ML19294B359

Responds to NRC 791123 Ltr Re Violations Noted in IE Insp Rept 50-334/79-18.Corrective Actions:Updating Station Drawings W/Design Changes & Class a Fire Door Ordered to Replace Door in QA Records Room

ML19294B359
Person / Time
Site:	Beaver Valley
Issue date:	12/19/1979
From:	Dunn C DUQUESNE LIGHT CO.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19294B352	List: ML19294B359
References
NUDOCS 8002280241
Download: ML19294B359 (7)

Text

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'Af (412) 456-6000 435 Sixth Avenue Pittsburgh, Pennsylvania 152n December 19, 1979 United States Nucle . Regulatory Commission Attention: Mr. Boyce H. Grier, Director Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Reference:

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 IE Inspection No. 79-18

Dear Mr. Gricr:

In response to your letter of November 23, 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 violations were failures to provide the following:

a) A written safety analysis for the OSC determinations regarding DC 0223 and DC0233 b) Drawings that reflect As Built conditions described in respective design changes c) An updated procedure to reflect installation of a new safety related hydraulic snubber (SI-HS-529) d) A procedure regarding a field change to the charging pump modification e) Compliance with ANSI N45.2.9 requirements for the storage of single copy records.

We have reviewed the referenced audit report for 10 CFR 2.790 information and none were identified.

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

Very truly yours,

' ( N ... -

C. Dunn Vice President, Operations Attachment 8 0 0 2 2 8 07H

DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-18 Letter Dated November 2.' . 1979 Description Of Infraction (79-18-04) h- 10 CFR 50.59 Paragraph (b) states in part, "The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that such changes constitute changes in the facility as described in the safety analysis report....These records shall include a written safety evaluation which provides the basis for the determination that the change. . .

does not involve an unreviewed safety question."

Maintenance Manual Chapter 1, Section P, Control of Design Changas, Revision 1, states in part, "9. SAFETY ANALYSIS a. The OSC shall perform a safety analysis of the design change... .This safety analysis shall provide the basis for the determinations that the change does not involve an unreviewed safety question.

Contrary to the above, there was no written safety analysis / evaluation contained in OSC minutes 51-4 and 55-5 to provide the basis for the OSC determinations regarding DC 0223, Generator Manual Field Flash and the associated test provedure, and DC 0233, Safety Inspection line hangers.

Corrective Action The OSC has been made aware of the condition and a more detailed documentation of the safety analysis using the basis for this determination will be provided in the OSC minutes.

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Action Taken To Prevent Recurrence No further action is required.

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

Description Of Infraction (79-18-05)

O 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program states in part, "This Program shall 12 documented by written policies, procedures or instructions and shall be carried out throughout plant life in accordance with those policies, procedures or instructions...."

OP-4, Station Design Control, Revision 5, Paragraph 4.6.2 states in part

"....when preoperational testing is complete and test results are approved, the Station Superintendent shall update the station files with the As Built drawings..."

Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-18 Page 2 Description Of Infraction (79-18-05) (continued)

Contrary to the above, as of August 24, 1979, the following drawings which are maintained in the station files do not reflect the As Built condition as described in the respective design changes.

DCP No. Drawing No.

0251 8700-RE-21PQ 8700-RE-21SD 8700-RE-4AM 0223 8700-RE-14B 8700-RE-3BF 8700-RE-3BD 8700-RE-14A 0971 8700-RE-25W 8700-RE-3FS 8700-RE-3CW 8700-RE-3CX Corrective Action Beaver Valley Power Station is presently updating station drawings that have been affected by design changes. This is in the form of field marking prints since Beaver Valley Power Station does not have the capability of changing sepias. This update will be completed on the safety related design changes that ara covered under the QA Progran.

Action Taken To Prevent Recurrence Station Engineering procedures have been revised and are presently in the approval stage with expected approval by January 15, 1980. These revised procedures will better define the actions that station engineering personnel will take to update station drawings at the completion of design changes.

Date On Which Full Compliance Will Be Achieved All drawings will be field updated by January 31, 1980.

Description Of Infraction (79-18-06) 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances..."

Maintenance Manual, Chapter 1, Conduct of Maintenance, Section P, Control of Design Changes, Revision 1, Section 14.b states in part, "The senior engineer shall be responsible for updating or having updated station files and procedures."

' Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-18 Page 3 Description Of Infraction (79-18-06) (continued)

Contrary to the above, as of August 24, 1979, ISI Procedure 5.0, Reactor Coolant System Hydraulic Pipe Support Examination, Revision 2, had not been updated to reflect the installation of a new safety related hydraulic snubber (SI-HS-529) nor had the licensee submitted the required Technical Specification change to NRC requesting addition of the hydraulic snubber to Table 3.7.4.

Corrective Action A Technical Specification Change Request has been initiated to update Table 3.7.4.

NSQC's ISI Procedure is being revised to incorporate the snubber into the program.

Action Taken To Prevent Recurrence Station Engineering personnel have been instructed that when a design change is presented to the Onsite Safety Committee for approval, the Technical Specification block must be reviewed carefully.

