ML20064C834
| ML20064C834 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/26/1978 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML17054C948 | List: |
| References | |
| NUDOCS 7810270189 | |
| Download: ML20064C834 (3) | |
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?!219 Septenber 26, 1978 United States Nuclear Regulctory C dssion Attention:
Mr. Eldon J. 3 runner, Chief 2
Reactor Operations and Nuclea:
Support 3 ranch Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
3eaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 II Inspection Report No. 78-20
Dear Mr. Brunner:
In response to your letter of August 30, 1973 and in accordance with 10 CFR 2.201, the actached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report.
The noted violaticus involved the perfernance of surveillance tests by a vendor without approved procedures and the lack of f ornal require =ents and docreentation for the periodic review of naintenance procedures.
Duquesne Light shares your concern over the noted iten (Item A). A reviev of this natter was nade to deter =ine any steps which can be taken to ensure y
i proper control concerning vendor procedures. The Station Ad=inistrative Directive will be revised and ::he vendor will be notified cc preclude si=ilar occurrences.
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If you have any questions concerning this response, please centact ny office.
Very truly yours,
(-]Y'
+ n mAM C. N. Dunn Vice President, Operations Attach =ent i
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?I /d 270 /T9 k
DUQUESNE LIG'd! CCMPANY 3eaver Valley Power Sta:Lon Unic No. 1 REPLY TO NOTICE OF VIOLATICN 3
Inspec:Lon No. 78-20 Latter Dated August 30, 1978 INFRACTION A Descriotion of Infraction (78-20-01)
Section 6.8.1 of the Technical Specifications requires that written procedures be established, implemen:ed and =aintained for surveillance and test ac:171:1es of safety related equipment, including fire protection program i=plementation.
Section 6.8.2 of the Technical Specifications sta:es, "Each procedure and admi f atrative policy of 6.8.1 above.....shall be reviewed by the OSC and approved by the Plant Superintendent prior :o i=plementation..."
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Contrary to the above, on August 10, 1978, 1: was determined that Technical Specification surveillance tests 4.3.3.6.1 and 4.3.3.6.2 condue:ed on the fire alarm system for the period from January 1, 1978 thru June 30, 1978, were perfor=ed without approved procedures.
Discussion of Infraction, Honeywell, Incorporated has been testing the Station's smoke detector equipment on an annual basis since initial installation.
The annual inspection was due to begin in February of 1978.
On December 30, 1977, Technical Specification Amendment No. 11 beca=a effective which required the same inspection to be performed prior to August 13, 1973 except the procedura must be OSC approved.
The inspection was started in February,1978 and was complaced.
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An inspection procedure was requested from Honeywell. On August 10, 1978 af:ar receipt and review, the procedure was approved w1:hout change.
Since the inspection was performed according to :he procedure which was subsequently approved, it was determined that no retest was required.
Corrective Action Operating Manual Change Notice 73-161, OST 1.33.16 - Snoke Detector Instrumenta:1on Test, was reviewed and approved by the OSC on August 10, 1978.
Since the tes:
procedure that was utill:rd has been approved without any changes that vould affect the results, there was no compromise of safety.
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.'l Reply Io Notice of Violation Inspection No. 78-20 Page 2 l
7 Action Taken To Prevent Recurrence
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The Station Administrative Directive will be revised to remind personnel that procedures used by vendors on site must also receive OSC review and approval.
Honeywell, Inc. will be requestad to notify the -Station if they intend to change the test procedure.
Date On Which Full Compliance Will 3a Achieved Full compliance has been achieved at this time.
I INFRACTION 3 Descriotion of Infraction (78-20-02) 9 Technical Specification Section 6.8.2 states,.in part, "Each procedure and administrative policy of 6.8.1...shall be reviewed by the OSC and approved by the Plant Superintendent prior to implementation and reviewed periodically as set forth in administrative procedures."
Contrary to the above, on August 10, 1978, it was determined that there are no requirements established for the periodic review of maintenance procedures, and no evidence to support that a review has been performed.
Discussion Of Infraction Presently the Station Maintenance Manual does not state a frequency for review of procedures relating to surveillance and tast activities on safety related equipment. Tech Spec 6.8.2 states that the frequency should be in accordance with Regulatory Guide 1.33, November,1972. The recommended frequency is within a period of rwo years and has been the Station Maintenance accepted practice for
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review of these procedures. A present check of the'Maint'enance surveillance and i
calibration procedures review dates confirms the review of these procedures has been performed within the required period.
f Corrective Action Sections D, O and '4 of the Maintenance Manual will be revised to require periodic review of naintenance procedures.
Action Taken To Prevent Recurrence The revision to the Maintenance Manual should prevent recurrence of this problen.
Date On Which Full Comolian:e Will 3e Achieved Full compliance will be achieved by November 30, 1978.
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