ML20137P067
| ML20137P067 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/02/1997 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| NUDOCS 9704090129 | |
| Download: ML20137P067 (2) | |
See also: IR 05000334/1996010
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April 2, 1997
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Mr. J. E. Cross
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President
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Generation Group
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' Duquesne Light Company
Post Office Box 4
Shippingport, Pennsylvania 15077
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SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-334/96-10, ! 4-412/96-10 AND
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Dear Mr. Cross:
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This letter refers to your March 24,1997 correspondence, in response to our
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February 21,1997 letter.
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Thank you for informing us of the corrective and preventive actions documented in your
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Your cooperation with us is appreciated.
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Sincerely,
Original Signed By:
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Peter W. Eselgroth, Chief
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Projects Branch 7
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Division of Reactor Projects
Docket No.
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cc: w/o cy of Licensee's Response Letter
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S. Jain, Vice President, Nuclear Services
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R. LeGrand, Vice President, Nuclear Operations
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L.- Freeland, Manager, Nuclear Engineering Department
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B. Tuite, General Manager, Nuclear Operations Unit
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K. Ostrowski, Manager, Quality Services Unit
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R. Brosi, Manager, Nuclear Safety Department
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cc: w/cy of Licensee's Response Letter
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M. Clancy, Mayor
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Commonwealth of Pennsylvania
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State of Oh o
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9704090129 970402
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ADOCK 05000334 [-
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Distribution w/cv of Licensee Response Letter
Region i Docket Room (with concurrences)
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Nuclear Safety information Center (NSIC)
PUBLIC.
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NRC Resident inspector
D. Screnci, PAO -
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- P. Eselgroth, DRP
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D. Haverkamp, DRP .
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J. Nick, DRP
C. O'Daniell,' DRP -
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W. Dean, OEDO .
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R. Correia, NRR
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D. Taylor, NRR
Inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\BV9610.rpy
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TJ receive a copy of thee document. Indecte in the boa: 'C' = Copy without ettechment/ enclosure
- E' = Copy with attachment / enclosure
- N" = No copy
OFFICE
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DATE
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OFFICIAL RECORD COPY
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@ COfDpany Ba'vy",PA
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Shppengport
15077-0004
SUSHil C. JAIN
(412) 393 5512
DMsaon Vice Presiders
March 24,1997
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Nuclear Services
Nuclear Power Division
U. S. Nuclear Regulatory Commission
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Attention: Document Control Desk
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
BV-2 Docket No. 50-412, License No. NPF-73
Integrated Inspection Report 50-334/96-10 and 50-412/96-10
Reply to Notice of Violations
In response to NRC corTespondence dated February 21,1997, and in accordance
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with 10 CFR 2.201, the attached reply addresses the Notice of Violations transmitted
with the subject inspection report.
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If there are any questions conceming this response, please contact Mr. J. Arias at
(412) 393-5203.
Sincerely,
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Sushil C. Jain
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Attachment
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Mr. D. M. Kern, Sr. Resident Inspector
Arc H.-J: Miller, NRC Region I Administrator
Mr. D. S. Brinkman, Sr. Project Manager
Mr. R. W. Cooper,11, Director of Reactor Projects, Region I
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DEllVERING
QUALITY
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E N E.R G Y
M O 4 0/Cl [ $
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DUQUESNE LIGHT COMPANY
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Nuclear Power Division
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Beaver Valley Power Station, Unit No. I and No. 2
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ReDiv to Notice of Violation
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Integrated Inspection Report 50-334/96-10 and 50-412/%-10
Letter Dated February 21,1997
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VIOLATION A (Severity Level IV, Supplement I)
Section 70.24(a) of Title 10 of the Code of Federal Regulations, requires, in part, each
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licensee authorized to possess special nuclear material (SNM) in a quantity exceeding
those identified, to maintain a radiation monitoring system in each area where SNM is
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handled, used or stored that will alarm if accidental criticality occurs. Furthermore,
- applicable emergency procedures must be maintained to ensure personnel are withdrawn
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to an area of safety when the alarm sounds.
