IR 05000412/1985099

Revised SALP Rept 50-412/85-99 for Apr 1984 - Mar 1985, Incorporating Info Provided in Util & 850619 Mgt Meeting Re Completion Status of Cable Pulling & Scheduling for RCS & Steam Generator Hydrostatic Tests

ML20134E589
Person / Time
Site:	Beaver Valley
Issue date:	08/13/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134E574	List: IR 05000412/1985099 ML20134E570
References
50-412-85-99, NUDOCS 8508200338
Download: ML20134E589 (46)

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ENCLOSURE 1

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT 50-412/85-99 DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION, UNIT 2 (Construction Phase)

ASSESSMENT PERIOD: APRIL 1, 1984 - MARCH 31, 1985 BOARD MEETING DATE: MAY 20, 1985 hp[ ND M G

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SUMMARY (4/1/84 - 3/31/85)

BEAVER VALLEY POWER STATION, UNIT 2 Functional Area Hours % of Time i Containment and other Safety-Related Structures 50 1 Piping Systems and Supports 1039 27 Safety-Related Components 607 15

' Support Systems (HVAC) 345 9 Electrical Power Supply and Distribution 668 17 Instrumentation and Control Systems 425 11 Licensing Activities 0 0 Storage of Safety-Related Components 372 9 Engineering / Construction Interface 219 6 1 Preoperational/Startup Test 192 5 11. Quality Assurance and Administrative Controls *

TOTAL 3917 100

• Included in other functional areas

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INSPECTION ACTIVITIES BEAVER VALLEY POWER STATION, UNIT 2 Report Number Inspector Areas Inspected i

84-04 Specialist Installation of safety-related electrical equipment 108 Hours and the status of the separation progra Resident Followup on unresolved items, bulletins, 50.55(e)

107 Hours items, information notices, self-initiated INP0 audit; design and inspection of seismic Cat. 2 com-ponents and daily site tour SALP Repor Resident Followup on unresolved items, allegation on surface 127 Hours coatings, 50.55(e) items, deviation; cable separation; activities of constructability review team; vendor supplied material record review; qualification of post weld heat treatmen Specialist Work activities relative to the installation of in-96 Hours strument cables and termination, and HVAC system to ascertain whether these activities were being accom-plished in accordance with NRC rec 'irements and licensee SAR commitment Resident Followup on noncompliances, unresolved items and 135 Hours 50.55(e) reports; in place storage; reactor vessel internals; dispositioning Nonconformance and Dispo-sition Reports; fire protection; record review of steam generator tube rollin Specialist Work activities and documentation relative to the 96 Hours installation of instruments and electrical equipment storage to ascertain whether these activities were being accomplished in accordance with NRC require-

. ments and licensee SAR commitment Specialist Followup on licensee actions relating to several 8 Hours open items in the area of HVAC, electrical, piping and equipment support Specialist Inspection of turnover portion of the Quality Assur-104 Hours ance Program for preoperational testing, including

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QA/QC overview and interface activitie c ___________________ _ _____________ .

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Report Number Inspector Areas Inspected 84-13 Specialist Previously identified unresolved items, record re-61 Hours view, qualification of post weld heat treatment, observation of welding, visual inspection of welds, review of welder performance qualification, filler metal contro Resident Followup on unresolved items adn 50.55(e) items, 142 Hours Quality Control reinspection program of supports, electrical cable, incorporation of Construction Re-vision Notices, Engineering Confirmation Program, drawing control, seismic and environmental qualifi-cation reports, record review of pipe weld Specialist Independent measurements inspection at the construc-434 Hours Onsite tion site using the NRC mobile Non-destructive Ex-192 Hours Offsite amination (NDE) Laboratory. Selected safety-related piping, structural and support weldments fabricated to ASME Code,Section III, Classes 1, 2 and 3, and American Welding Society (AWS) Code D1.1 requirements were inspecte Resident Followup on unresolved items, in place storage of 247 Hours components, construction of Spent Fuel and Refueling Cavity Liner, electrical and instrument tubing sup-port installations, repair of main steam isolation valves, inst weld heat treatment of piping welds, upper reactor vessel internals, dispositicn of Non-conformance and Disposition Report Specialist Installation of safety-related electrical equipment 62 Hours and the status of the color separation program and the vendor wiring inspection progra Resident Followup on unresolved iter.s, in place storage of 307 Hours reactor coolant system component fuel pool heat ex-changers and batteries, installation of rigid sway strut pipe supports, review of several information notice .

