ML19260A966

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Responds to NRC 790912 Ltr Re Violation Noted in IE Insp Rept 50-334/79-13.Corrective Actions:Temporary Test Circuit Remounted on Fireproof Matl & Installation Checked for Secure Mounting
ML19260A966
Person / Time
Site: Beaver Valley
Issue date: 10/05/1979
From: Dunn C
DUQUESNE LIGHT CO.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19260A956 List:
References
NUDOCS 7912060205
Download: ML19260A966 (3)


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(412) 4M000 43$ Sesth Avenue nscurgn. Pa October 5, 1979 United States Nuclear Regulatory Commission .

Attantion: Mr. Eldon J. Brunner, Chief Reactor Operatioas and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, Fennsylvania 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 79-13

Dear Mr. Brunner:

In response to your letter of September 12, 1979 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violation was the inadequate implementation of design control measures.

If you have any questions concerning this response, please contact my office.

Very truly yours,

( Y' V%m C. N. Dunn Vice President, Operations Attachment 1510 324 1912060 gC[

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'JQoESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-13 Letter Dated September 12, 1949 Desari'; tion Of Infraction (79-13-01) 10 CFR 50 Appendix B, Criteria III, states, in part, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."

The Beaver Valley FSAR, Appendix A, Quality Assurance Program, Paragraph A.2.2.3 Design Control states, in.part, that: "The design control measures applied to design changes includes provisions for the selection and review for suitability of the application of materials, parts / equipment, and processes that are essential to the safety related functions of structures, systems, and components."

Beaver Valley Quality Assurance Procedure No. OP-4, Revision 5, Stations Design Control, Paragraph 4.3.4 states, in part, that: "A design concept is developed by the design group as part of the planning process. This concept provides the framework within which the design change is implemented, and includes as a minimum.. . . (5) an index of required design and installation documents and procurement specifications."

Contrary to the above, on November 9, 1978, Engineering Memorandum No. 20121 was approved, authorizing installation of a temporary local monitoring circuit in the Emergency Diesel Generator control panels for the purpose of monitoring relay operation. The type of material and method of mounting this component within the s.ibject panel was not specified, evaluated, or documented by appropriate engineering personnel nor were installation document and material specifications prepared.

Discussion Of Infractjon The installation of the temporary local monitoring circuit was reviewed and authorized by the Onsite Safety Committee (OSC). Since this is not a permanent change, an in-derth review, as required for permanent design changes, is not necessary.

Corrective Action The temporary test circuit was re-mounted on fire-proof material and the installation was supervised and reviewed for secure mounting by the assigned engineer.

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Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-13 Page 2 4: tion Taken To Prevent Recurrence Temporary test installations required to provide information necessary for engineering evaluation, design verification, troubleshooting or similar purposes will be mare closely reviewed by the OSC to assure adequate evaluation and engineering review prior to installation.

Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.

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