ML20004E685
| ML20004E685 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/06/1981 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20004E683 | List: |
| References | |
| NUDOCS 8106150046 | |
| Download: ML20004E685 (3) | |
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February 6, 1981 ge. p..
United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Boyce H. Grier, Regional 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 80-u5 Document Ref:
(a) NRC (Brunner) letter, dated March 25, 1980 (b) DLC (Dunn) letter, dated April 17, 1980 (c) h1C (Blumberg) - DLC (Werling) telephone conversation on June 11, 1980 (d) NRC (Brunner) letter, dated August 11, 1980 (e) DLC (Dunn) letter, dated January 12, 1981 (f) NRC (Grier) letter, dated January 29, 1981 Gentlemen:
This supplemental response is being forwarden at the request of the Senior Resident Inspector and addresses NRC's stated concern related to management controls which permitted corrective action related to one item in Inspection 80-05 to require more time to complete than was originally committed.
Ref. (b) indicated the corrective actions taken or planned concerning the items of noncompliance identified in the subject inspection report forwarded by Ref. (a).
Ref. (d) listed additional corrective actions which the station agreed to undertake as a result of the telephone conversation noted as Ref. (c).
One of these additional commitments was to establish a " log room" to assure the use of current procedures by December 31, 1980.
As discussed in Ref. (e), this original date could not be met.
Following the commitment of Ref. (c), the Station Superin-tendent directed Stone and Webster Engineering Corporation to study the requirements for a satisfactory " log room" and to make recom=endations to implement this commitment.
This study was completed in December, 1980 and recommended a scope of work involving significant expenditures for new equipment which involved long lead times for delivery.
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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 IE Inspection 80-05 Page 2 Station management currently uses a computerized commitment tracking system in which input is based primarily on written documents received or sent by the Station Staff. ' For the commitment in question, the commitment was made in a telephone conversation which took place approximately two months following the submittal of our initial audit response. Written documentation of this commitment appeared two months after the telephone call and six months af ter the inspection, in a letter which was sent to acknowledge our initial written response.
In this case, our normal computerized tracking system appears to have been bypassed because:
(1) the commitment only appears in correspondence not normally utilized to denote new actions, and (2) the time delay involved and the brevity of the written commitment in Ref. (d) made it unclear to those reviewing the correspondence as to what exactly had been committed and that it was a new action not previously entered in the commiment tracking system.
It should be noted that the commitment was not totally overlooked in that initial work efforts had been underway for some time and on December 23, 1980, verbal notification was given to our Resident Inspector that the " log room" concept would not be implemented by the December 31 target date and that a letter providing current status and a new completion date would be forthcoming. This information was subsequently provided in Ref. (e). We feel that the NRC was kept sufficiently informed in this instance and do not consider this item to be a " missed commitment" by virtue of the verbal noti-fication given.
To date, our present tracking method has been effective as a management tool. All management personnel authorized to make commitments have been instructed to ensure tat these commitments are promptly entered into the tracking system. We believe that because of the unusual circumstances involved in this instance and recognizing the experience gained as a result of this incident, no further action regarding management controls is needed at this time.
Concerning actionsito prevent recurrence of the original audit findings, measures other than the " log room" have been implemented to date.
Responsi-bility for control over the issuance of maintenance procedures has been delegated to the Procedures Group. When a maintenance procedure is needed, the Procedures Group checks the most recent issue in the master file and reviews it to make sure there have been no later revisions and that no changes are needed.
Sufficient work copies are then made from the master copy and are properly stamped and dated for use.
Beaver Valley Power Station, Unit No.1 Docket No. 50-334, 14:ense No. DPR-66 IE Inspection 80-05 Page 3 A similar situation exists for the operating procedures. A controlled copy fer operating procedures is kept in the control room and a copy is made from the most recent issue in the controlled copy file when needed by operations personnel. While it appears that these measures have been pro-viding adequate control for the past 4-6 months, additional measures are still being considered by the Station to enhance the control of procedure issuance and use.
The " log room" concept is under review at this time as items under consideration involve the procuring of additional materials and equipment at considerable expense and/or extensive lead times for procurement.
However, while the " log room" concept is being reviewed to determine the feasibility of its implementation, we believe sufficient controls over procedure issuance and use exist at this time to prevent recurrence of the incident.
Should you have any additional questions concerning this item, do not hesitate to contact me or my staff.
Very truly yours, d 'kf dhke tt - -
C. N. Dunn Vice President, Operations cc:
U.S. Nuclear Regulatory Connission c/o Document Management Branch Washington, DC 20555 Mr. D. A. Beckman, Resident Inspector U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shipping 3 ort, PA 15077
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