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Contrary to the above, as of February 1,1997, the licensee had never installed a
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radiation monitoring system in the Beaver Valley Unit I new fuel storage areas capable
of alarming should an accidental criticality occur. Furthermore, the licensee's initial
exemptions from the requirements of 10 CFR 70.24(a) (contained as part ofits original
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NRC Materials License for possessing SNM) expired when the Beaver Valley Unit 1
construction permit was converted to an operating license in 1976. At that time, the
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licensee failed to install a radiation monitoring system and implement appropriate
emergency procedures, or renew its exemptions. Since then, new fuel storage areas have
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been used to handle, use and store new fuel assemblies on a regular basis prior to each
unit refueling outage.
Reason for the Violation
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The reason for the violation was determined to be personnel error by Duquesne Light
Co. (DLC) Licensing personnel. Licensing personnel failed to recognize that the original
BV-1 Operating License did not contain an exemption from 10 CFR 70.24 requirements
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and consequently failed to take corrective action.
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Corrective Actions Taken and Results Achieved
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On December 18,'1996, DLC submitted to the Nuclear Regulatory Commission (NRC)
an exemption request from the requirements of 10 CFR 70.24 for BV-1. The NRC
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subsequently requested additional information to support the review of the exemption
request. DLC is in the process of providing this additional information and will submit it
to the NRC by April 10,1997.
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Reply to Notice of Violation
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Corrective Actions to Prevent Further Violations
Currently, there are no new fuel assemblies in the BV-1 new fuel storage areas. DLC
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will neither store new fuel in the new fuel storage racks nor handle new fuel assemblies
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in the new fuel storage areas unless the requirements of 10 CFR 70.24 are met or an
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exemption from the requirements of 10 CFR 70.24 is received. N:w fuel assemblies for
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the next BV-1 refueling outage are presently expected to be received onsite in late June
1997.
To ensure fuel cannot be placed in the BV-1 new fuel storage racks, additional
administrative controls have been placed on the lockable hatches on top of these racks.
A Temporary Post Order was issued by Security, who has physical control of the hatch
keys, to add an additional requirement prior to issuance of the keys. This requirement is
to obtain the approval of the Division Vice President, Nuclear Operations and of the
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Director, Nuclear Safety & Licensing before issuing these keys.
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Procedural controls will also be established, prior to the receipt of any new fuel
assemblies onsite for the upcoming BV-1 refueling outage, to prohibit the handling of
new fuel assemblies in the BV-1 new fuel storage areas.
These controls will be
established by April 30,1997.
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The above controls will remain in place unless the requirements of 10 CFR 70.24 are
met or an exemption from 10 CFR 70.24 is received.
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DLC will take actions to postpone the scheduled shipments of new fuel assemblies to the
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BVPS site for the next BV-1 refueling outage, if adequate means to handle and store the
new fuel assemblies will not be available by the scheduled date of receipt.
Date When Full Compliance Will Be Achieved
By prohibiting the storage or handling of new fuel assemblies in the BV-1 new fuel
storage areas, DLC will be in compliance with the intent of 10 CFR 70.24. These
actions will be complete by April 30,1997.
Full compliance will be achieved when an exemption to the requirements of 10 CFR
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70.24 is received for BV-1 or when the requirements of 10 CFR 70.24 are met.
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Reply to Notice of Violation
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VIOLATION B (Severity Level IV, Supplement I)
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10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, requires in part that -
the QA program shall provide control over activities affecting the quality of systems,
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structures, and components consistent with their importance to safety. Additionally, the
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program shall take into account the need for special skills to attain the required quality.
The program shall be documented by written policies, procedures, or instructions and-
shall be carried out throughout plant life.
