ML20133F423

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-334/96-07 & 50-412/96-07

ML20133F423
Person / Time
Site:	Beaver Valley
Issue date:	01/06/1997
From:	Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J DUQUESNE LIGHT CO.
References
NUDOCS 9701140178
Download: ML20133F423 (2)

See also: IR 05000334/1996007

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l January 6, 1997

Mr. J. E. Cross

l President

Generation Group

i Duquesne Light Company

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Post Office Box 4

Shippingport, Pennsylvania 15077

l SUBJECT: INSPECTION REPORT 50-334/96-07 AND 50-412/96-07

Dear Mr. Cross:

This letter refers to your December 9,1996 correspondence, in response to our

November 8,1996 letter.

Thank you for informing us of the corrective and preventive actions documented in your

letter. These actions will be examined during a future inspection of your licensed program.

, Your cooperation with us is appreciated.

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Sincerely,

Original Signed By:

Peter W. Eselgroth, Chief

Projects Branch 7

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Division of Reactor Projects

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Docket Nos. 50-334;50-412

! cc w/o cv of Licensee's Resoonse:

Sushil C. Jain, Vice President, Nuclear Services

l T. P. Noonan, Vice President, Nuclear Operations

l L. R. Freeland, Manager, Nuclear Engineering Department

i B. Tuite, General Manager, Nuclear Operations Unit

K. L. Ostrowski, Manager, Quality Services Unit

R. Brosi, Manager, Nuclear Safety Department

cc w/cv of Licensee's Resoonse

M. Clancy, Mayor

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Commonwealth of Pennsylvania

State of Ohio j\

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140019

9701140178 970106 [.(>l

PDR ADOCK 05000334 /

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Mr. J. E. Cross 2 .

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Distribution w/cv of Licensee's Resoonse:

Region i Docket Room (with concurrences)

PUBLIC

Nuclear Safety Information Center (NSIC)

D. Screnci, PAO

NRC Resident inspector

P. Eselgroth, DRP

D. Haverkamp, DRP

B. Welling, DRP

C. O'Daniell, DRP

Distribution w/enci (VIA E-MAIL):

J. Stolz, NRR  :

D. Brinkman, NRR

W. Dean, OEDO

R. Correia, NRR

R. Frahm, Jr., NRR

Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\BV9607.RPL

To acceive a copy of this document, indicate in the boa: *

C* = Copy without attachment / enclosure *E' = Copy with attachment / enclosure "N* = No copy

l OFFICE Rl/DRP ,

c Rl/p@ Rl/DRS , &

NAME BWelling G// PE{pfED4h RKeimig VA

DATE 12/18/96 18/4/96 12/A /96 yv 12/ /96 12/ /96 j

OFFICIAL RECORD COPY

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• y y Beaver Vaney Power Statbn

Shippingport, PA 15077 0004

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Nuclear Power Olvulon

December 9,1996

U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

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Washington, DC 20555-0001

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Subject: Beaver Valley Power Station, Unit No. I and No. 2

BV-1 Docket No. 50-334, License No. DPR-66 l

BV-2 Docket No. 50-412, License No. NPF-73

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Integrated Inspection Report 50-334/96-07 and 50-412/96-07

Reply to Notice of Violation

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In response to NRC correspondence dated November 8,1996, and in accordance

with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with

the subject inspection report. j

If there are any questions concerning this response, please contact Mr. Roy K.

Brosi at (412) 393-5210. l

Sincerely,

Sushil C. Jain

c: Mr. D. M. Kern, Sr. Resident Inspector

Mr. H. J. Miller, NRC Region I Admini.strator

Mr. D. S. Brinkman, Sr. Project Manager

Mr. P. W. Eselgroth, Chief, Projects Branch No. 7

Division of Reactor Projects, Region I

DEllVEllH

0UALlTY

ENERGY

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DUQUESNE LIGHT COMPANY

l ,. Nuclear Power Division

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Beaver Valley Power Station Unit No. I and Unit No. 2

l Reoly to Notice of Violation

Integrated Inspection Report 50-334/96-07 and 50-412/96-07

Letter dated November 8,1996

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VIOLATION A (Severity Level IV, Supplement III)

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Description of Violation (50-334/96-07-07 and 50-412/96-07-07)

, 10 CFR 73.21 requires that, "Each Licensee...shall ensure that Safeguards information is

l protected against unauthorized disclosure."

