ML20054E356
| ML20054E356 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/19/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20054E353 | List: |
| References | |
| NUDOCS 8206110111 | |
| Download: ML20054E356 (4) | |
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Telephone (412) 456-6000 Nuclear Division April 19, 1982 P.O. Box 4 Shippingport, PA 150776 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Thomas T. Martin, Director Division of Engineering and Technical Programs Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Re fe rence :
Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 IE Inspection Report No. 82-05 Gentlemen:
In response to your letter of March 23, 1982, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Vfolation which was included as Appendix A with the referenced Inspection Report.
If you have any questions concerning this response, please contact my office.
Very truly yours, J. J. Carey Vice President, Nuclear
Attachment:
Reply to Notice of Violation cc:
Mr. D. A. Beckman, Resident Inspector 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 8206110111 820604 PDR ADOCK 05000334 g
I COMMONWEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER
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i DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation Inspection No. 82-05 Letter dated March 23, 1982 VIOLATION (Severity Level IV; Supplement I)
Description of Violation (82-05-01)
Criterion III, Appendix B,10CFR 50, in part, states:
" Measures shall be established to assure that applicable regulatory requirements and the design basis.
.. are correctly translated into specifications, drawings, procedures and instructions."
" Measures shal1 ~ be established for the identification and control of design interfaces and for coordination among participating design organizations."
"The design control measures shall provide for verifying the adequacy of design.
Contrary to the above:
(a) Two design change packages (DCP's), DCP-298 and DCP-299 (a sample) neither identified the applicable regulatory requirements nor contained information to demonstrate how the design requirenents were correctly translated into specifications, drawings, procedures, and instructions.
(b) A review of three design changes, namely, DCP-298, DCP-333, and DCP-303 (a sample), identified inadequate control of design interfaces and coordination among participating design organizations in that the engineering organizations did not inform the licensing organization about the dif ferences between NUREG-0737 requirements and the actual design in a timely and controlled manner.
Additionally,
the licensing organization did not appraise the engineering organizations of NUREG 0737 commitments made by a corporate of ficer in a timely and controlled manner.
(c) The design verification letters for DCP-293 and DCP-299 (a sample). lacked the necessary information for verifying the adequacy of the respective designs.
Beaver Valley Power Station - Unit No.1 Reply to Notice of Violation, Inspection No. 82-05 Page 2 Corrective Action Taken
. A detailed review of all NUREG-0737 related modifications was started and is currently in progress. The objectives of this review are as follows:
(a) Examine the applicable regulatory requirements for each DCP and ensure that:
(1) requirements are included as inputs to the design process (2) compliance to requirements is addressed in design output documents.
(b) IdentJfy the status and projected schedule of completion as well as any instances where the-proposed design deviates from NUREG-0737.
requirements.
Identified deviations and their proposc d corrections or justifications will then be ~ submitted to the NRC for review.
Action Taken to Prevent Recurrence Procedures will be revised to assure proper identification of regulatory requirements and their translation to design outputs.
Procedures will be developed to control interfaces for correspondence within the Nuclear Division.
A procedure will be developed to control interfaces between all divisions and outside organizations to assure that the regulatory require-ments are transmitted to the design engineer and that deviations from regulatory requirements are transmitted to the Licensing Section for records updating and notification of the NRC, as required.
Date On Which Full Compliance Will Be Achieved The actions listed under " Corrective Action Taken" will be completed prior to Cycle 3 startup.
The actions to prevent recurrence will be completed on or before September 30, 1982.
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