ML20102A208
| ML20102A208 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/30/1985 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-5-012, 2NRC-5-12, NUDOCS 8502080202 | |
| Download: ML20102A208 (3) | |
Text
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( 2 (412)923-1960 Nuclear Construction Division Robinson Plaza, Building 2. Suite 210 Telecopy (412) 7s7-2629 Pittsburgh, PA 15205 January 30, 1985 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 Ins pect ion Report No.
50-412/84-03, Supplemental
Response
Gentlemen:
This is a supplemental response to the item of Violation cited in Inspection No. 50-412/84-03 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever, dated April 16, 1984.
In the NRC letter from R.
W.
Starostecki to Mr.
E.
J. Woolever, dated June 15, 1984, the NRG expressed the following concern in regards to the DLC Response 2NRC-4-064, dated May 17, 1984:
"... based on the additional information supplied in your response, the root cause of the violation was a failure to revise the speci-fication to incorporate approved changes rather than any unaccept-able hardware' conditions. Therefore, although your letter clarifies this matter, a violation was warranted and we do not plan to with-draw it ae you have requested.
Your corrective actions need to address measures to as sure that governing specifications - reflect all approved changes."
DLC has completed its review of existing procedures and practices in response to these comments.
Response
Project Procedure 2BVM-25, " Handling' of Nonconformance and Disposi-tion Reports (N&Ds)," defines the measures necessary to ensure that spe ci-fications reflect.the as-built design of equipment.
The procedure defines categories for approved N&Ds _ as either " change" or "nonch ange" relative to the problem disposition and the requirements of the specification.
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Unitcd Stctso Nuclect Ragulctory Commission Mr. Richcrd W. Starostccki Fage 2 The' following summarizes the current procedural requirements for specification update:
Category N&D Disposition Type of Specification Change Change
" Repair" Revise text or list in final "A c ce pt as is" issue of specification Nonchange
" Rework" List in final issue of
'.'S c r a p" specification
" Return to Vendor" Requirements for assigning a particular N&D disposition are provided in 2BVM-25, as -well as guidance for determining whether a " change" N&D is to be incorporated into the text of the specification or listed in an appendix to the - final-~ specification as required by 2BVM-ll7, " Finalization of Engi-neering Documents for Purchase Orders and Contracts." The issuance of 2BVM-117 on April 11,.1979, now ensures that " rework" N6D's, such as the cited VSG-362, formerly N&D No. 20, will be listed in the final issue of the s peci fication. -Similarly, 2BVM-94 provides guidance on incorporating E&DCRs in. specifications, and 2BVM-117 requires' all E&DCRs which have not been incorporated in the text of the specification to be listed in the final revision of the specification.
Training on the above requirements has been conducted at -both head--
quarters and the SEG since June 1983.
It is our opicion that the implementa-tion of the above-mentioned-requirements is sufficient to ensure that all approved changes will be reflected in specifications.
DUQUESNE LIGHT COMPANY
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By E.(). Woolever Vice President iJS/wjs-
.cci -Mr. R. DeYoung, Director (3)
{Mr. B. K. Singh, Project Manager Mr.'G.'Walton, NRC Resident Inspector iINPO Records Center NRC Document Control Desk SUBSCRIBED AND SWORN TO BEFORE,ME THIS M DAY 10F O, wad
- ,.1985.
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.i Notary Public-
- ANITA ELAINE REITER, NOTARY PUBUC -
ROBINSON TOWNSHIP, ALLEGHENY COUNTY,
MY COMMISSION EXPRES OCTOBER 20/1998 hi LT
U:itsd Stctos Nuclect Rsgulctory Conunicsion Mr. Richard W. Sterostecki
-Page 3 COMMONWEALTH OF PENNSYLVANIA
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COUNTY.0F ALLEGHENY
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On -. this d day of 44T
/ / 86, before me, a m
Notary. Public in and for said Codnwealth (n3 County, personally appeared E.
J. - Woolever, 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 th'e --foregoing Submittal on behalf of said Company, and'(3) the statements set forth -in the Submittal are true and correct to the best of his knowledge.
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Notary Public ANITA ELAINE REITER, NOTARY PUBLIC -
4 ROSINSON TOWNSHIP, ALLEGHENY COUNTY.
MY COMMISSION EXP!RES OCTOBER 20,1986 q-
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