ML20138H472
| ML20138H472 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/23/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8510290050 | |
| Download: ML20138H472 (14) | |
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Telephone (412) 3934000 Nuclear Division P O. Box 4 Shippingport. PA 150774004 Director, Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission ATTN: Mr. James M. Taylor, Director Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Gentlemen:
Your letter dated September 13, 1985, indicated that two Duquesne Light Company employees were among 25 participants from six utilities who attended a training course on containment integrated leak testing provided by General Physics Corporation (GP).
Your letter further stated that the NRC determined that General Physics Corporation distributed material during these training courses which appears to suggest or condone practices that could be misleading to the NRC program of inspection.
Based upon our investigation, it appears that General Physics Corporation presented this course two times; first at Oyster Creek on November 29 and 30, 1983, and later at Columbia, MD on March 1 and 2, 1984.
The two Duquesne Light employees identified in your September 13, 1985 letter attended this later course and no Duquesne Light personnel attended the former course.
We have discussed the content of this course with the two employees involved and examined the course material provided by General Physics for the March, 1984 presentation and find significant differences between the course material obtained by our employees at the March, 1984 General Physics course and the materials attached to your September 13, 1985 letter.
The relevant portions of the course material from the March, 1984 course are attached as Attachment A.
Even considering that General Physics Corporation revised its training course between November, 1983 and March, 1984, we believe that the revised version is flawed in several respects (see pages 3-3 and 3-4).
We do not condone any practices which would mislead any person into believing that a test is acceptable when, in fact, it may not be or to coerce an inspector to accept results of a questionable nature.
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Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 2 Therefore, notwithstanding differences in some facts between the information in your September 13, 1985 letter and those determined by us in our investigation, we concur that some remedial action is appropriate on our part.
We hasten to point out, however, that this situation was not caused or aided in any way by the actions of the two Duquesne Light Company employees identified in your September 13, 1985 letter.
Specifically, your letter addressed the following suggested actions:
1.
Advise (the two Duquesne Light employees) of the NRC's concern regarding the Enclosure 1 material and its potential effect on the regulatory process.
If other employees have utilized this material they should be similarly advised and reinstructed.
RESPONSE
A copy of your September 13, 1985 letter was provided to each of the employees involved and, along with their supervisor, the investigation of facts was performed by them and discussions were held with them concerning the significance of the concern involved in this issue.
These affected employees will be provided with a copy of this response to further clarify our position on this matter.
2.
Review your policies or procedures that are currently in effect to assure that your employees are open and candid in all communications with NRC representatives and that the two Duquesne Light employees have been reinstructed in those policies and procedures.
RESPONSE
We believe that our unwritten policies and practices for dealing with regulatory interfaces have demanded open and candid communication of facts to appropriate authorities.
However, we have developed and issued a written policy, a copy of which is attached as Attachment B, which addresses our mutual concerns in this area.
This policy is posted on Beaver Valley Unit 1 bulletin boards for general employee information.
3.
Revise remaining copies of the lecture material provided by GP to remove the objectionable material.
RESPONSE
Pages 3-4 and 3-5 will be removed from the lecture material and destroyed.
O Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 3 4.
Review results of integrated leak rate tests (ILRT) con-ducted since this course was given by GP to your employees to assure information reported regarding the test is correct and complete.
RESPONSE
There have been no containment integrated leak rate tests performed at Beaver Valley since March, 1984.
5.
Review your internal controls over contractor provided training and training material.
RESPONSE
We have reviewed our internal controls over contractor provided training.
However, we do not believe that any practical controls, short of a page by page review of all course materials prior to the presentation of any course, lecture or seminar, would preclude a situation similar to the one which is the sub]ect of this letter from occurring again.
Realistically, contractors would not provide detailed materials and lesson plans in advance for such courses or seminars so as to preserve the value of the training product which they are offering to sell to the industry.
Your letter also requested our comments on the allegation that the practices described in the General Physics course are a
" traditional industry approach."
From our perspective, we cannot offer an opinion as to how each utility approaches its regulatory interfaces.
I can assure you, however, that these practices are not the approach taken by Duquesne Light Company in fulfilling its duties under its license.
I suggest that region based and resident NRC inspectors are in the best position to evaluate this concern with respect to industry practice and the practices and philosophies of individual utilities.
It is my further understanding that the Regions conduct perodic meetings with resident inspectors, and I suggest that this forum could be used to explore the accuracy of this allegation.
We, of course, would be concerned if such an allegation were accurate for even one plant.