84-19 Specialist Activities relating to the installation of safety-16 Hours related electrical cable and equipmen ..

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Areas Inspected 85-01 Specialist Preoperational test and operational preparedness in-72 Hours spection program including schedule of testing acti-vities, construction program status, test program requirements, responsibilities and involvement of Quality Assurance and Quality Control, preoperational test procedure status, test procedure review and verificatio Specialist Safety Injection System piping, pipe supports, reac-95 Hours tor vessel internals, preservice inspection and re-view of certain open item Resident Followup on unresolved items, in place storage of 227 Hours components, installation of pipe supports, contain-ment polar crane maintenance, weld material control, weld material certification, review of welding, in-spection procedures, and installation of high strength bolts and nut Specialist Work in process, completed work, and partially com-62 Hours pleted work relating to the installation of safety-related components and system Review and closecut of open item Resident Followup on unresolved items, control of hold tags, 191 Hours inspection and disposition of electrical panel wiring separation, cable pull ticket controls, pipe welding and associated activities; installation of electrical pull boxe Resident Followup on unresolved items, review of radiographic 100 Hours film, welder qualification, and review of nonconfor-mance and disposition report CTI Project management, engineering / construction inter-693 Hours Onsite face, electrical, piping, and quality assuranc Hours Offsite

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ATTACHMENT 1 ENFORCEMENT DATA Report Severity Functional Number Subject Level Area 84-08-03 Uncapped or unplugged instrument tubing and

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instrument connection ports. (Closed 84-16) V 8 84-09-01 Failure to meet commitments to revise several documents affecting raceway cable overfil (Closed 85-05) De Failure to follow procedures to control storage of the personnel air lock (Closed 84-16) IV 8 84-10-01 Sealing of electrical equipment in storag V 8 84-12-01 Walkdown personnel are not certified / qualified except group leaders and Site Quality Contro IV 10 84-18-01 Failure to adhere to procedures for storage requirements for permanent plant equipmen IV 8 85-02-01 Failure to follow procedures for disassembly of valv IV 3 85-02-05 Liquid penetrant indications founds on pre-viously accepted reactor vessel internal V 3 85-04-01 Instrumentation separation did not meet criteri IV 6 85-04-03 Vent drain lines not installed per specification -

V 6 85-04-04 Instrumentation supports-redundant lines *not

supported from independent support IV 6-85-05-01 Failure to remove hold and reject tags in accordance with procedure requirement IV 11 85-05-02 Failure to perform QC inspections in accordance -

with the QA program on electrical panel internal wiring separatio IV 6

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85-05-03 Failure to properly disposition Nonconfor-mance and Disposition reports for cable l pull tension and bend radiu IV 11 85-07-01 Failure to follow procedures in electrical cable installation IV 5 85-07-02 Failure to maintain records to show how or IV 9 whether cable side wall pressure was con- I sidered in cable pulling calculation !

