CCP-008-

l

'

.l'

' ADD, ND#2462,165PSl/

454 &455-3

1

180F & 2850si/100F

DCV-101-A

D i f fe ren-

107206

2BV-651

Masonellan int:135psig Masoneilan Int; 135

tial

150F, 285psig/100F,

psig/150F & 285 psi /

"

"

pressure

l

l

ASME lil/CL-3, SN AE

100F, ASME Ill/CL-3

. control

897-1-1

6/1971 + 6/1973 ADD

'

lvalve on

L

l

. SN AE-897-1-1, 16"-

J2-CCP-016-

37000 series, Class

570-3

150#, Model 3, Actu-

ator position-3

MOV-150-1

Butterfly

RM-778-128

109906

2BV-076

ASME lil/CL-2; Class

Hen ry P ra t t , 153psig/

Henry Pra tt, 153 psi /

(outside

Dvalves

IE

150F, ASME lil/CL-2

1150 F , 275 psi /100F,

l

i

SN A0027-1/2-1

ASME fil/CL-2-1971 +

l

l

CTMT) & MOV- motor

i

150-2 ( in-

ope ra ted

W1972 ADD, SNA-0027-

side CTMT) l on 2-CCP-

1/2-1

1018-030-2

_ _ _ _ _ _ _ _ _ _ _

. . . .. ..

.

.

.

..

.

,

y.

{f,

(@

. TABLE'6.2'

'

Page 2, of 3

PCCW SYSTEM EQUIPMENT SELECTED-FOR DESIGN. DATA REVIEW

<

i-

1 SWEC

SPC

SPECl.

FSAR.

FIELD NAME

VENDOR DOC.& NPV-1

SWEC EQUIP # DESCRIPT

FLOW DIA. #

ISO

DATA

DATA

PLATE DATA

DATA

MOV-112A

Mo to r0pe r- RM-7 78-128

110703

2BV-076A ASME Ill/CL-3; Class

POSI-SEAL INT, 153 psi /

POSI-SEAL I NT, . inc.

ated

.. I

I

IE.

~

100F,'ASME lil/CL-3;;

150#,.18"-2144 type;

Ibutterfly 1.

I

li

SN 152-45-5A, limit-

ASME lil/CL-3 1974 +

Ivalve on l

to rque op r. t SN 261757f

S1976 ADD, SN-15245-

,

12-CCP-018 i

Type H-

5A, 153 psi /100F,

I-95-3

i

Li m i t to rque, H l BC- -

l

l

.

I

I

SM800012

V5

BCheck

lRM-77A-12D

1107222

2BV-069

ten ry Pra tt; 200psig/

Hen ry P ra t t,

20"-

l

tvalve on l

l

300F, ASME lil/CL-3;

1400 series, MDT -

"

12CCP-020- 1

I

SN A-0034-8-2

manua l opr, 200 psi / .

,

1436-3

l

l

.I

300F, 275 psi /100F,

I

l

l

I.'

l

ASME-lil/CL-3 1971 +

l

'l

i

l

W1972 ADD,SN A-0034-

l

l

t

8-2. VV1015-AR-3

V2

l Butterfly I

ASME Ill/CL-3;

' Henry Pratt; 200psig/

Henry Pratt; VVF015-

12-CCP-020-1

i

SN A-0034-1-1

'

A-3, 20"-1100 series

"

"

"

l valve on i

Class IE

'200F; ASME I l l/CL-3; .

MDT manual opr SN .

1433-3

l

l

l

A0034-1-1, 200psig/.

l

l

l

l

200F, ASME Ill/CL-3'

l

l _.

l

l

'

-1971 + W1972 ADD

V34, V35

l Ga te

l RM-77A-120 lC4-410- 2BV-064

Hancock va lve-Dresser

Dresser IND-Hancock

D V29

l valves on I

1639,620

IND; 940psig/700F,VCS- Line, 1"-600# CS-950

"

12-CC P-001 l

ik 637 I

i

060-B-3; SN H096/94/'

W-3-XN VCS060-B-3,

1-465/444-3l

l

l

110 AAE;ASME lil/CL-3;

C009 valve, 940 psf /

l

l

l

l

1700F, 1440 psi /100F,

I

'l

l

l

ASME lil/CL-3-1971+

l

1

1

S1973 ADD,SN H096/94

l

l

110 AAE

V539 k V96 lCate Valvel

. CI-410

ASME lil/CL-3;

Hen ry Vog t mach i ne

2"-600# CS Dresser

"