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Contrary to the above, station procedures were inadequate to assure vendors _ net
Qualified Suppliers List requirements prior to perfonning safety related work. At a
result, on December 1-2, 1996, a vendor performed safety related leak injection repair
services without satisfying applicable quality requirements.
Reason for the Violation
The reason for the violation was determined to be inadequate station administrative
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procedures. The applicable procedures did not provide sufficir.ntly detailed instructions
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to ensure appropriate station personnel would verify all Qualitied Suppliers List (QSL)
conditions are met prior to utilizing an existing purchase order.
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Corrective Actions Taken and Results Achieved
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1.
Effective January 15, 1997, temporary " Vendor Oversight Interim Program
Controls" were instituted. These controls were in addition to the requirements
established in the existing site procedures for the control of onsite vendor services.
These interim program controls include restricting vendor onsite access until the
front page of the "Onsite Service Checklist" has been completed and signed by the
responsible Service Coordinator and a copy forwarded to the Manager of Security.
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Completion of the "Onsite Service Checklist" includes verifying appropriate
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program requirements are met including:
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ensuring all Qualified Supplier List (QSL) restrictions / conditions are
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addressed and
ensuring a Blanket Purchase Order Release is obtained from the Nuclear
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Procurement Department for blanket service purchase orders.
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A review of all outstanding QA Category 1/A blanket purchase orders was
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conducted to determine if, during the blanket period, a QSL restriction or condition
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had been revised or added.
Purchase order change notices were issued to
incorporate any revised QSL restrictions / conditions into applicable outstanding
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Reply to Notice of Viol: tion
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blanket purchase orders. The review found that there were no adverse safety
consequences as a result of these QSL restrictions / conditions not being applied.
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Quality Services Procedure (QSP) 7.4, '" Vendor Selection, Evaluation and
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Qualified Suppliers List" was revised, effective January 17, 1997, to require the
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Quality Services Unit (QSU) to notify the Nuclear Procurement Department (NPD)
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whenever QSU's evaluation of a QSL supplier results in a purchasing
restriction / condition.
Furthermore, per QSP 7.4, QSU will request NPD to
determine the impact, if any, the restriction / condition will have on any open
purchase orders.
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Corrective Actions to Prevent Further Violations
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Additional requirements will be added to existing station administrative procedures to
ensure vendors meet the Qualified Suppliers List requirements prior to their performing
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safety related work. These requirements will' include elements of the " Vendor Oversight
Interim Program Controls."
The procedures to be revised and the schedule for
completing the revisions is as follows:
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Nuclear Power Division Administrative Procedure (NPDAP) 9.5, " Request for
Contracted Services" will be revised by April 15, 1997. The revision will include
requirements for initiating purchase order changes if a QSL condition or restriction
change is implemented after the issuance of a purchase order.
Also, as an
enhancement, completion of the " Vendor Performance Evaluation Record,"
included in the NPDAP, will be required for all services that could affect
permanent plant systems, structures or components.
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NPDAP 9.8, " Request for Contracted Services" will be revised by April 15, 1997,
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to address the implementation and control of Blanket Service Purchase Orders.
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The Manager of Nuclear Procurement will issue a letter to NPD personnel by
March 31,1997, providing additional guidance on the handling of purchase orders
for material.
In particular, it will focus on NPD personnel responsibilities
following notification by QSU per QSP 7.4 of a new QSL purchasing
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restriction / condition.
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NPDAP 9.1, " Material Management," will be revised by May 15,1997, to provide
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specific actions to take for material purchase orders when changes to QSL
restrictions / conditions occur.
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Reply to Notice of Violation
Page 5
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Date When Full Compliance Will Be Achieved
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With the implementation of the interim program controls described in this response and
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the changes to Quality Services Procedure 7.4, Duquesne Light is in full compliance at
this time.
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Once the administrative procedure changes described above have been incorporated into
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those procedures, the interim program controls will be discontinued.
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