85-07-03 Failure to follow administrative procedure V 11

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EllCLOSURE 2

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• UNITED STATES NUCLEAR REGULATORY COMMISSION ti C-l REGION 1 631 PARK AVENUE

%, ,o'g KING OF PRUSSIA, PENNSYLVANIA 19406 Docket No. 50-412 JUN 0 71985 Duquesne Light Company ATTN: Mr. J. J. Carey Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Report 50-412/85-99 The NRC Region I SALP Board has assessed the performance of activities at the Beaver Valley Power Station, Unit 2 for the period April 1, 1984 - March 31, 198 The SALP Board Report is enclosed. A meeting to discuss this assessment has been scheduled for June 19, 1985. This meeting will be held in Shippingport, Pennsyl-vania, near the sit At the SALP meeting, you should be prepared to discuss our assessment, particularly in the area of organizational structure, reinspections, and electrical concerns discussed in the report and your plans to improve performance. The meeting is in-tended to be a dialogue wherein any comments you may have regarding this report may be discussed; and, if there is additional information which you believe could alter the assessment, please feel free to identify such matters. Additionally, you may provide written comments within 30 days after the meeting. Consideration of any points raised during the meeting or in your written comments will be re-flected in my characterization of your overall safety performance which will be provided as part of the final SALP packag Your cooperation with us is appreciate

Sincerely,

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Thomas E. Murley -

Regional Administrator Enclosure:

SALP Report 50-412/85-99

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Duquesne Light Company 2 JT4f 0 7 ggg; cc w/ enc 1:

E. J. Woolever, Vice President, Nuclear Construction Division R. E. Martin, Manager, Engineering ,

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R. J. Swiderski, Manager, Startup Group E. Ewing, Quality Assurance Manager E. F. Kurtz, Jr., Manager, Regulatory Affairs P. RaySircar, Stone and Webster Engineering Corporation Public Document Room (POR)

local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania

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ENCLOSURE 3 SALP MANAGEMENT MEETING ATTENDEES

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JUNE 19, 1985 Duquesne t.ight Company J. Arthur, Chairman J. J. Carey.. Vice President, Nuclear E. J. Woole w r, Vice President, Special Nuclear Projects N. R. Tonet,', General Manager, Nuclear Engineering and Construction J. Sieber, Seaior Manager, Unit 1 H. M. Siegel,' Nuclear Engineering Manager C. E. Ewing, Qgality Assurance Manager R. J. Swiderskii Startup Manager R. E. Martin, Engineering Manager J. F. Grogan, Corporate Communications F. A. Cavalier, Manager, Project Control J. A. Hultz, Construction Liaison S. D. Hall, Licensing, Senior Project Engineer Stone and Webster Engineering H. F. Foley, Site Project Manager W. H. Bolke, Senior Project Manager H. W. Durkin, Superintendent of Engineering C. O. Richardson, Project Engineer A. A. Dasenbrock, Resident Manager J. E. Williams, Senior Construction Manager P. A. Wild, Director of Engineering CAPC0 B. M. Miller, Manager, Projects, Ohio Edison Company A. Timme, Toledo Edison Company Nuclear Regulatory Commission T. Murley, Regional Administrator, Region I W. F. Kane, Deputy Director, Division of Reactor Projects (DRP), Region I

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E. C. Wenzinger, Chief, Projects Branch No. 3, DRP, Region I L. E. Tripp, Chief, Reactor Projects Section 3A, DRP, Region I S. Varga, Chief, ORB-1, Division of Licensing, NRR B. K. Singh, Project Manager, NRR G. A. Walton, Senior Resident Inspector, Beaver Valley Unit 2 W. M. Troskoski, Senior Resident Inspector, Beaver Valley Unit 1

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ENCLOSURE 4 s* T-

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Nuclear Group Quahty Assurance Unit Box 184 smooingport. PA 15077 July 19,1985 2NRC-5-105 United States Nuclear Regulatory Comission Region I 631 Park Avenue .

King of Prussia, PA 19406 ATTENTION: Dr. Thomas E. Murley, Regional Administrator -

SUBJECT: Systematic Assessment of Licensee Performance (SALP)

Report No. 50-412/85-99 Gentlemen:

Thank you for meeting with us on June 19, 1985 to discuss the Beaver Valley Power Station Unit No. 2 SALP Report for the period of April 1, 1984 through March 31,198 ..