"

lon 2-CCP- l

l-636 &

Class IE

2"-600#;ASME lil/CL-3;

valve; VCS060-B-3,

I

l002-437-3 1

1626

l SN 97-214959 & 101-

1480 psi 4100F, ASME l

l

l

l

1

1214959

lil/CL-3-1977+S1979 l-

l

l

l

ADD, SN 97-214959 &

l

l

101-214959

MOV-156-1

Motor

i RM-778-128

110701 12BV-076

ASME lil/CL-2; Class , Henry Pratt, 153 psi / -

Hen ry Pratt,

18"-

(outside

l ope ra ted l

.kl099011

, IE

150F; SN A-0027-2-3 &

VV1015-AR-3, 1400

A-0027-1-3;- ASME lil/

series, 153psig e

CTMT)& MOV-

butterfly l

I

I

I

' CL-2

150F & 275 psi 4100F i

156-2(inside valves on l

l

l

l

CTMT)

12-CC P-018- 1

l

l

l

ASME lil/CL-2, 1971

13

l

l

l

l

+W1972 ADD, SN

l

l

1

l

i

A-0027-1-3 & 2-3

RV-102 & 10413/4" x 1"

l

l

'2BV657 U

i Dresser ind; Cold Set:

Dresser IND, 3/4" x

(inside

Irelier

i

i

155 psi;ACC:15 psi SN

1" relier valve;3/8"

"

"

"

CTMT)

l valve on l

TE97415 & TE97413 ASME orifice, SN TE97413/

12-CCP-018-l

l

Ill/CL-2

15, 150psig SET

130/36-2

i

L

pressure, 793#/HR

I

I

l

sat STM e 10% blow-

)

i

i

I

down, ASME I l l/CL-2-

l

l

l

l

11974 + 1974 ADD,

I

l

l

l

1200 osi/400

. _ _ _ _ _ _ _ _ _ .

- _ _ - _ _ _ - - - . . . _ .

_ _ . ,

_ ,___

,,

, --

,

.

%

TABLE 6.2

Page 3 or 3

PCCW SYSTEM EQUIPMENT SELECTED FOR DESIGN DATA REVIEW

SWEC

SPC

SPECI.

FSAR

FIELD NAME

1 VENDOR DOC.& NPV-1;

EWEC EQUIP # DESCRIPT

FLOW DIA. #

ISO

DATA

DATA

PLATE DATA

.

DATA

V20 & V21

Gate

RM-77A-120

107225

2BV-073

ASME ,I l l/CL-3

Walworth valve; ASME

Wa lwo rth Co. , 8"-150

valves on

i

lil/CL-3, SN D66475 & ' 275 psig/100F, ASME

1. CS, VGWO15-A-3,

2-CCP-008

D66483, 275psig 0100F

-454/455-3

.(600F MAX)

lil/CL-3 -1971 +

6/1972 ADD, SN

0-66475 &.483

V8

Chec,k

107203

2BV-022

TRW-Mission MFG; Size

Mission MFG Co. Buo-

valve on

20; 275ps ig/100 F; SN

Check Valve-20"-150#

"

"

2-CCP-020-

B8631 ASME 111/CL-3

VCl-015-C-3, 275psig

463-3

100F, ASME 111, CL-3

1974 + 6/1974 ADD,SN

88631

V49 & VS1

Butterfly

RM-77A-12D

107209

2BV-069

ASME lil/CL-3

Henry Pratt; 200psig/

Hen ry Pra tt,20"-1400

valves on

300F, operator deltaP

series VV1015-AR-3

2-CCP-020-

153 psi SN A0034-8-1&5

200psig/300F, 275 psi

492/493-3 l

ASME lil/CL-3

100F ASME lil/CL-3

1971+W1972 ADD, SN

A-0034-8-1 & 5

VII & V19

' Butterfly

107203

Henry Pratt; 200psig/

Henry Pratt; 20"-

valves on

200F, opr delta P=135

l 1100 series VVF015-A

"

"

"

2-CCP-020-

psi, SN-D-0134-1-2 & 4 l-3,

200psig/300F,

463/464-3

ASME lil/CL-3

l275psig/100F, ASME

lil/CL-3 1971 + 1972

L

l

ADD.SN 0-0134-1-2&4

V146, V147

Gate

RM-778-12B

110703

2BV-073

ASME lil/CL-3

Walworth valve; 275 psi

Walworth Co.

18"-

& 158

valves on

100F; (600F max) SN

VCWO15-A-3, 150#,

2-CCP-018-

D63683,84&85, ASME Ill 275psig/100F; ASME

31/96/57-3

CL-3

lil/CL-3, 1971 +

6/1972 ADD, code case

1672, SN D63683,

84 & 85

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