I further believe that to some extent, the influence that material, such as the General Physics material, has on plant employees is directly related to the personal integrity and sense of professionalism of each employee.
As a management philosophy, Duquesne Light Company fosters in its employees a sense of professionalism, personal integrity and responsibility.
e Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 4 We believe that this philosophy is the most effective way to prevent interference with the inspection and enforcement process and assure safe operation in full compliance with all requirements.
This philosophy is the best defense against outside influences which would misdirect our mutual goals.
Ve y ruly yours,
. J.
Carey Vice President Nuclear Group Attachments cc: Dr. T. E. Murley 1
Regional Director U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P. O. Box 26666 One James River Plaza Richmond, VA 23261 1
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ATTACHMENT A
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LECTURE #3 INTERACTIONS WITH THE NRC J
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_KE Y PHASES 4
CONSTRUCTION PERMIT - PSAR COMMITMENTS 9
OPERATING LICENSE - FSAR COMMITMENTS & TECH SPECS S
PREOPERATIONAL TEST - LOTS OF ATTENTION 4
COMMERCIAL OPERATIONS - UPDATES AND PERIODIC TESTS e
OPERATING LICENSE RENEWALS - UPDATES AND PLANT MODIFICATIONS SUBMITTALS AND UPDATES S
SARs (PSAR, FSAR)- CONTAINMENT AND SYSTEMS 4
TECHNICAL SPECIFICATlONS - SUBMIT AT LEAST 6 MONTHS PRIOR TO USE (10CFRSO.SSa(gXSXii))
9 EXEMPTlONS TO 10CFRS0 APPENDIX J 9
RELIEF REQUESTS FOR ASME SECTION XI VALVE TESTING 9
PREOP AND PERIODIC ILRT
SUMMARY
REPORTS (INCLUDES LLRT TESTING
SUMMARY
SINCE LAST ILRT) i G
SECONDARY CONTAINMENT TESTING REPORT (PER TECH SPECS)
G LICENSEE EVENT REPORIS (REPORTABLE OCCURRENCES)
G ASME SECTION XI REPAIR / REPLACEMENTS, AS APPLICABLE (NIS-2 FORM AVAILABLE PER W82A & LATER)
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INSPECTION AND ENFORCEMENT AUDITS S
PROGRAM COMMITMENTS (FSAR & TECH SPECS) e RECORDS OF REQUIRED TESTS / INSPECTIONS e
PROGOURES e
REPAIR AND REPLACEMENT ACTIONS INSTRUMENTATION /CAllBRATION PROGRAM ANTICIPATING NRC ACTION / RESPONSES e
LOCAL / REGIONAL (SURVEILLANCE AND ENFORCEMENT)
PERSONAL INTERESTS AND KNOWLEDG AFFECT AREAS SCRUTIN! ZED AND EMPHASIZED INSPECTOR'S PREJUDICE WILL VARY ON INTERPRETATION / APPLICATION OF REQUIREMENTS NRC POSITlON CAN BE " GUESSED"8ASED ON EXPERIENCE o
EXPERIEN AT OTHER PLANTS i
o PREVIOUS INSPECTIONS REGIONAL PREFERENGS MUST BE CONSIDERED 4
CENTRAL OFFICE - PREPARES / REVISES REGULATIONS, REG. GUIDES; ISSUES POSITIONS 3-2
DAY TO DAY COMMUNICATIONS (INDUSTRY EXPERIENGS)
I 9
Ttf UTILITY SHOULD INFORM THE NRC OF CONTEMPLATED PROGRAM CHANGS KEEP NRC INFORMED ON KEY ISSUES AND TO COMMUNICATE WITH THE INSPECTOR. LOG AND DOCUMENT COMMUNICATIONS. -
BENEFITS: UTILITY CAN LEARN OF NRC POSITION APRIORI. IF NO REVIEW IS PERFORMED, UTILITY CAN DEFEND ACTIONS BY SAYING "THE NRC HAD SUFFICIENT TIME TO COMMENT (BUT DID NOT)... THIS WAS ASSUMED TO CONSITUTE TACIT APPROVAL."
