L-98-043, Forwards Response to Violations Noted in Insp Repts 50-334/97-09 & 50-412/97-09.Corrective Actions:Util Emergency Preparedness Plan,Section 7.6.2,Rev 10,revised to State Alternate EOF Phones Shall Be Tested Quarterly
| ML20216B168 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/06/1998 |
| From: | Jain S DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-334-97-09, 50-334-97-9, 50-412-97-09, 50-412-97-9, L-98-043, L-98-43, NUDOCS 9803120429 | |
| Download: ML20216B168 (4) | |
Text
1 1
ver Valley Power Station Sh5pingport. PA 15077-0004 EUINaw ni March 6,1998 ru$l$U$$$
Ul*Nw"'Sion L-98-043 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 50-334/97-09 and 50-412/97-09 Reply to Notice of Violation In response to NRC correspondence dated February 4,1998, 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 contact Mr. J. Arias at
_(412) 393-5203.
Sincerely, Sushil C. Jain
/
Attachment c:
Mr. D. S. Brinkman, Sr. Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator U
I Mr. Neil S. Perry, Acting Chief, Reactor Projects Branch No. 7, Region 1 DEllVERING 9803120429 980306 lllllllllll.lllallll l 011 A L I T Y DR ADOCK 050003 4 i
l L
DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit No. I and No. 2 I
Reply to Notice of Violation Integrated Inspection Report 50-334/97-09 and 50-412/97-09 Letter Dated February 4,1998 VIOLATION A (Severity Level IV, Supplement VIII)
Description of Violation (50-334(412)/97-09-03)
)
The Beaver Valley Emergency Preparedness Plan, Section 7.1.4.2, provides that M %
event the nearsite _ Emergency Operations Facility (EOF) is uninhabitable, it will be relocated to the Alternate EOF at Coraopolis, PA.
Communications equipment, including direct telephone lines, is provided in the Alternate EOF.
10 CFR 50, Appendix E, Section IV.E.9, requires that all communication plans shall have arrangements for emergencies, and that, where consistent with the function of the governmental agency, these arrangements will include:
a.
Provision for communications with contiguous State / local governments within the plume exposure pathway EPZ. Such communications shall be tested monthly, b.
Provision for communications with Federal emergency response organizations. Such communications systems shall be tested annually.
c.
Provision for communications among the nuclear power reactor control room, the onsite technical support center, and the near-site emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams. Such communications systems shall be tested annually.
d.
Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite technical support center, and the near-site emergency operations facility. Such communications shall be tested monthly.
Contrary to the above, the licensee had not tested twenty of twenty-seven direct lines at its Alternate EOF in Coraopolis, PA.
These lines would be used to perform the functions described in Section IV.E.9.a-d of Appendix E in the event of an activation of that facility.
I-
Q Reply to Notice of Violation Inspection Report 50-334/97-09 and 50-412/97-09 Page 2 Reasons for the Violation The original Alternate Emergency Operations Facility (AEOF) was located at an occupied DLC location. In 1990, the AEOF was moved to another location which was not normally occupied until recently. The daily use equipment checks from the original AEOF were not incorporated into any formal procedure for the new AEOF.
The reason that regular testing of the communications circuits at the new AEOF was not performed was an insufficient evaluation of the impact of the change from moving the facility to another location.
Corrective Actions Taken and Results Achieved Condition Repcrt #972287 was issued on December 11,1997. An extent of condition evaluation was perfonned, which did not identify any other occurrence of an insufficient evaluation of the impact of moving an emergency facility.
All conununications circuits at the AEOF were tested on December 12,1997. The test results for the twenty (20) normally off-line phone lines identified fifteen (15) phone lines operable and five (5) phones inoperable. The five inoperable phones were located on desks where other operable phones were available for emergency response use (one of two independent phone lines was operable on each desk). The inoperable phones were repaired and tested satisfactor9v by December 18,1997.
The BVPS Emergency Preparedness Plan, Section 7.6.2, Rev.10, was revised to state
" Alternate EOF phones shall be tested quarterly" and became effective on January 1, 1998.
Corrective Actions to Prevent Further Violations Administrative Procedure EP-10 " Monthly, Quarterly, Annual Communications, ERDS and ERO Voice Mail System Tests" was revised and approved on February 11,1998, to include testing of AEOF phones, and a step was also added to determine and address the impact of new, or relocated equipment.
A determination of other non-daily use emergency facility equipment necessary to be checked is currently being conducted. Upon completion of this determination, the appropriate equipment checks, performed at the testing frequencies required per 10 CFR50, Appendix E, Section IV.E.9, will be incorporated into an Emergency Peeparedness Administrative Procedure by April 1,1998.
1 Reply to Notice of Violation Inspection Report 50-334/97-09 and 50-412/97-09 Page 3 In addition, a step will also be added to Administrative Procedure EP-10 by April 1, 1998, to address evaluating the impact of moving an emergency facility from one location to another.
Date When Full Compliance Will Be Achieved Compliance was achieved following the completion of the testing of the AEOF communication systems, repairing the inoperable phones and the incorporation of a.
quarterly test requirement for the AEOF phones into the Emergency Plan which became effective on January 1,1998.
A determination of other non-daily use emergency facility equipment necessary to be checked is currently being conducted. Based upon this determination, the appropriate equipment checks and testing frequencies will be incorporated into an Emergency Preparedness Administrative Procedure by April 1,1998.
x
--