ML19305B867
| ML19305B867 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/19/1979 |
| From: | Beckman D, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19305B856 | List: |
| References | |
| 50-334-79-21, NUDOCS 8003200505 | |
| Download: ML19305B867 (6) | |
See also: IR 05000334/1979021
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
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Report No. 50-334/79-21
Docket No. 50-334
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License No. DPR-66
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Category
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Licensee: Duquesne Light Company
435 Sixth Avenue
Pittsburgh, Pennsylvania 15219
Facility Name.:
Beaver Valley Power Station, Unit 1
Meeting at:
USNRC, Region I, King of Prussia, Pennsylvania
Meeting conducted:
September 25, 1979
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Inspector:
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(T. Ag'Bei:kmaQeactor Inspector
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date signed
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Approved by:
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R. R. Keimig, Chief, Reactor Projects
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Section No. 1, RO&NS Branch
Meeting Summary:
Enforcement Conference on September 25, 1979 (Report No. 50-334/79-21)
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Summary: Special enforcement conference convened by Region I management to discuss
NRC concerns regarding licensee implementation of the design control program, the
effectiveness of licensee management controls, and the facility's recent enforcement
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history. The meeting was attended by senior licensee and Region I management and
involved 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in the Region I office by all attendees.
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a.
-Region I Form 12-1
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(R v. August 77)
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DETAILS
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Attendees
Duquesne Light Company
J. Carey, Technical Assistant - Nuclear
C. Dunn, Vice President, Operations Division
G. Moore, General Superintendent, Power Stations Department
R. Swiderski, Superintendent of Construction, BVPS
H. Van Wassen, Project Manager, BVPS
R. Washabaugh, Manager of Quality Assurance
J. Werling, Superintendent, BVPS
E. Woolever, Vice President, Engineering and Construction Division
U. S. Nuclear Regulatory Commission
B. Grier, Director, Region I
J. Allan, Deputy Director, Region I
D. Beckman, Reactor Inspector, Reactor Operations and Nuclear Support
Branch, Region I
E. Brunner, Chief, Reactor Operations and Nuclear Support Branch,
Region I
R. Keimig, Chief, Reactor Projects Section No. 1, Reactor Operations
and Nuclear Support Branch, Region I
H. Kister, Chief, Nuclear Support Section No. 2, Reactor Operations
and Nuclear Support Branch, Region I
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Meeting Summary
Opening remarks made by regional management summarized the concerns
further described below and included a discussion of the need to
communicate these concerns directly to the senior licensee management
present. The purpose of the meeting was characterized as preventive
enforcement based on the results of recent inspections, NRC review of
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licensee communications, and the facility's recent enforcement history.
The goal of the meeting was stated to be the projection of NRC concerns
to licensee management to permit additional licensee attention to be
focused on the concerns.
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a.
Design Control Program
NRC:RI inspection experiences with the licensee's program for the
control of design changes and modifications were discussed on the
basis of the previous eighteen months of inspection. A brief
history of NRC inspection findings and observations was presented
to the licensee. This history emphasized the apparent difficulty
experienced by the licensee in implementing the design control
program and associated corrective actions and c.mitments which
have resulted from NRC inspections and Duquesne Light Company
internal quality assurance audits between March 1978 and the
present.
The licensee's design control program activities were
most recently inspected during August 1979 (IE Inspection Report
No. 50-334/79-18) during which NRC:RI identified several items of
noncompliance and incomplete commitments. As a result of these
inspection findings, the licensee's meeting representatives were
informed of the NRC's concern for the need for improvement in the
conduct of plant design changes and modifications within the
provisions of the facility's operating license.
These concerns included:
The need to evaluate completed design change packages which
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were not accomplished in accordance with design control
program requirements to ensure that safety related issues
were adequately addressed;
The need to promptly update design documents affected by
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previously accomplished design changes to reflect the as-
built condition of the plant;
The need to complete organization and program changes to
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ensure adequate support of future design change engineering
and implementation, particularly with regard to those activities
scheduled for performance during the November 1979 outage;
The need to ensure that design change activities are conducted
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by designated and trained personnel only; and,
The need to better administer commitments made to NRC in
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writing in respon:;e to previous NRC inspection findings.
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The licensee was informed that, as part of the correspondence
with IE Inspection No. 50-334/79-18, NRC:RI will request Duquesne
Light Company to make specific comitments for improvements in
the management of the design control program to provide assurance
that previously completed design change work presents no reduction
in plant safety and that design changes to be implemented during
the upcoming outage will be perfonned in accordance with the
requirements of the facility's operating license.