The Beaver Valley Power Station (BVPS) Physical Security Plan, section 13.7, requires

that, "a system shall be established and maintained for the protection of Safeguards )

l Information."

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l These requirements were implemented by Nuclear Power Division Administrative

l Procedure (NPDAP) 2.8, " Protection of Safeguards Information." The requirements of  ;

NPDAP 2.8 include the following: i

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(1) Safeguards Information Custodians are responsible for the protection of Safeguards

Information within their department.

(2) Personnel who handle or use Safeguards Information are responsible for protecting ,

! the information as required by 10 CFR 73.21 and this procedure.  !

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(3) Personnel who possess Safeguards Information shall control the information while l

it is in use so that only persons who have a need-to-know are permitted access to l

the information.

(4) Department Managers shall develop a method to inventory their section's

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Safeguards Information at a minimum of annually.

Contrary to the above, safeguards infonnation was not adequately protected in

accordance with the above procedures as evidenced in the following examples:

a. On August 28,1996, a Safeguards Information custodian discovered three

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missing safeguards drawings during an inventory. Further investigation

revealed a total of seven drawings that were unaccounted for.

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Beaver Valley Power Station, Unit No. I and Unit No. 2

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Reply to Notice of Violati:n  ;

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b. An annual inventory of the Instmmentation and Controls Section Safeguards

, Information was not conducted in 1995. l

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c. On August 30,1996, the Instrumentation and Controls Section safeguards l

file lock combination was found to be uncontrolled.

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Reason for the Violation

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The root cause of this event was determined to be inadequate enforcement by

management of Standards, Policies and Admmistrative Controls for the protection of

l Safeguards Information (SI) within the Maintenance Department.

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Corrective Actions Taken and Results Achieved

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1. Security performed inspections by September 3,1996, which verified that there

l were no known compromises to security areas, systems, or components addressed

l by the unaccounted for SI.

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l 2. Evaluations of the potentially compromised SI were performed by September 3,

1996, which determined that the unaccounted for documents could not have

allowed unauthorized or undetected access to protected or vital areas.

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3. Lock combinations were changed at each SI storage location by September 15,

1996.

, 4. A comprehensive inventory of site SI files was completed by September 14,1996.

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5. The number of site SI storage locations and custodians and the quantity of SI

materials was reduced by September 15,1996. The reduction in the number of SI

storage locations removed the Maintenance Department SI storage facility,

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6. Training and management expectations regarding the control of SI were provided to

l SI custodians by September 13,1996.

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l 7. Maintenance Department management and supervisory personnel were counseled l

and performance expectations pertaining to the control of SI were reinforced by

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Corporate Management by September 3,1996.

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Be:.ver Valley Power Station, Unit No. I and Unit No. 2

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Reply to Notice of Violation

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Actions Taken to Prevent Recurrence

1. General Employee Refresher Training was revised on November 11,1996, to

include a description of the event, root cause and corrective actions.

2. NPDAP 2.8, " Protection of Safeguards Information," will be revised to enhance

controls on transmitting and receiving SI by December 31,1996.

3. Implementing procedures will be revised to reflect changes made to NPDAP 2.8 by

January 31,1997.

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4. The control of SI was addressed in the Plant Manager's Standard of the Week, for l

the week of September 30,1996.

Date When Full Comollance Will be Achieved

As described above, Duquesne Light Company is in full compliance at this time.

The above actions will be completed by January 31,1997.

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VIOLATION B (Severity Level IV, Supplement I)

Description of Violation (50-334/96-07-03 and 50-412/96-07-03)

10 CFR 50, Appendix B, Criterion XVIII requires in part that a comprehensive system of

planned and periodic audits be performed to verify compliance with all aspects of the

quality assurance (QA) program.  ;

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10 CFR 50.34(b)(6)(ii) requires in part that the Final Safety Analysis Report describe the I

managerial and administrative controls to be used to assure safe operation. This shall

include discussion of how the applicable requirements of 10 CFR 50, Appendix B will

be satisfied.