In addition to the items discussed at the June 19th meeting, the following items summarize the actions taken or planned to be taken to address the con-cerns which were identified in your letter of June 7,1985:

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.Section IV.2 - Piping Systems and SupportsSection IV.2 identified an area of concern regarding control of reworked items, specifically pipe supports. This item was originally identified by DLC in mid-1984 as a potentia"y significant deficiency (SDR-84-06). As outlined in the final report for SDR 84-06 (letter 2NRC-4-200 dated 12/3/84), correc-tive actions taken to improve control over reworked pipe supports have included:

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Issuance of FCP-41 to formally document and track the requirements applicable to dismantled or partially dismantled items, components, or structures which have been previously SQC inspecte . Issuance of SQC IP 7.45 to provide an SQC over-view of this area and ensure site compliance with the requirements of FCP-4 .

Assignment of an SQC inspector to perform surv'eillance of the above program to provide assurance that the intent of the program .

is bei.ng fulfille Subsequent to the above noted concerns with pipe supports, the NRC

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, R:s;s,onse 'to SALP Report No. 50-412/85-99 issued Violation 85-02-01, regarding ths disassembly of a safety-related valve with'out appropriate authorization or documentation being issued. As a correc-tive action regarding this problem, Site Project Management has directed the electrical and mechanical contractors to re-emphasize to appropriate personnel the requirements for strict adherence to the site rework control program; personnel failing to comply with rework control procedures will be subject to disciplinary action. To prevent similar occurrences in the future, designated contractor Building Managers are now a focal point for any rework of previously installed permanent plant equipment, and are responsible for assuring that such rework complies with all rework requirement Section IV.5 Electrical Power Supply and Distribution The NRC's concerns for this area can be divided into two distinct cate-gories, specific concerns and general conc. erns. The specific concerns have ,

been identified as NRC Unresolved Items or Violations or reported on Signifi-cant Deficiency Reports. These specific issues have involved several aspects of the electrical design and installation process at BVPS-2, as well as all organi-zations involved in the process. All of these specific issues have been pre-viously addressed as NRC Open Items and are being tracked to ensure timely resolu-tion and completions. Certain of the issues have precipitated changes in the procedures or processes governing electrical activities within engineering, SQC, or the electrical contractor. Many of the issues have already been resolved to the NRC's satisfactio ..

The NRC's general concerns are the following:

"(Licensee is to) complete development of an overall comprehensive plan to address and resolve problems in this area. Implement an integrated plan for timely resolution of remaining outstanding electrical issues. Complete reinspections and rework prior to system turnover."

As stated above, the resolution of remaining outstanding electrical issues is currently on-going and receives high priority. The BVPS-2 Project NRC Open Items List provides concise information regarding the status for these NRC item This report is utilized by management personnel to ensure that all items receive timely attentio An integrated and detailed plan, entitled the Electrical Plan Guide (EPG)

has been developed and was issued for official project use and information on June 10, 1985. It describes the plans for resolution of engineering items and completion of construction and inspection activities on tasks important to the electrical effort. The plan will be kept up to date on a quarterly basi The Project recognizes that systems are being turned over for the constr; -

tion proof testing activity with outstanding items. The previously referenc6d EPG defines all of these required actions and the reinspection / verification of ~

the conditions reported has conmence The Project has recently undertaken an overall review of the BVPS-2

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Response to SALP Report No. 50-412/85-99

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electrical installation specification,The electrical Field Construction Proce-dur'es, and the SQC electrical Inspection Procedures. The objective of this review is to ensure consistency among these documents, and to ensure each do'u- c ment is complete regarding its purpose. The review of the electrical installa-tion specification will identify the bases used to develop the various numerical limits and requirements specified and will provide assurance that calculations, codes, or standards used as bases for the specification are properly documente These reviews, and any necessary corrective actions are scheduled to be completed by September 30, 198 Finally, the staffs of both the Site Engineering Group and the Integrated Construction Support Group have been strengthened through the addition of senior experienced electrical engineers. The introduction of these individuals has improved the interface among engineering, construction, and quality contro .

