ML20091R803
| ML20091R803 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/14/1984 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20091R802 | List: |
| References | |
| NUDOCS 8406150243 | |
| Download: ML20091R803 (6) | |
Text
__
'A@
Telephone (412) 393-6000 Nuclear Diviolon Shippingport, PA 150U 0004 May 14, 1984 jU.S. Nuclear Regulatory Commission
/ Office of Inspection and Enforcement Attn: Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Inspection Report 84-06 Gentlemen:
In response to your letter of April 12, 1984, and in accordance with 10CFR2.201, the attached reply addresses the Notice of Violation which was included with the referenced inspection report. Our response addresses the steps taken to improve the effectiveness of our management control systems in addition to describing our specific corrective actions.
If you have any questions concerning this response, please contact my office.
Ver tr y yours,
. Carey Vice President, Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector U.S. Nuclear Regulatory Commission Beaver Valley Power Station Shipping? ort, PA 15077 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation and Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 8406150243 840611 PDR ADOCK 05000334 G
- 1. -
DUQUESNE LIGHT COMPANY p
Beaver Valley Power Station Unit No. 1 0
i i[
Reply to Notice of Violation Inspection 84-06 l
Letter dated April 12, 1984 e
j VIOLATION A (Severity Level IV; Supplement 1) l Description of Violation (84-06-01)
Technical-Specification paragraph 4.0.5 states in part that inservice testing of pumps and valves shall be performed in accordance with Section XI of the i
ASME Boiler and Pressure' Vessel Code and applicable Addenda as required by 4
j 10CFR50, Section 50.55a(g), except where specific written relief has been granted by the Commission.Section XI, Subsections IWP and IWV, provides specific requirements for testing. pumps and. valves, respectively.
IWV para-1-
ph 3410 states that valves."shall be exercised'at least once every three i
months."
I 10CFR50 Appendix 'B Criterion I states that "The authority and duties of.
persons and organizations performing activities affecting the safety related 2
... components.shall be clearly established and delineated in writing," and Criterion XVIII states that "a comprehensive system of planned and periodic' audits shall be carried out to verify compliance with all aspects of the-quality assurance program and to determine the effectiveness.of the program."
j.
The Beaver Valley QA Procedure OP-1 paragraph 1.1.7 statesLthat the Operations-l_
Quality Assurance Program is written to conform to the applicable requirements.
of Appendix B to 10CFR50. QA Procedure OP-3, paragraph 3.3, states in partl i
f that directives and detailed procedures-shall be developed, administrative.
procedures shall be established prescribing activities affecting-safety-related i
items including revisions or chen~ts-thereto and shall delineate responsibili-.
l ties and authorities of the plant staff.
o Technical Specification 6.8 states that written procedures shallI be.estab--
lished and implemented for surveillance and test activities of safety-related.
equipment and shall be reviewed by the OSC (Onsite Safety Committee).
Contrary to the above, the following.are examples of a lack of management
}
controls: including quality. assurance for the Inservice Testing' Program for -
i l
pumps and valves:
R j
-1.
' Hydrogen recomLiners' valves MOV-1HY-201A and MOV-1HY-201B are: required!
to be tested quarterly in:accordance with ASME Section XI IWV-3410, and I
.the valves were not being tested quarterly. - These valves.had specifi '
cally been denied' relief from quarterly; testing in a -letter dated.
o lune 29, 1982 from NRC to Beaver Valley.
-l I
.)[
.,,_ _ _... ; ~
- 1. 4,
m 4,,.. L m _,,
.May 14, 1984 Reply to Notice of Violation Inspection 84-06 Letter dated April 12, 1984 i
Page 2 of 5 Description of Violation (continued) 2.
There were no approved procedures clearly delineating the authorities, duties, and responsibilities for the inservice testing of pumps and valves from the highest management level through intermediate levels to and including the technical support activities.
3.
The QA audits conducted of the Inservice Testing Program for pumps and valves during operations provided no coverage of the aspects of the test procedure implementation and the actual conduct of testing.
4.
An annual QA audit of inservice testing of pumps and valves was being conducted on February 15, 1984, using an unapproved copy of the updated Inservice Testing Program for pumps and valves.
5.
