ML20011A316

Responds to NRC 810702 Ltr Re Violations Noted in IE Insp Rept 50-334/81-03.Corrective Actions:Review Will Be Performed to Update Data Records of Past Tests

ML20011A316
Person / Time
Site:	Beaver Valley
Issue date:	08/03/1981
From:	Carey J DUQUESNE LIGHT CO.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20011A305	List: ML20011A313 ML20011A316
References
NUDOCS 8110090292
Download: ML20011A316 (5)

Text

_ . . _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

9

. 1

'Af (412) 456-6000 4M Sisth Avenue Pittsburgh, Pe

' 52 August 3, 1981 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Boyce 11. Crier, 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 Report No. 81-03 ,

Centlemen:

In response to your Ictter of July 2, 1981, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A with the referenced inspection report.

We have reviewed the referenced inspection report for 10 CFR 2.790 information and none was identified.

If you have any questions concerning this response, please contact my office.

Very truly yours, v

. J. Carey Vice President, Nuclear Attachment cc: Mr. D. A. Beckman, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuc1 car Regulatory Commission c/o Document Management Branch Washington, DC 20555 81i0090292 810924 PDR ADOCK 05000334 G PDR

~ - _ _

r

+ * .

DUQUEENE LIGHT COMPANY Beaver Valley Power Station

, Unit No. 1 Reply to Notice of Violation Inspection No. 81-03 Letter dated July 2, 1981 VIOLATION (Severity Level VI)

Description of Violation (81-03-03)

As a result of an inspection conducted on February 2-6 and 18-20, 1981 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),

it was identified in the following three areas that corrective actions and management controls to ensure proper corrective actions concerning a pre-viously identified notice of violation were inadequate; and that Technical Specification administrative controls were not followed. The following items are separated examples which are considered cel.?ectively to be a single violation:

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 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 action shall be documented and reported to the appropriate levels of management."

Contrary to the above, management controls to enstre corrective accion and the corrective action taken for a previously identified item of noncompliance was inadequate in that the following item of noncompliance identified in our letter dated thrch 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 for the above calibrations 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 Specificatiens.

Continued inadequate corrective action is evidenced by noncompliance in the following areas:

Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Inspection No. 81-03 Page 2 Description of Violation (81-03-03) (continued)

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 reviewed by the OSC and approved by the plant superintendent prior to implementation . . . Temporary changes to procedures ... may be made provided ... the intent of the original 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 11.2, states, in part, that implementitig procedures are required for each calibration listed in Technical Specifications.

t Contrary to the above, for the procedure used for tests per-formed on July 12, 1980; November 1, 1980; and February 5, 1981, no documentation existed that this procedure had been approved by the p?qnt euperintendent. Note: It was documented that the Onsits Safety Committee (OSC) at meeting BV-OSC-71-80 held Jun( f2, 1980, reviewed and recommended for approval by the plant <uperintendent, the NUS (vendor) Procedure 1539, Volume 2, " art 1, Section 4.0, Revision 2, draf t " 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 pe-formed November 1, 1980 and February 5, 1981, had not been reviewed by the OSC nor approved by the plaat superintendent; and a copy of this revised procedure was not being maintained on site.

Additionally, Duquesne Light Letter, BVPS:RLH:15, dated June 16, 1980, authorized NUS Corporation to make minor "non-intent" revisions to this prc;. Jure without obtaining station approval, which is not in conformance with Technical Specification 6.8.3.

b. Technical Specification 6.10.1.d states, in part, " Records of...

calibrations required by these Technical Specifications (shall 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 information and rccord purposes were incomplete, omitting the reccrding 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.

Beaver Valley Power Station, Unit No.'1 Reply to Notice of Violation Inspection No. 81-03 Page 3 Corrective Action On May 1, 1981, NUS Procedure 1539, " Beaver Valley Metec. alogical Monitoring System Maintenance and Calibration Procedure," wa, revised and approved as MSP 45,17, Revision 2, " Meteorological Monitoring System Test /

Calibration Meteorological Monitoring System."

An approved procedure will be kept in the MET tower trailer along with data sheets and critique sheets. When the test has been completed, the data sheets will be presented to the Shift Supervisor to verify satisfactory com-pletion. If any problems are encountered, the critique sheets will then be filled out to document this. These data sheets will then undergo the normal review as prescribed by the MSP program.

For the past tests where data records appear to be incomplete, a review will be performed to update our records. We expect to receive in early August information from NUS regarding past tests. We expect to complete our review by September 15, 1981.

Action to Prevent Recurrence A meeting was held between Duquesne Light Company and NUS and it was agreed that the NUS Procedure 1539 would be controlled by Duquesne Light Company within the MSP program. It was stressed that any changes to the procedure required station review and approval and the completed data must be retained by the station as a permanent record.

Date On '*

• n Full Compliance Will Be Achieved Full compliance will be achieved with the completion of the past test record review, expected by September 15, 1981.

l l

f '

m

([ v 3, ,

y 7, COMMONWEALTH OF PENNSYLVANIA)

COUNTY OF BEAVER 1ss:

On thi mb day of b u r /9O , before me, d,AeA# (he ,

, a Notary Pdblic in and for said Commonwealth an@ County,personallyappehdJ.J.Carey,whobeingdulysworn, 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 i Company, and (3) tha statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.

1 y

( Ql h_ f s-M 4 - I app #aG V JUDITH 0. I'lTHONY, Notary Pdig

%i;pingport Borough, Seaver Co., Fa.

'N Commission bpires Dec. 12, 1983 I

i 3

2 ,

,.-,.-r .. , t e -

. -- - n. , , .--

---

v