Section I Instrumentation and Control Systems .

The SALP Report discussion of this functional area identified the following areas as needing improvement:

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a) The engineering and design process regarding QA Category I instru-mentation tubin b) Engineering and construction efforts to ensure compliance with R.G. 1.75 separation requirements for internal panel wirin Actions which are being taken to address these issues are summarized below:

a) The NRC's concerns with the engineering and design process for QA Cate-gory I instrumentation tubing are summarized in the SALP Report as follows:

"The three violations involving the installation of instruments and L instrument tubing were the result of inadequate engineering design review and ambiguity in the specification and are indicative of a problem in this area. Specifically, onsite engineering failed to translate sufficient information from composite drawings to single line construction drawings used by craft and QC personnel. The

insu"ficient information in these drawings regarding installation and construction criteria such as instrument type, tubing size, loca-tion, separation, slope and routing led to problems involving inadequate separation of redundant tubing, mounting of redundant instrument tubing on the same support, and failures to mount instrument vents and drains to direct the discharge away from personnel and electrical equipmen The licensee and SWEC took rapid corrective action by issuing a stop work order on the installation of instrument tubing pending an engineer-ing review and resolution of the discrepancies. The licensee has pro-posed tighter engineering controls, but still does not require Quality

Control personnel to verify separation criteria for instrument tubing." l i

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. Page 4 Response to SALP R2 port No. 50-412/85-99

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The following points are drawn from letter 2NRC-5-078 and serve to respond to the NRC concerns quoted above:

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A review of specification 2BVS-977 and the engineering and design pro-cess was initiated in an effort to establish that all necessary requirements regarding separation criteria were present, consistent, and understandabl . The specification review was completed and 2BVS-977 was revised to enhance the clarity of various sections. Also, site procedure 2BVM-228 for the design of instrument tubing in seismic areas was issued, and SEG engineers and designers were trained in the use of the procedur .

A review of all issued isometric drawings was completed to assure that all tubing separation deviations or mounting deficiencies were appropriately identified and dispositioned. No hardware modi-

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fications have resulted from this revie . Regarding the installation of vent and drain lines on instrument tubing lines, administrative procedures are being revised to ensure that, where necessary, potential effluent discharges will not present any hazard .

A review of instrument tubing installation drawings was completed and indicated that, aside from the separation issues discussed above, the -

drawings contained sufficient information regarding instrument type, tubing size, location, slope and routing, as necessar .

The STOP-WORK order was released once necessary actions were com-pleted to ensure the adequacy of continuing work on QA Category I instrument tubin In addition to the above actions, the following steps have been taken to further address concerns in this functional area, and to provide an additional level of assurance that the instrument tubing and design pro-cess is of the highest quality:

. A review of 2BVS-977, pertinent Field Construction Procedures and SQC Inspection Procedures, will be conducted to ensure that these project documents are complete and consistent with each other regarding instrument tubing design and installation activitie This review, including any necessary corrective actions, will be completed by September 30, 198 .

Engineering is providing SQC with engineering information necessary to develop inspection procedures for SQC verification of the spatial separation of safety-related redundant instrument impulse lines. The necessary SQC and project documents to ensure this verification are scheduled to be issued by September 30, 198 ___. ..

