ML20010A567
| ML20010A567 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/27/1981 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20010A560 | List: |
| References | |
| NUDOCS 8108110549 | |
| Download: ML20010A567 (6) | |
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DuquesneU@t EM, U*.a" July 27, 1981 mi United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Boyce 11. Grier, Regional Director Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket Na. 50-334, License No. DPR-66 l
IE Inspection Report No. 81-02 Gentlemen:
In response to your letter of July 1, 1981, and in accordance with 10CFR 2.201, the attached replies address the Notices of Violation which were included as Appendicies A and B with the referenced Inspection Report.
In addition to the need for corrective action regarding specific items of noncompliance, your letter expressed concern about the implementation of our managemen: control syscems that permitted them to occur. This will be discussed in the attached appendicies following the replies to the violations.
Since the Reply to Notice of Violation, Appendix B, contains information 4
subject to Section 2.790 (d), Title 10, Code of Federal Eegulations and is, therefore exempt from disclosure, it is my understanding that this portion of this 81-02 response will not be placed in the Public Document Room and
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will receive limited distribution.
If you have any questions concerning this response, please contact my office.
Very truly yours,
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J. J. Carey i
Vice President, Nuclear Attachments: Reply to Notice of Violation,. Appendix A j
Reply to Notice of Violation, Appendix B cc:
'fr. D. A. Beckman U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 8108110549 810804 '
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CO.'4MONWEALTH OF PENNSYLVANIA) 1SS:
COUNTY OF BEAVER On thi
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, before me,[4/ //J,s / rr ~ -, a Notary Pubfic in and for said Commonwealth n
and' County, personally appeared J. J. Carey, who being duiy sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his kncwledge, information and belief.
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g, JUDITH D. ANTHONY, Notory Public ShipD;Mpert Borough, Beaver Co., Pa.
My Cownmion bpires Dec. 12, 4583 1
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Reply to Notice of Violation Appendix A Inspection No. 81-02 Letter dated July 1, 1981 VIOLATION A (Severity Level IV; Supplement I)
Description of Violation (81-02-04) 10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as...
deficiencies, deviations... and nonconformances are promp'.ly identified and corrected...." Quality Assurance Procedure No. OP-13, Control of Non-conforming Itema, nevision 4, Section 13.3.1, states, in part, "A corrective action system shall be established to assure that significant conditions adverse to quality are promptly identified and corrected. The corrective action system shall provide fcr determining that the specified corrective measures have been impicmented...."
Contrary to the above, on January 6, 1981, the established corrective action system did not assure that a condition adverse to quality was corrected and measures for determining that specified corrective measures have been implemented were not effective in that:
Licensee inspections and evaluations had determined that existing Main Steam Line pipe supports H-162, H-164, and H-166 deviated from original design and construction requirements for the size of the supports' shim stacks. This condition was identified on about July 31, 1980.
Instructions for correction of the candition were issued on about August 12, 1980 as part of Design Change Package No. 305. Due to deficiencies in document err *smittal procedurec and practices, the '
v modifications required to correct the condition were not accomplished prior to taejlity power operation on November 22, 1980.
Existing procedures and prectices for conf lrmation of corrective action completion. did not identiry the incomplete action.
Identification of the incomplete corrective action was made during a document review subsequent to licensee completion and signoff of modification activities (Design Change Package No. 305) which should have but did not include completed modification of the subject supports.
Corrective Action Taken The documents which had not been transmitted to field construction forces relating to the modification of supports H-162, H-164, and H-166 were trans-mitted to construccion forces at the site for the preparation of a Work Package for installation.
In addition, notification of the noncompliance was provided *y the Duquesne Light Corpany Engineering Department to the Beaver Valley Power Station Superintendent who subsequently notified the Nuclear Regulatory Commission of the existence of the nonconformance (see Violation B).