The licensee acknowledged the above stated concerns and provided
the following comments in response:
that an effort is currently
underway to review and update drawings affected by previously
implemented design changes to ensure that a firm data base is
available for future design changes; that for the upcoming outage,
all design change activities will be conducted by the Engineering
and Construction Division (E&CD) in accordance with the latest of
the Engineering Management Procedures; that no design change work
will be accomplished by station personnel; that new workforce of
E&CD personnel has been established at the station as an extension
of the corporate office engineering staff thus eliminating the
need for involvement of station engineering personnel in design
change engineering; that manning of this organization is currently
underway and will be supplemented by engineers provided by the
licensee's architect-engineer during the outage; and that this
onsite engineering group will function to coordinate field activities
with the corporate office and will provide expeditious field
support for outage activities.
The licensee and Region I attendees also discussed recently
completed design control program training for engineering personnel,
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licensee plans for quality assurance audits and surveillances of
outage design control ac?.ivities and, avoidance of previously
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experienced difficulties with regard to station perfonned design
change engineering.
The licensee was responsive to the NRC
comments and indicated that the problems discussed are being
actively pursued with the direct attention of senior corporate
management.
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Management Controls and Enforcement History
As a result of NRC:RI experience with the licensee's programs
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concerning recent technical issues, correspondence associated
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with IE Bulletins and infonnation requests, and observations or
findings made during inspections, the meeting discussion included
the efficacy of the licensee's management and administrative
controls.
The following areas of concern were presented by
Region I and discussed with the licensee.
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Additional emphasis appears necessary to ensure that management
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is available to provide the necessary focus for resolution
of technical and regulatory matters identified internally or
by the NRC.
Comunications with licensee plant and corporate
personnel appear to have suffered a loss of effectiveness
during the recent past.
Additional management attention
appears to be necessary early in the development of safety
issues or technical problems to assure responsiveness and
prompt resolution to prelude unnecessary and additional
iteration and manpower expenditure.
NRC:RI acknowledged the
extraordinarily high management and engineering burdens
placed upon the licensee through the last year by major
issues but expressed the need to effectively address safety
issues under all circumstances.
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Recent NRC experience with licensee submittals has indicated
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a need for improvement in document completeness and depth of
detailed engineering evaluation.
In some recent cases,
increased NRC attention has been required to obtain the
information necessary for NRC evaluation.
Examples include
IE Bulletin responses, licensee correspondence on technical
matters or safety issues, and licensee exceptions to generic
NRC positions.
Recent inspection experience has resulted in concerns regarding
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the licensee's administration of commitments made to the NRC
and control of licensee internal commitments which are
necessary to support licensed activities.
These concerns
include the need for additional management emphasis on the
tracking of commitment status, escalation of identified
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problems to appropriate levels of management, review of
comitment actions for completeness and adequacy prior to
presentation to NRC, and timeliness of completion for committed
actions.
Recent NRC experience also indicates that additional
coordination appears necessary between the various DLC
divisions and departments which must interface to implement
commitment actions.
NRC:RI inspections and observations of the licensee's
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implementation of programs required by license conditions
have indicated that marginally acceptable progress has been
made in several key programs such as in-service testing of
pumps and valves,10 CFR 50 Appendix J Leak Rate Testing,
snubber and pipe support surveillance, and emergency planning.
Program inspections in these and other similar areas have
been essentially preventive in nature with numerous findings
which address the need for program improvement or refinement.
The apparent difficulties observed include a need to more
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effectively address these inspection findings, a need for
improvement in developing priorities and tracking of identified
program problems or weaknesses, and a need to escalate
identified problems to appropriate levels of management to
assist in resolution.
During the past year, the plant has experienced periods of
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extended shutdown.
During that time, NRC observations and
findings appear to indicate a trend toward relaxation of
plant operating personnel adherence to administrative con-
trols as evidenced by an increasing latitude observed in
procedure interpretation and adherence.
Recent inspections
have identified noncompliances which have had the potential
to result in actual occurrences.
In several cases, the
licensee's quality assurance program provided a possible
mechanism for permitting the identified deviations of pro-
cedure based on the performance of appropriate evaluations
but no such option was exercised.
The general trend of the past several years' NRC enforcement
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history appears to indicate a continuing problem with the
successful implementation of administrative controls and
technical programs.
Additionally, the number of inspection
findings (unresolved items) which are cited as noncompliance
has not decreased.
These items do not appear to be receiving
the attention necessary to adequately resolve them before
they constitute noncompliance and thus, result in a greater
potential for continuing, future noncompliance.
The licensee representatives acknowledged the above comments and
stated that the matters would be taken under serious advisement.
The licensee further acknowledged that the past year's plant
experience has severely impacted their available resources and is
atypical of normal industry experience.
NRC:RI informed the
licensee that the matters discussed above would be presented in
a report of the meeting and would be accompanied by a request for
licensee comments and commitments for improvements in the respective
areas.
In closing, the licensee stated an intention to improve perform-
ance in the areas discussed above.
While considering their past
performance to be adequate with respect to meeting the conditions
of their NRC facility license, the licensee stated that improve-
ment in all areas will be made.
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