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b) The NRC's concerns regarding electrical panel internal wiring separa-tion reviews that were conducted without SQC participation have been fully addressed in DLC's letter 2NRC-5-073 dated 5/17/85. As stated in the letter, the engineering review to determine separation discrep-ancies was not outside the DLC QA Progra The subject panels were scheduled to receive a final SQC inspection following completion of the engineering activity. This SQC inspection activity has comence In addition, the NRR has been provided with the "BVPS-2 Electrical Separation Verification Testing Report", which provides justification for the explicit separation criteria being used in the evaluation of Class 1E electrical equipment at BVPS- Finally, pertinent project documents have been revised to include explicit separation requirements applicable to electrical panels that contain both external wiring (field installed) and internal wiring -

(vendorsupplied). Further details regarding this issue will be developed to address NRC Unresolved Item 85-05-0 A significant number of corrective actions have been initiated and com-pleted, and it is our opinion that, while a significant amount of instrumentation work is required to complete the project, no major changes to the existing admin-istrative controls are necessary to achieve full compliance with NRC regulation Section IV.8 Storage of Safety Related Components ~

The NRC discussion of this functional area refers to a variety of storage problems that have previously been identified as Unresolved Items, Violations, or SDRs. A majority of these individual items represented deviations from BVPS-2 in-plant storage requirements, and required various corrective action To date, most of the specific storage problems have been resolved with the NR In addition, as the NRC has acknowledged, strong and extensive action has been taken to improve storage conditions at BVPS-2, including:

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assignment of contractor personnel as permanent Building Managers, with direct responsibility and accountability for overall care, custody and control of installed equipment, until turnover to SU .

establishment of a Composite Review Work Group (CRWG), with broad contractor, SWEC, and DLC involvement, to identify weaknesses with storage requirements / procedures or with physical in-plant condition .

formation of a Management Oversight Committee (M0C) to assess the overall effectiveness of the storage program, and provide continu-ing and visible management attention in this are The evaluation of this functional area included a recommendation that the licensee " provide continuing management overview to preclude recurrence of past cyclic performance in this area." .

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Management attention to the storage program at BVPS-2 will continu The i

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CRWG, M0C, and Building Manager system tfiscussed above will be maintained as the primary vehicles for ensuring adequate in-plant storage condition .

Section IV.9 Engineering / Construction Interface The evaluation of the engineering / construction interface at BVPS-2 reflects the progress achieved to date in the ongoing programs established in response to weaknesses identified in this functional area during previous SALP assessment periods. However, two concerns remain:

a) "In the electrical and instrumentation functional areas, some linger-ing interface problems still exist..."

b) " Management must continue to be sensitive to the engineering /construc-tion interface in all functional areas to ensure that the recent improvements remain until the project is completed." '

Actions which are being taken to address these concerns are as follows:

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a) Initiatives which have been taken to enhance the engineering /construc-tion interface for the electrical and instrumentation controls areas are discussed under Section IV.5 and IV.6 of this documen b) Project Management has taken various steps to improve the BVPS-2 engineering / construction interface, including initiation of the -

BVPS-2 Engineering Confirmation Program, establishment of Construc-tibility Review Teams and the Integrated Construction Support Group, i

issuance of the project Electrical Plan Guide to provide an inte-grated and concerted approach for the resolution of electrical issues, and assignment of experienced individuals to various site potitions

.which involve direct contact with construction force Executive management has instituted a scheduled weekly meetirtg that involves senior site personnel from the Engineering, Construction, Startup and QA/QC department The prime function of this meeting

is to ensure that potential interface problems are identified at the earliest possible time and that appropriate actions are taken to ensure that timely resolutions are obtaine It is considered that these face to face discussions assist executive management in main-l taining the improved engineering / construction interfaces described l

in the SALP Repor c) With reference to the three specific items of concern described by the NRC in the CTI Report, DLC's response identifies the actions taken to ,

address cable pulling practices (85-07-05) and lack of documentation of calculations related to cable tension / side-wall pressure (85-07-09).

