ML20009D111
| ML20009D111 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/02/1981 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20009D110 | List: |
| References | |
| 50-334-81-03, 50-334-81-3, NUDOCS 8107230158 | |
| Download: ML20009D111 (3) | |
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Appendix A
. Notice of Violation Duquesne Light Company Docket No. 50-334 Beaver Valley Power Station, Unit No. 1 License No..DPR-66 t-As a result of 'an inspection conducted ca February 2-6 and 18-20,1981 and in accordance _with the Interim Enforcement Pelicy, 45 FR 56754 (October 7,1980),
it was-identified in the following three areas _that corrective actions and management controls.to ensure proper corrective actions concerqing a previously sidentified notice of violation were inadequate;-and that Technical Specification administrative controls.were not followed. The following items are separate examples which are considered ccllectively to be a single violation:
10 CFR 50, Appendix B, Criterion XVI, states, in part, "Maasures sqall be established to assure that conditions adverse to quality, such as... deficiencies,
- deviations... and nonconformances are promptly identified and corrected...
The measures shall assure that the cause of the condition is determined and corrective action taken to' preclude repetition... the cause of the condition, and.the corrective act'on shall be documented and reported to the appropriate levels of management."
' Contrary to-the above, management controls to ensure corrective action and the corrective action taken far a previously identified item of noncompliance was
-inadequate in that the following item of noncompliance identified in our letter dated March 25, 1980 (NRC Inspection 50-334/80-05 conducted February 4-8 and 11-13, 1980) still existed:
(1)- Calibrations of seismic monitoring and meteorological monitoring instrumentation as required by Appendix A of the Technical Specifi-cations were being accomplished by a vendor using a procedure estab-lished by the_ vendor which had not been reviewed or approved by your staff.
-(2) Procedures fcv-the above calibra:fons previously established and approved by your staff were not being implemented.
(3) Records of -these calibrations were not being maintained by your staff as required by the Technical Specifications.
Continued inadequate corrective action is evidenced by noncompliance in the following areas:
O O
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- Appendix A-2 a.-
< Technical Specifications 6.8.1, 6.8.2 and 6.8.3 state, in part
" Written' procedures shall be established, implemented and maintained covering... the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33... Each procedure...
and changes thereto, shall be revinwed by the OSC and approved by the. plant superintendent prior to implementation... Temporary
- changes to procedures... may be made provided... the intent of the origtaal-procedure is not altered...
and the change is documented, reviewed by the OSC and approved by-the plant superintendent within 7 days of implementation."
Regulatory Guide 1.33, November 1972, Appendix "A" Paragraph H.2, states, in part, that implementing procedures are required for each calibration listed in Technical Specifications.
Contrary to the above,.for the procedure used for tests per-formed on July-12,-1980; Novenl. a 1,1980; and February 5, 1981, no documentation existed that this procedure had been approved by the' plant superintendent.
Note: It was documented Lthat the Onsite Safety Committee (OSC).at meeting BV-0SC-71-80 z
held June 12, 1980, reviewed and recommended for approval by theLplant superintendent, the NUS (vendor) Procedure 1539, Volume 2, Part 1, Section 4.0, Revision 2, draft " Beaver Valley Meteorological Monitoring System Maintenance and Calibration Procedure."
Further, changes made to the vendor procedure data sheets, and apparently to the procedure, for tests performed November 1, 1980 and February 5,1981, had not been reviewed by the OSC nor approved by the plant superintendent; and a copy of this revised procedure war,not being maintained on site.
Additionally, Duquesne Light Letter, BV?S:RLH:15, dated June 16, 1980, authorized NUS Corporatica to make minor "non-intent" revisions'to this procedure without obtaining station approval, which is not in conformance with Technical Specification 6.8.3.
I b.
Technical Specification 6.10.1.d states, in part, " Records of
... calibrations required by these Technical Specific:tions fshall be retained at least five years /."
Contrary to the above, for the tests completed July 12, 1980; November 1, 1980; and February 5, 1981, procedure data sheet appendices provided to your staff by NUS Corporation for infor-mation and record purposes were incomplete, omitting the recording of data entries-required by the procedure data sheet appendices.
Additionally, copies of the data recorded in the main body of the procedure were not provided to your staff.
.This is a severity level VI violation (Supplement I).
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Appendix A 3
Pursuant to the provisions of 10 CFR 2.201, Duquesne Light Company is hereby required to submit to this office, within thirty days of the date of this notice, a written statement or explanation in reply, including:
(1) admission or denial of the alleged violations; (2) the corrective steps which have been taken and the results achieved; (3) corrective steps which will be taken tu dvoid further violations; and (4) the date when full compliance will be achieveu.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amendec,
' this response shall be submitted under oath or affinnation. Where good cause is shown, consideration will be given to extending your response time. The responses diret.t.ed by this Notice are not subject to the clearance procedures of the Office of Management and Budget as required t.- the Paperwork Reduction Act of 1980, PL 96-511.
W 0 2 1981
- p)fb hp Date homas T. Martin', Chief Engineering Inspection Branch s
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