Date On Which Full Compliance Will Be Achieved Procedure revisions will be completed by January 31, 1980.

Description Of Infraction (79-18-07)

, 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality

\) shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings...."

QA Procedure OP-1, Operations Quality Assurance Program, paragraph 1.1.9, states in part, "Each organization is responsible for identifying the activities affecting quality and assuring that such activities are adequately prescribed by appropriate procedures . . ."

Contrary to the above, no procedure existed which required the on site engineering group to forward information regarding a field change to the charging pump modification to the responsible engineering group for review. As a result the field change was accomplished and the plant returned to power operation without the required seismic re-analysis being accomplished. ,

Corrective Action This problem arose from the station engineer's interpretation of " design change" as explained in the Station Engineering Procedures. After consultation with the pump vendor who considered the practice of enlarging the bolt holes normal, the engineer determined a design change was not involved. All engineers have been instructed as to what constitutes a design change and that careful consideration be taken of subtle changes.

' Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-18 Page 4 Action Taken To Prevent Recurrence No additional corrective action is necessary.

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

With regard to the deviation noted in the inspection report, corrective actions indicated will be completed by January 15, 1980 for procedures and January 31, 1980 for drawing update. With respect to the failure to meet commitment, the Duquesne Light Company response to your Inspection No. 79-21 provides management controls that are being implemented to correct the problems in this area.

Description Of Infraction (79-18-10) - Part I k

10 CFR 50, Appendix B, Criterion XVII, states that the requirements for records retention shall be specified. The FSAR states that provisions include a permanent on-site records storage facility complying with the applicable requirements, records preservation, records protection and facility access control. Further,

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the FSAR commits to Regulatory Guide 1.88 which endorses ANSI N45.2.9.

ANSI N45.2.9 states that records shall be firmly attached in binders for storage on shelving in containers and specifies physical requirements for a permanent records storage facility.

Contrary to the above, with regard to the QA Records Room, the coor was determined not to be Class A fire rated and it also was determined that ventilation is inadequate.

Failure to comply with the records storage requirements as specified above constitutes an item of noncompliance at the deficiency level (334/79-18-10).

Corrective Action A Class A fire rated door has been ordered to replace the present door in the QA records room. The existing door will be replaced by April 30, 1980.

The QA records room is a temporary storage area for the QA records. The time the records are stored there is very limited and short term only from transmittal from the station until microfilming, which is not more than six months. The features that ANSI N45.2.9 suggest should be considered in its construction have been considered and it has been determined that the QA records room meets these requirements for protecting the records from destruction.

' Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-18 Page 5 Corrective Action (continued)

A Hygrothermograph has also been ordered to record the temperature and humidity in the room to further protect these records. Therefore, at this time, it is felt that the ventilation and filter system in the building is adequate for the records room.

The Hygrothermograph which will be used to record the temperature and humidity in the QA records room will be placed in the room by April 30, 1980.

Action Taken To Prevent Recurrence Once the above requirements have been completed, the QA records room will be in compliance with the requirements of ANSI N45.2.9.

Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by April 30, 1980.

Description Of Infraction (79-18-10) - Part II 10 CFR 50, Appendix B, Criterion XVII, states in part, " Consistent with applicable regulatory requirements,...shall establish requirements concerning record retentions, such as duration, and assigned responsibility..."

FSAR, Appendix A, Section A.2.2.17, states in part, " Provisions include on-site facility for permanent records retention, including steps taken to assure preservation, protection, controlled access and'all other applicable requirements." Further, Attachment to A.2 (FSAR, Appendix A, Section A.2) states in part, "The Duquesne Light Company Operations Quality Assurance Program follows the guidance of Regulatory Guide 1.88. . ." Regulatory Guide 1.88 endorses ANSI N45.2.9.

ANSI N45.2.9, Paragraph 5.4, states in part, " Provisions shall be made in the storage arrangement to prevent damage from condensation... Records shall not be stored loosely. They shall be firmly attached in binders... folders... envelopes for storage on shelving in containers..." Further, Paragraph 5.6 describes minimum physical storage requirements.

Contrary to the above, as of August 24, 1979, the following are identified examples of noncompliance with the ANSI N45.2.9 requirements for the storage of single copy records.

Corrective Action In November, 1979, the records in the Station Document Storage Room were relocated to the QA Records Room in the new office building.

Quality Assurance records will be properly stored in accordance with ANSI N45.2.9 in the QA Records Room.

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'Beave'r Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-18 Page 6 Corrective Action (continued)

The QA kecords Room has been provided with a three (3) hour rated fire door, adequate ventilation and a fire protection system.

The QA Records Room does not include floor drains nor wall sealant. However, the facility is located within a building, the e"vironment and construction of this building provide these criteria based on Engineering Memorandum No. 20197.

Action Taken To Prevent Recurrence Equipment will be provided to properly store records. The Document Control clerk shall again read the applicable Office Administration Procedure, and periodic inspection of the QA Records Room shall be performed.

Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by January 31, 1980.