Further details describing our actions with reference to Unresolved

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. * * Page 7 Response'to SALP R: port No. 50-412/85-99 Section IV.10 Preoperational/Startup Testing The BVPS-2 Startup Group provides direct and timely knowledge of plant status, and includes determination of turnover acceptability of systems / subsystems. The acceptability of a system / subsystem is based upon the readiness for satisfactory performance of construction proof testing and does not imply that the system /

subsystem is ready to perform activities other than construction proof testin Accordingly, the number of open items can be higher when a system / subsystem is turned over at the construction proof test phase than at the system testing phase (system operability verification tests and preoperational tests).

The DLC SUG has established a three phase program for the formal review and acceptance of plant systems by DLC: the initial phase defines the turnover of systems / subsystems from construction to DLC SUG to perform construction proof testing, the second phase requires a system review release for the performance of system operability verification (50V) and/or Pre-operational (pre-op) test activi- ,

ties, and after completion of the 50V and/or pre-op testing, the final phase requires a system acceptance release by DLC Nuclear Operations personne Field Construction Procedures have been revised to add additional controls, specifically identify and assign responsibilities and provide greater detail regarding implementation of the turnover program. These procedures require appro-priate certification of personnel, programatic review of system / subsystem comple-tion status and identification of uncompleted items by the site contractor. A formal review and concurrence by Building and Milestone Managers that the system /

subsystem is ready for turnover, and SQC verification of the construction status -

prior to submission of the turnover package to SVG for acceptance is require This process is functioning to turn over systems / subsystems for construction proof testing with a recognizable reduction in the number of discrepancies or nonconform-ing conditions reporte All site organizations have become more proactive in ensuring that systems /

subsystems are more complete prior to turnover. Senior DLC personnel have been assigned within the electrical contractor's site organization. The rework con-struction activities are directed by a senior DLC construction representative working within the Construction Management site organization. Additionally, field construction supervision with greater contemporary experience in systems /

subsystems completion and turnover have been assigned. The assignment of the personnel described ensures accurate and thorough identification of system /

subsystem status and approves and coordinates all construction work to be per-formed on systems / subsystems that have been turned over for testin Section IV.ll Quality Assurance and Administrative Controls Duquesne Light management has discussed the NRC concern regarding organiza-tional changes wherein the QA/QC function reports to the Nuclear Group Vice Presi-dent. It must be recognized that cost and schedule concerns and quality concerns must be addressed by a key individual at some level of management. In Duquesne Light, this occurs at the Nuclear Group Vice President level, who reports directly -

to the Chairman of the Board and President of the Company. It should also be noted i

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that the Manager of Quality Assurance may go directly to the President of the Com-pany with quality matters. In addition to the normal reporting chain, quality matters can also be discussed at the weekly BVPS-2 Site Managers Meeting, at the Vice President of Nuclear Group's biweekly BVPS-2 Staff Meeting, and at the bi-monthly Project Management Committee Meetin Duquesne Light management is com-mitted to assuring the high quality of BVPS-2 and will continue to monitor quality trends to ensure that cost and schedule concerns do not adversely affect the quality of the plan DLC management has established a quality organization which is totally inde-pendent of the engineering / construction /startup organization. The Quality Assur-ance Manager is provided with adequate resources to ensure that the inspection activity can be accomplished in a timely manner to enable the construction work to proceed in an orderly manne We recognize that the project organization has undergone an evolution during .

the period covered by this SALP Report. The Management Analysis Corporation has been retained to review our existing organization and to provide recommendations on the desirability of adding additional key personnel to assist us in the comple-tion of the project. We expect the results of this review to be issued in Septem-ber. We will inform you of any planned changes to the project organization per-sonnel that are made as a result of this revie We believe that the BVPS-2 Project has one of the finest quality programs in the industry and we will continue to provide the necessary support to assure the independence and integrity of the existing progra DUQUESNE LIGHT COMPANY 1 p/'

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By

d.J(frey Vice President CEE/jh

cc: Mr. B. K. Singh, NRC Project Manager Mr. G. Walton, NRC Resident Inspector NRC Document Control Desk

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