ML20101B355

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Responds to NRC Re Noncompliance Noted in Insp Rept 50-412/84-12.Corrective Actions:Resumes of Walkdown Team Participants Reviewed.Extension for Response to Part (B) Until 850115 Requested
ML20101B355
Person / Time
Site: Beaver Valley
Issue date: 12/10/1984
From: Woolever E
DUQUESNE LIGHT CO.
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
2NRC-4-204, NUDOCS 8412200269
Download: ML20101B355 (3)


Text

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2NRC-4-204

, (412)787 - 5141 hn- u --

(412)923 -1960 Tefecopy (412) 787-2629 Nuclear Construction Division December 10, 1984 Robinson Plaza, Building 2, Suite 210 Pittsburgh, PA 15205 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Richard W. Starostecki Division of Project and Resident Programs

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/84-12 Gentlemen:

This is in response to the Item of Noncompliance cited in Inspection No. 5 0-412/84-12 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever, dated November 9,1984.

Notice of Violation:

As a result of the inspection conducted on September 10-14, 1984, and in accordance with the NRC Enforcement Policy (10CFR2, Appendix C), the follow-ing violation was identified:

10CFR50, Appendix B, Criterion II, states in part that the Quality Assurance Program "shall provide for indoctrinat ion and training of personnel performing act ivi ties affecting quality ...." The FSAR, Section 1.8 commits to ANSI N45.2.6-198 which requires that the employer of ins pe ction , examination and testing personnel assures they meet the qualification requirements of the standard including cert ification thereof.

Contrary to the above, the established Quality Assurance Program did not provide for personnel (other than from the QC and startup groups) that participated in the September 13, 1984, walkdown of a Service Water Intake Subsystem or the personnel (other than from the QC and startup groups) that participated in the Stress Reconciliation Walkdowns to date to be certified in accordance with the appropriate ANSI N45.2.6 qualifi-cation requirements.

Response

The Violation involved certification of personnel invo lved in the following two types of walkdowns:

(a) ASME Piping ISO Verification Walkdown as applicable to stress reconciliation.

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Mr.-Richard W. Steroatscki-Page 2 (b) System Walkdown prior to turnover for system testing.

Following is a response to part (a):

The resumes of the walkdown team participants, other than those assigned by Site Quality Control (SQC) and the Start-Up Group (SUG),

were reviewed. The SQC and SUG personnel had already been certified in accordance with the requirements. The initial review indicated that - all personnel involved in the walkdown were capable of-being certified to the requirements prior to the commencement of the walk-down activity. f A Management decision has been made to trans fer members, from groups Kher than SQC and SUG, to the SQC Department for certification ~ for the activity to be performed. When this

-reassignment occurs, the individual will be certified as a Level I QC Inspector for weasurement of piping as compared with the _ isomet-ric. The appropriate procedures will be revised to reflect this approach. This action will be completed by December 31, 1984.

A request for an extension of time is needed to develop a satisfac-tory response for part (b) of the Violation . identified above. This extension was discussed with the NRC Senior Resident Inspector on

-Friday, November 30, 1984, and it was concluded that, due to the need -for . a Senior Management review of DLC's overall approach to System Releases, a re s po ns e date of January 15, 1985, was acceptable.

DUQUESNE LIGHT COMPANY By % . i

~E.(/J . Tooldver Vice President SDH/wjs cc: Mr. R. DeYoung, Director (3)

Mr. B. K. Singh, Project Manager Mr. G. Walton, NRC Resident Inspector INPO Records Center NRC Document Control Desk SUBSCRIBED AND WORN TO BEFORE ME THIS

/d d DAY OF- ab , 1984.

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Notary Public ANITA ELAINE REITER, NOTARY PUBUC RODINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMIS$lON EXFIRES OCTOBER 20,1986 L....

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Unitsd Stctaa Nuclacr Rsgulctory Commiccion Mr. Richcrd .W. ' Sterostccki Page 3 4-COMMONWEALTH OF PENNSYLVANIA )

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COUNTY OF ALLEGHENY )

-On this / day'of c/ c , /M , before me, a Notary Public in and for said Commonwealth and County, personally appeared E. J. Wooleve r , who being duly 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 en behalf - of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.

M d62 Notary Public ANITA ELAli;E PEliER, NOTAitY PUBLIC ROBINSON TOWNSHIP ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986 d

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