IR 05000334/1984030

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-334/84-30.Checks & Balances Provided by Procedure to Assure Independent Review Necessary & Warrant Suggested Clarification

ML20137C026
Person / Time
Site:	Beaver Valley
Issue date:	08/16/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carey J DUQUESNE LIGHT CO.
References
NUDOCS 8508220193
Download: ML20137C026 (2)

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AUG 161985 ,

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Docket N Duquesne Light Company ATTN: Mr. J.~ J. Carey Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Inspection Report No. 50-334/84-30 This refers to your letter dated May 10, 1985, in response to our letter dated April 5, 198 We have reviewed your response and concur with your rationale regarding the acceptability of this specific case and, therefore, withdraw the violatio Ho' wever, we do maintain that the checks and balances provided by the procedure to assure independent review are necessary and possibly warrant clarification as you have suggested. We will review this matter and your proposed actions during a future inspectio Your. cooperation with us is appreciate

Sincerely,

. h Y bf Stewart D. Ebneter, Director Division of Reactor Safety

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- H. M. Siegel, Manager, Nuclear Engineering Department C. E. Ewing, QA Manager

W. S. Lacey, Station Superintendent

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R. Druga, Chief Engineer

. R. Martin, Nuclear Engineer

- J. Sieber, Manager, Nuclear Safety and Licensin

- T. D. Jones, Manager, Nuclear Operations

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, U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atten: Stewart D. Ebneter, Director Division of Reactor Safety Region I 631 Park Avenue King of Prussia, PA 19406 Reference: Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 84-30 Gentlemen:

In response to your letter of April 5, 1985, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced inspection report. Note that a one week extension of the response time was granted per telecon with Region I (Mr. Cliff Anderson).

Upon review of the circumstances surrounding the apparent violation, Duquesne Light Company believes that there was no violation of procedure as is discussed in the attached Reply to Notice of Violation. Duquesne Light Company therefore respectfully requests that this violation be withdraw If you have any questions concerning this response, please contact my offic Very truly yours,

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J. J. Carey Vice President Nuclear Group Attachment c"

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Reply to Notice of Violation Inspection 84-30 Letter dated April 5, 1985 Page -2- Programmatically the lead inspector is designated as the-discipline supervisor (in the supervisor's absence), as referenced in the Schneider Power. Corp. Quality Control Procedures. QCP- states that, " Management personnel may delegate the performance of activities to their subordinates; however, they shall retain the responsibility for those activie In the absence of an individual filling a specific position, the person in the next superior position may assume the responsibilities and duties of that position."

It should be noted that an independent review of the inspection report was provided by the QC Enginee Based on our review of the existing procedures and the aforementioned circumstances, it is our opinion that the activities conducted in the review of the noted IR were performed in accordance with approved procedures. These procedures meet and exceed the minimum requirements for quality control inspections as specified in 10CFR50 Appendix B and the QA Program. Therefore, Duquesne Light Company does not consider this to be an item of non-complianc In order to preclude any future confusion on this subject, the applicable Schneider Power Corporation Quality Control Procedures will be reviewed by July 1, 1985, to determine if any changes can be incorporated to provide additional clarification.

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Beaver Valley Power Station, Unit N Docket No. 50-334, License No. DPR-66 Inspection Report 84-30 Page -2-cc: W. M. Troskoski U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261

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DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION UNIT NO. 1 Reply to Notice of Violation Inspection 84-30 Letter dated April 5, 1985 VIOLATION (Severity Level V; Supplement I)

Description of Violation (84-30-03) -

10 CFR 50, Appendix B Criterion V states in part that " Activities affecting quality shall be prescribed by documented instructions, procedures... and shall be accomplished in accordance with these instructions and procedures". -

Licensee procedure ~ QCP 10.1, states in part that " Inspection attributes shall be signed off by the inspector, the lead inspector (or his designee),

the Q-C supervisor, and by the Q-C engineer".

Contrary to the above, on December 18, 1984, the inspector identifed on licensee Inspection Report IR-E-14528 (NOTE: number was incorrectly listed in Notice of Violation), the sign-offs for all except the Q-C engineer were made by the same person ( a level II inspector).

Discussion A review of the Schneider Power Corporation Quality Control Procedures was performe Procedure 10.1 provides a review cycle for the sign-off of~

inspection reports (IR). This procedure requires the inspector who performed the inspection to initial and date the report. QCP 10.1 then states "The QC inspector... shall forward the IR to the Lead Inspector for an initial cursory revie He shall forward the IR to the QC Supervisor for initial review and determination that all required attributes have been inspected as required. The IR is then~ forwarded to the QC Engineer for final review and approval."

The multiple sign-offs by one individual on the inspection report was considered acceptable in this instance because: The individual was certified as a level II inspector to IP-E-04, Rev. 3, the inspection plan of. record and therefore initialed and dated the report as the responsible inspecto . The individual was sole lead inspector for the electrical discipline and therefore responsible for performing the lead inspector revie S

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