The Beaver Valley Unit 1 Inservice Testing Program for pumps and valves 20-month update was submitted to the NRC on March 28, 1983, and placed in use at the station without being reviewed and approved by the Onsite Safety Committee (OSC).
Discussion As a result of our review of the circumstances associated with this violation, extensive procedure development has been initiated to eliminate the concerns regarding the lack of management controls in the area of the Inservice Test-ing Program for pumps and valves. Our actions, as outlined below, should improve the effectiveness of our management control for this program. The specific actions taken in regard to the five examples cited in the Notice of Violation have also been addressed in this reply.
Immediate Corrective Action and Results Achieved The Testing and Plant Performance (T&PP) administrative procedure which covers T&PP personnel and their authorities and responsibilitics for pump and valve inservice testing has been approved and issued.
A letter outlining the Station's plan of. action concerning the develop-ment of Site Administrative Proceduresias issued on April 5,1984.
A meeting was held on April 30, 1984 to discuss the speci-fic content and fonn of the procedures for the ISI Program.
May 14, 1984 Reply to Notice of Violation Inspection 84-06 Letter dated April 12, 1984 Page 4 of 5 Specific Actions Taken (continued) 2.
There were no approved procedures clearly delineating the authorities, duties, and responsibilities for the inservice testing of pumps and valves from the highest management level through intermediate levels to and including the technical support activities.
Actions Taken:
The T&PP administrative procedure which covers T&PP personnel and their authorities'and responsibilites for pump and valve inservice testing has been issued. Additional administrative procedures which clearly delin-iate the authorities, duties, and responsibilities for the IST Program from the highest management level through the intermediate levels to and including the technical support activities are being developed as pre-viously described in this response.
3.
The QA audits conducted of the Inservice Testing Program for pumps and valves during operations provided no coverage of the aspects of the test procedure implementation and the actual conduct of testing.
Actions Taken:
Duquesne Light Company Quality Assurance Unit has formed a permanent sur-veillance activity to perfonn ongoing operating plant surveillances in accordance with Quality Assurance Instruction 18.3.2, " Quality Assurance Surveillances." Surve111ances will also be conducted in conjunction with the auditing of departments whose responsibilities include testing functions.
In future Inservice Testing Audits, quality assurance surveillances will be performed to provide coverage of test procedure implementation and the actual conduct of pertinent tests.
Designated surveillance personnel are currently working with the Quality Assurance Unit.
Full compliance has been achieved.
4.
An annual QA audit of inservice testing of pumps and valves was being conducted on February 15, 1984, using an unapproved copy of the updated Inservice Testing Program for pumps and valves.
Actions Taken:
Future Duquesne Light Company Quality Assurance audits of the Inservice Testing Program for pumps and valves will be performed with the approved and controlled Inservice Testing Program for pumps and valves.
1 l
May 14, 1984 Reply to Notice of Violation j
Inspection 84-06 Letter dated April 12, 1984 Page 5 of 5 Specific Actions Taken (continued) 4.
Actions Taken:
(continued)
To ensure the adequacy of the 1983 audit of the Inservice Testing Program for pumps and valves (Audit BV-1-84-04), a review will be performed after final Duquesne Light Company management approval of the Inservice Testing Program for pumps and valves. The review will be conducted by the Duquesne Light Company Quality Assurance Unit, and will compare the approved Inservice Testing Program for pumps and valves to the unapproved Inservice Testing Program used during the performance of the quality assurance audit. Any changes noted in the approved Inservice Testing Program will be evaluated to ascertain their effect on Audit BV-1-84-04.
Full compliance will be achieved within thirty days of the final approval of the Inservice Testing Program for pumps and valves.
5.
The Beaver Valley Unit 1 Inservice Testing Program for pumps and valves 20-month update was submitted to the NRC on March 28, 1983 and placed in use at the station without being reviewed and approved by the Onsite Sefety Committee (OSC).
Actions Taken:
The T&PP administrative procedure governing the IST Program requires that controlled copies of the program be used. The IST Program, which includes the 20-month update submitted to the NRC on March 28, 1983, will be reviewed by the OSC by June 1, 1984. The administrative procedures being developed will require all revisions to the program to be reviewed by the OSC and approved prior to issuance.
7
..