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A 3-3
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DAY-TO-DAY COIMMUNICATlONS (CONTO)
O INFORMING THE LOCAL INSPECTOR IT'S IMPORTANT TO KEEP LOCAL INSPECTOR INFORMED OF CURRENT DEVELOPMENTS ENCOURAGE INSPECTOR TO WITNESS A TYPE C TEST, BUT PERFORM DEMO ON AN " EASY" VALVE WHICH HAS TRADITIONALLY NOT BEEN A
" PROBLEM LEAKER" 9
NRC WILL WANT TO CONCENTRATE ON PAST PROBLEM AREAS AND PET PEEVES PLANT STAFF SHOULD REVIEW ALL NRC COMMENTS / PROBLEMS WITH PAST ILRTs AND ENSURE PROPER RESOLUTION EXAMPLE: VALVE LINEUP (BEFORE AND AFTER TESTING; CHECK PLANT HISTORY) l l
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3-4
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I KEY CONSIDERATlONS IN PEPARING PROGRAM i
G REVIEW PLANT DESIGN FOR INSPECTABILITY/ TESTABILITY 0
DETERMINE AREAS OF NONCOMPLlANCE WITH REGULATIONS, CODES, STANDARDS, E TC.
4 PREPARE EXEMPTION REQUESTS FOR APPENDIX J PROGRAM (TYPE A,8 & C TESTS)
I G
PREPARE RELIEF REQUESTS FOR ASME SECTION XI, CATEGORY A, VALVE TESTING G
DISCUSS MAJOR PROGRAM CONCEPTS / CHANCES WITH NRC EARLY IN DEVELOPMENT G
PERFORM DEVELOPMENTAL AND IMPLEMENTATION TASKS AS EARLY AS POSSIBLE 6
REDUCE EXCEPTIONS TO TESTING - COMPLETE PLANT MODIFICATlONS i
I 3-5 l
l SOME NRC POSITIONS _
S ANSI 56.8 - 1981 VS. ANSI N45.4 -1972 ANSI 56.8 IS NOT REQUIRED BY NRC FOR PLANTS BUILT TO ANSI N45.4 DEPENDING ON YOUR REGION, NRC STAFF MAY REQUIRE COMPLlANG WITH PORTIONS OF ANSI 56.8 l
NOTE: NRC PLANS TO ACCEPT ANSI 56.8 BY REG. GUIDE
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BECHTEL TOPICAL REPORT BN-TOP-l NRC DOES NOT LIKE SHORT DURATlON TESTING BUT...
NRC HAS (AND IS EXPECTED TO) ACCEPT THE SHORTENED ILRT ON A CASE BASIS l
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LLRT - ILRT SEQUENG CONSIDERATlON NRC RECOGNIZES THAT ILRT FAILURE "HAS TEETH" PUBLIC WILL BE PROTECTED IF INTEGRATED LEAKAG 15 "lN SPEC" l
NRC 15 CONSIDERING ILRT BEFORE LLRT TO DETERMlNE "AS FOUND" I
CONTAINMENT LEAKAG CONDITION REVISION TO 10CFR50 APPENDIX J CONTINUES i
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- - L,r ATTACHMENT B DUQUESNE LIGHT COMPANY Nuclear Group Vice President's Office October 3, 1985 Policy Statement Interactions with the Nuclear Regulatory Commission TO:
All Nuclear Group Personnel INTRODUCTION It has come to my attention that a vendor has conducted an industry training course during which the vendor indicated that industry advocated practices designed to mislead NRC inspectors by such tactics as being less than candid, selecting easy demon-strations and by manipulating NRC personnel into agreeing to accept test-results which may not fully satisfy the require-ments.
The tactics suggested by this vendor totally violate the policy of the Duquesne Light Company Nuclear Group with respect to interactions with the NRC.
Because of this incident, I believe that it is necessary to restate our policy' on inter-actions with the NRC.
POLICY It is the policy of the Duquesne Light Company Nuclear Group to cooperate with NRC personnel in the performance of their lawful duties.
Specifically:
1.
All employees shall provide information to the NRC when j
requested in an open, candid, responsive and j
professional manner.
I 2.
Properly authorized NRC personnel have the right to examine Nuclear Group records and obtain information i
which relates to any activity which falls within their 4
regulatory pervue.
Additionally, properly authorized NRC personnel have a right to witness any operation, process or test to determine conformance with requirements.
No employee shall alter schedules, operations, procedures, tests, facilities or equipment for the purpose of misleading NRC personnel into believing that such items are acceptable, when in fact they may not be.
6
$ f Policy Statement Page 2 3.
No employee should attempt to convince NRC personnel that an item meets requirements when that employee has facts which would prove otherwise.
4.
Strict compliance with NRC regulations and license conditions is required of every employee.
5.
If any employee becomes aware that this policy is not being adhered to or that any vendor or contractor advocates or advises policies which conflict with this policy, the employee should notify his supervisor or Nuclear Group management immediately.
J. J. Carey l
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