ML19324B785
| ML19324B785 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/30/1989 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911080219 | |
| Download: ML19324B785 (4) | |
Text
f'l
(,.
p -.
- f.
['. '
M @ M fg** g j "*v % 'S*"
o, f-sn.pp.ngwt. a n,on. coo 4 f,
r s
. w c,M 1412 643 62 %
i October 30, 1989 c
.U.
S.
Nuclear Regulatory Commission L
Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66
,H BV-2 Docket No. 50-412, License No. NPF-73 Combined Inspection Report 50-334/89-13 and 50-412/89-14 Gentlemen:
In response to NRC correspondence dated September 29, 1989 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation included with the referenced inspection report.
If-there are any questions concerning this response, please contact my office.
Very truly yours,
(
D. Sieber ice President Muclear Group Attachment
.l cc:-
Mr. J.
Beall, Sr. Resident Inspector Mr. W. T. Russel.L, NRC Region I Administrator l
Mr. Edward C. Wenzinger, Chief Reactor Projects Branch No.
4, 1
Division Jf Reactor Projects, Region I Mr. R. Saunders (VEPCO) 1 0911080219 891030
[]
M l
DR ADOCK 050 34 r
i
- , x L
DUQUESNE LIGHT COMPANY i
Nuclear Group Beaver Valley Power Station Units 1 and 2 Reolv to Notice of Violation Combined Inspection Report 50-334/89-13 and 50-412/89-14 Letter Dated September 29, 1989 VIOLATION (Severity Level IV, Supplement I)
Descriotion of Vio?ation (50-334/89-13-01; 50-412/89-14-01) 10 CFR Part 50, Appendix B,
Criterion XII requires that meaF.ures shall be established to assure that tools, gauges, instruments, and i
other measuring end testing devices used in activities affecting quality are properly controlled.
.Section 2
of the Instrument and Control Administrative Manual.
Control and Calibrations of Measuring and Test equipment, wh,
requires that past _due devices be marked and segregated fi calibrated devices, and that the Daily Use and Issue Log be complete each day for instruments in use imploments this requirement.
Contrary to the above, the following two examples represent licensee failures to properly control
- tools, gauges, instruments and other measuring and test devices used in activities affecting quality.
(1) Approximately 90 measuring and test devices were past due for calibration and were not properly marked and segregated from calibrated measuring and test devices as required by procedure (Section 2
of the Instrument and Control
- Manual,Section VI.F.12).
(2) Multiple examples (about 100) of the failure to properly use the Daily Use and Issue Log as required by procedure (Section 2 of the Instrument and Control
- Manual,Section VI.F.)
wcre ident3fied.
E.esconse to Violation Pgrt 1:
Immediate Corrective Action All equipment identified as past due has been cross-checked or recalibrated and safety reviews were performed for all out-of-calibration situations.
Unusable gauges have been identified and segregated from calibrated gaugss.
W'
- Reolv to Notice of Violation Page 2 Response to Violation Part 1 (Continued)
We performed a review of Measuring and Test Equipment (M&TE) history logs in order to identify the existence of any additional uses of past due M&TE being signed out for Category I work.
None were found.
In the event M&TE was used in Category I work and that usage was not recorded in the H&TE usage logs, a sampling of Category I Maintenance Work Requests (MWRs) written from January 1988 to September 1989 were reviewed.
For Unit 2, all Category I work was logged properly on the M&TE logs.
Unit 1 had three (3) instances which amounted to one (1) percent of the MWRs reviewed.
The logs for these three instances were updated during the review and the corresponding safety reviews were performed.
In order to facilitate issue and return at the M&TE issue areas, an automated on-line M&TE tracking systqm has been placed into service.
Action to Prevent Recurrence 1.
In ' order to improve accountability of the M&TE program, the issue areas will be reorganized according to their functional usage.
2.
Since compliance with this program ultimately depends upon the M&TE
- user, after they have been issued M&TE, aupervisors have been instructed to monitor their work with specific attention to the M&TE requirements.
3.
Plant supervision and QA have discussed this issue with site users of M&TE at departmental meetings.
4.
The concept of M&TE tracking specific program requirements has been added tc General Employee Refresher Training (GERT).
Date When Full Compliance Will Be Completed Immediate corrective actions and actions to prevent recurrence have been completed with the exception of reorganizing the M&TE issue areas according to their functional usage.
This will be completed by December 29, 1989.
Resoonse to Violation Part 2:
Ima?diate Corrective Action A
complete history of the Mechanical Maintenance M&TE issue area was performed which included a
review of the last use of each piece of M&TE identified in the audit.
I&C recalibrated each item found to be past due for calibration and initiated safety reviews for these iters.
In no case was any Category I work actually performed with any M&TE past-due for calibration, r
[
tw-R2 ponno to Nativo of Vicicticn l.*
.Page 3 Action to Prevent Recurrence 1.
Supervision has discussed the requirements of the Site M&TE Program at their departmental meetings.
2.
.[n order to improve accountability of the site M&TE Program, the issue areas will be reorganized according to their functional usage.
Date When Full Comoliance Will Be Achieved Immediate corrective actions and actions to prevent recurrence have been completed with the exception of reorganizing the M&TE issue areas according to their functional usage.
This will be completed by December 29, 1989.
6 k
i
' \\.
. - - - - -