Appropriate changes to supports H-162, H-164, and H-166 were installed on January 7, 1981 in accordance with the design documents.
s' Reply to Notice of Violation Apgendix A Inspection No. 81-07 Letter dated July 1, l?81 VIOLATION A (Severity Level IV; Supplement I)
Action Taken To Prevent Recurrence Transmittal procedures and practices were modified to clearly identify the individual responsible for examining document receipt acknowledgement forms to verify the documents transmitted to the field have been properly received and acknowledged.
In addition, turnover procedures will be revised to provide that Duquesne Light Company Construction shall compare the Design Output List of issued documents against documents in the Work Packages to assure that the modification was built as designeJ.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by August 31, 1981.
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Reply to Notice of Violation Appesdix A Inspection No. 81-02 VIOLATION B (Severity Level IV; Supplement 1)
Description of Violation (81-02-05)
I 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
These measures shall include, as appropriate, procedures for identification, documentation and notification to affected organizations...." DLC Quality Assurance Procedure No. Op-13, Control of Nonconforming Items, Revision 4, Section 13.2.1 states " Materials and parts which do not conform to require-ments shall be identified and controlled in accordance with written 1
instructions to prevent their incorrect use of installation. These instructions shall include, as appropriate, methods for identification... document 9 tion,
... and notification to affected organizations. DLC Mechanical Engineering
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Department Procedure No. MED-305-1, Reporting of Nonconformances as a Result L
of IE Bulletin 79-14, Revision 2, section 4.1 requires the following information to be included in reports of nonconformances from the facility architect engineer:
"1) Nonconforming component.. 6) Safety related function jeopardized if applicable...." Section 4.3.1. of that procedure requires that, following DLC Mechanical Engineering Department review of the architect engineer supplied information:
"A copy of this information will be transmitted to... the Station Superintendent...."
Contrary to the above, on July 31, 1980, the notification provided to the Station Superintendent did not identify the safety related function jeopardized by a nonconformance in that:
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The DLC Mechanical Engineerlag Department had been rotified by the I
facility architect engineer that Main Steam Line supports H-162, H-164, and H-166 deviated from original design and construction requirements for the size of the supports' shim stacks.
The nonconformance increased the probability that the shims would not properly distribute postulated Main Steam Line rupture piping loads and could result in failure of the Fbin Steam Valve Room structure and adjacent Fhin Steam Lines in a manner less conservative than assumed in the facility accident analysis.
The notification provided to the Station Superintendent, Mechanical Engineering Department - Stone and Webster Notification No. 4, dated July 31, 1980, provided only a brief description of the nonconfromance and included only the following relative to the safety related function jeopardized: "These existing shims will not transmit load evenly to the honeycomb section of the restraint which was designed to protect the main steam valve house north wall." A documented description of the safety related function jeopardized by the nonconformance was not available at the facility until January 7, 1981.
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0 Reply to Notice of Violation Appendix A Inspectiot. No. 81-02 VIOLATION B (Severity Level IV; Supplement I)
Corrective Action Taken j
Additional information concerning the nenconforennees was requested by the Station Superintendent and provided by Duquesne light Company Engineering to more adequately describe the consequences postulated for the failure of supports H-162, H-164, and H-166.
This additional information was provided to the NRC on January 7, 1781.
Action Taken To Prevent Recurrence Procedure MED-305-1 will be revised to more completely describe the information which must be transmitted by the Mechanical Engineering Department to the Station Superintendent to permit his full evaluation to determine whether the nonconformance constitutes an unreviewed aafety question.
Date On Which Full Compliance Will Be Achieved Full compliance will be achieved by August 1, 1981.
Actions Taken And Planned To Improve The Effec';iveness Of Our Management Contrc.
Systems Because of the potentially serious nature cf the violations described in Appendix A, the Duquesne Light Company, through its Quality Assurance Depart-ment, co ducted an investigation into the circumstances surrounding the non-compliantes relating to the procedures of document transtittal associated with plant modifications.
?a an out-growth of the recommendations from that study, a computerized Doccment Tracking System is being dev9. loped which will permit prompt and accurate tabulation and verification of tne status of documents on the Design Output List that have been transmitted to and received by the field forces. We believe that the use of this new computerized Document Tracking System will substantially improve the management control system.
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