IR 05000412/1987020

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-412/87-20

ML20237H636
Person / Time
Site:	Beaver Valley
Issue date:	08/19/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Carey J DUQUESNE LIGHT CO.
References
NUDOCS 8708250091
Download: ML20237H636 (2)

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AUG 1 9 1987

Docket No. 50-412 Duquesne Light Company ATTN: Mr. J. J. Carey Senior Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Inspection No. 50-412/87-20 This refers to your letter dated July 24, 1987, in response to our letter dated June 16, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed progra s Your cooperation with us is appreciate

Sincerely,

,0r.isinal signed By:

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filiam V. Johnston, Acting Director Division of Reactor Safety cc w/ encl:

J. D. Sieber, Vice President, Nuclear J. Crockett, Senior Manager, Nuclear Operations E. Ewing, Quality Assurance Manager R. J. Swiderski, Manager, Startup Group J. P. Thomas, Manager, Engineering R. E. Martin, Manager, Regulatory Affairs C. O. Richardson, Stone and Webster Engineering Corporation Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania -

S 8708250091 870019

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PDR ADDCK 05000412 G PDR OFFICIAL RECORD COPY RL BV2 87-20 - 0001. /18/87

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Region I Docket Room (with concurrences)

Managentent Assistant, DRMA (w/o enc 1)

DRP Section Chief J. Beall, SRI, BV-1 P. Tam, LPM, NRR T. Martin, DRSS S. Ebneter, DRS A. Lodewyk, DRS Robert J. Bores, DRSS

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0FFICIAL RECORD COPY RL BV2 87-20 - 0002. /18/87

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Vall No. 2 Unit Project Organization P.O. Box 328

. Shippingport, PA 15077 United States ~ Nuclear Regulatory Comission Region I 631 Park Avenue King of Prussia, PA 19406 ATTN: Mr. William V. Johnston, Acting Director Division of Reactor Safety SUBJECT: Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-20 REFERENCE: 1) Letter dated June 16, 1987, (W. V. Johnston to J. J. Carey)

Gentlemen:

The above referenced letter transmitted a Notice of Violation as Aopendix Attachment 1 of' .this letter provides Duquesne Light Company's (DLC)

response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Violation. As requested in your letter, our response focuses on corrective actions taken to avoid similar problems in the futur DUQUESNE LIGHT COMPANY By . . It k

// J. D. Sieber

!/ Vice President Nuclear DLC/ijr NR/DLC/IR/8720 Attachments AR/NAR cc: Mr. P. Tam, Project Manager (w/a/s) l Mr. J. Beall, NRC' Sr. Resident Inspector (w/a/s)

Mr. L. Prividy, NRC Resident Inspector (w/a/s)

INP0 Records Center (w/a/s)

NRC Document Contr 01 Desk (w/a/s)

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United States Nuclear Regulatory Commission Mr. William V. Johnston, Acting Directcr

• Inspection Report 50-412/87-20 Page 2 bec: J. J. Carey - w/ attachment C. E. Ewing - w/ attachment l '

J. A. Hultz - w/ attachment R. J. Druga - w/ attachment K. D..Grada - w/ attachment T. P. Noonan - w/ attachment M. J. O'Neill - w/ attachment S. C. Fenner - w/ attachment C. Richardson (S&W)(5) - w/ attachment J. Sutton (S&W) - w/ attachment A. A. Dasenbrock, SWEC - w/ attachment R. Anstey, SWEC - w/ attachment l R. Wittschen, SWEC - w/ attachment J. M. Grigsby (W)

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- w/ attachment C. Majumdar - w/ attachment BV-2-NCD-SEG/ Phase 11 PUC Audit - w/ attachment Distribution PDR-378 (4)

Inspection 87-20 File - w/ attachment NCD File - w/ attachment

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ATTAC""ENT 1 i VIOLATION 87-20-01 The Notice of Violation states, in part:

10CFR50, Appendix B, Criterion X states in part "A program for inspection of activities affecting quality shall be established and implemented by or for the organization performing the activity to verify conformance with the documented instructions procedures, and drawings for accomplishing the activity. . . .

During the NRC inspection conducted between March 16 and 26, 1987 the following examples of failure to implement quality control proced ures affecting safety related inspections were identified. . .

. . . . This is a Severity Level V Violatio Response:

As noted in Mr. W. V. Johnston's letter which accompanied the report, the 12 examples of minor problems identified by the NRC were corrected during the course of the inspectio We concur with the NRC assessment that several of these problems may possibly be the result of unauthorized rework. In this regard, we wish to state that, with the onset of the Operational Phase, a revised method of controlling work has been placed into effec All construction work is presently authorized and controlled through a work package system which defines the areas, and the items in those areas which may be worke Based upon our experience with this method of controlling work at BV-1, we believe that the possibility for unauthorized rework is greatly reduce T h e Director of Quality Control has issued a memo to all QC personnel, via training update, in which the aspects of Violation 87-20-01 are discusse In this memo, the importance of maintaining diligence and attention to cietail during inspections is emphasized. As it is tne practice of DLC to engage QC inspectors who are certified in a number of activities, often in multi-disciplines, personnel have been directed to remain cognizant of their own limitations in recalling details applicable to a variety of inspection procedure Page 1 of 2

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i Procedure SQC-1.4, which provides instruction for the issue and control of

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QC procedures, permits controlled copies of individual procedures to be l issued to inspectors for reference in the fiel Personnel have been encouraged to use this program to frequently refer to the text of the inspection procedure during the course of each inspectio Our QA Auditing Group has endeavored to be responsive to NRC comments and suggestions which have been expressed during Inspections 86-47, 87-02, 87-03 and in the recent SALP Repor In our response to the SALP Report, we outlined three plans of action which are being implemented to improve our QA progra Our development of recent audit plans has emphasized increased involvement with the process and physical performance of the audited activit It is our intention to maintain this emphasis and to continue to look for new ways to enhance and improve the effectiveness and benefits of our auditing progra Page 2 of 2

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