Technical Specification 6.5.2.8.d requires that audits of facility activities be performed

under the cognizance of the offsite review committee (ORC). The audits shall

encompass the performance of activities required by the QA program to meet the criteria

10 CFR 50, Appendix B.

BVPS Updated Final Safety Analysis Report (UFSAR) 13.4 states that the onsite safety

committee (OSC) reviews various activities that have nuclear safety significance and

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Beaver Valley Power Station, Unit No. I and Unit No. 2

,, . Reply to Notice of Violation

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advises the General Manager, Nuclear Operations, on all matters related to nuclear .

safety. I

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The BVPS QA program commits to NRC RG 1.33 and ANSI N18.7 as described in l

Operations QA procedure OP-1, " Operations Quality Assurance Program," Rev. 6 and I

the UFSAR.

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NRC Regulatory Guide (RG) 1.33, "QA Program Requirements (Operation)," Rev. 2,

conditionally endorses American National Standards Institute (ANSI) N18.7/American

Nuclear Society (ANS)-3.2 as an acceptable method to comply with 10 CFR 50, l

Appendix B. Section 4 of ANSI N18.7/ANS-3.2 requires that programs for reviews and j

for audits of activities affecting safety shall be established, and that such programs for J

reviews and audits shall, themselves, be periodically reviewed for effectiveness. Audits

of selected aspects of operational phase activities shall be performed with a frequency  !

commensurate with their safety significance and in a manner to ensure that an audit of all  !

safety-related functions is complete within a period of two years. Periodic reviews of

the audit program shall be performed by an independent body.

10 CFR 50.54(a)(3) requires in part that changes to the QA program description that

reduce commitments must be submitted to the NRC and receive NRC approval prior to

implementation.

Contrary to the above, the licensee failed to perform required periodic audits of activities  :

performed by the OSC under the cognizance of the ORC since March 1992.

Additionally, failure to perform OSC audits constituted a reduction in QA program

commitments which was implemented without prior NRC approval.

Discussion of the Violation

From 1980 to 1990, annual compliance based audits of the OSC were performed.

During this period, only four minor deficiencies were identified. In 1991, based on

NUREG/CR-5151, " Performance Based Inspections," and the OSC's audit performance,

it was determined that the review of OSC activities could be integrated into other

applicable audits. This method was implemented and provided the opportunity for a

performance based review of the OSC, since audits would reflect the extent to which the

OSC's activities were effectively accomplished. In this manner from 1992 to present,

OSC activities were revieived in 15 separate audits which audited the areas of

Operations, Maintenance, Engineering, Training, Health Physics, Chemistry, Emergency

Planning, Environmental and Corrective Actions.

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l' Braver Valley Power Stati::n, Unit No. I and Unit No. 2

'.. Reply to Notice of Viol tion

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j In June of 1996, a Cooperative Management Audit Program (CMAP) audit was

conducted meeting the requirements of Technical Specification 6.5.2.8.d. During this

audit (SPEC-%-01), the function of plant oversight groups, including the OSC, was

reviewed at the request of the ORC.

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Reason for the Violation

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l The reason for the violation was a misinterpretation of the audit requirement. An audit

j of the OSC was not considered a requirement of Technical Specification 6.5.2.8.a.

j Corrective Actions Taken and Results Achieved

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A self assessment of the Quality Services Unit's overview of the OSC and Section 6 of l

the Technical Specifications was completed on September 30, 1996. The Quality l

I Services Unit will perform biennial audits of site oversight groups. These groups will

! include the OSC, ORC, and the Nuclear Safety Review Board (NSRB). Surveillances of

j these groups will also be performed to supplement the audit process.

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The audit of the site oversight groups has been included in the 1997 audit schedule.

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Actions Taken to Prevent Recurrence

Quality Services Procedure (QSP) 18.1 " Audit Schedules" will be revised to include a

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biennial audit of Section 6 of the Technical Specifications including site oversight

groups.

Date When Full Compliance Will be Achieved

Surveillances of the site oversight groups will begin in December 1996. The first

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biennial compliance based audit of these groups will be completed by March 31,1997.

The revision to QSP 18.1 will be issued by January 31,1997.

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