L-97-070, Forwards Response to Violations Noted in Integrated Insp Repts 50-334/97-07 & 50-412/97-07.Corrective Actions:Qsu Performed 10CFR50.54(a)(3) Evaluation Re Reassignment of Quality Control Receiving Insp Function from Qsu
| ML20203B279 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/08/1997 |
| From: | Jain S DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-334-97-07, 50-334-97-7, 50-412-97-07, 50-412-97-7, L-97-070, L-97-70, NUDOCS 9712120397 | |
| Download: ML20203B279 (4) | |
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UUS*ea L-97-070 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Integrated Inspection Report 50-334/97-07 and 50-412/97-07 Reply to Notice of Violation In response to NRC correspondence dated November 7,1997, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
If there are any questions concerning this response, please ;ontact Mr. J. Arias at I
(412) 393-5203.
Sincerely, Sushil C. Jain Attachment c:
Mr. D. S. Brinkman, Sr. Project Manager Mr. P. W. Eselgroth, Chief, Reactor Projects Branch No. 7, Region I i
Mr. C. W. Hehl, Director, Division of Reactor Projects f
i Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator 9712120397 971200 i.
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DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit Nos. I and 2 Repiv to Notice of Violation Integrated Inspection Report 50-334/97-07 and 50-412/97-07 Letter Dated November 7,1997 VIOLATION (Severity Level IV, Supplement 1)
Description of Violation (50-334(412)/97-07-02) 10 CFR 50.54(a)(3) requires, in part, that changes to the quality assurance program description that reduce the commitments (in the program description previously accepted by the NRC) be submitted to the NRC and receive NRC approval prior to implementation.
Contrary to the above, in April 1994 the licensee changed the quality assurance program, resulting in a reduction in commitments in the quality assurance program description previously accepted by the NRC without prior NRC approval. Specifically, the licensee realigned the Quality Control receipt inspectors from the Quality Services Unit to the procurement department. This organizational change reduced the authority and organizational freedom of the quality control organization performing procurement receipt inspections.
Reason for the Violation In January 1994, prior to the Quality Control personnel who were performing receising inspections being reassigned to Nuclear Procurement, the Quality Services Unit (QSU) perfotmed a review of the QA Program description contained in Unit 2 UFSAR, Section 17.2 and determined that a 10 CFR 50.54(a)(3) evaluation was not required. This was based on the Unit 2 UFSAR Section 17.2 not containing any details identifying to whom the inspectors performing receiving inspections reported and the proposed change not requiring any rewordidg of that section.
This Unit 2 UFSAR section contained the QA Program description applicable for both Units 1 and 2, which was submitted to the NRC in 1988 for approval. The proposed change did not require any rewording of this QA Program description for the Beaver Valley Power Station contained in the Unit 2 UFSAR Section 17.2. It was QSU's understanding that only actual wording changes to this Unit 2 UFSAR section or to the UFSAR positions on QA related Regulatory Guides needed to be reviewed for potential reductions to the QA Program description commitments under 10 CFR 50.54(a)(3). It
J Reply to Notice of Violation -
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Inspection Report 50-334/97-07 and 50-412/97-07
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- i was not believed that a change to the Unit 2 UFSAR Chapter 13 could reduce the QA' Program description commuments.
Corrective Actions Taken and the Results Achieved The QSU performed a 10 CFR 50.54(a)(3) evaluation regarding the reassignment of the Quality Control receiving inspection function from QSU to the Nuclear Procurement Department, which occurred in April 1994. This evaluation was completed on October 10,1997, and concluded that this reassignment of personnel was a reduction in commitments to the NRC. Following this detennination, and also on October 10,1997, the Vice President, Nuclear Services issued a letter (NPDSVP:7934) which efTective immediately and until further notice, functionally reassigned the Quality Control receiving inspection function to the Manager, QSU.
Corrective Actions to Prevent Further Violations The following additional corrective actions will be implemented:
The root cause evaluation for this event will be reviewed with the Quality Sersices Unit personnel responsible tbr perfonning 10 CFR 50.54(a)(3) evaluations. This will be completed by December 22,1997.
A review of organizational changes related to the Quality Assurance Program, including transfer of personnel or resporisibilities from QSU to other organizations, which occurred after January 1994 will be performed. This is the period when certain changes to QA processes were implemented to more effectively utilize resources. This review will identify if any additional 10 CFR 50.54(a)(3) evaluations are required and will be completed by February 28,1998.
.-. Additional reviews of UFSAR sections (other than the Unit 2 UFSAR, Section 17.2) '
will be performed to determine if there are other instances where changes to those sections could potentially result in a reduction in commitments in the Quality R
. Assurance Program description. These reviews will be completed by March 31, 1998/ Should any additional instances be identified Condition Reports will be
- written, e ~ Revise procedure NPDAP 7.3, " Annual Final Safety Analysis Report Update" to
- ensure the ~ question of whether a proposed change to the UFSAR can result in a reduction in commitments in the Quality Assurance Program description is addressed.
This revision will be completed by May 29,1998.
Reply to Notice of Violation Inspection Report 50-334/97-07 and 50-412/97-07 Page 3 Develop and implement a process to review organizational changes prior to implementation to ensure licensing documents and commitments are not affected.
This will be completed by June 30,1998.
Date When Full Comnliance Will Be Achieved With the reassignment of the Quality Control receiving inspection function to the Manager, QSU on October 10,1997, the issue of the requirement to submit a 10 CFR 50.54(a)(3) evaluation to the N.RC was resolved and full compliance was achieved.
. No other issues of non-compliance have been identified. If the additional corrective actions identify any new issues of potential non-compliance, appropriate corrective actions will be implemented.
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