ML20151N492

Notice of Deviation from Insp on 880201-05.Deviation Noted: Failure to Follow NRC Approved Procedures Generation Package

ML20151N492
Person / Time
Site:	Beaver Valley
Issue date:	04/14/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151N483	List: ML20151N476 ML20151N492 ML20151N506
References
50-334-88-02, 50-334-88-2, NUDOCS 8804250312
Download: ML20151N492 (2)

Text

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. NOTICE OF DEVIATICN Duquesne Light Company Docket No. 50-334 P.O. Box 4 License No. OPR-C6 Shippingport, Pennsylvania 15077 As a result of the inspection conducted on February 1-5, 1983 an apparent deviation was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actient," 10 CFR 2, Appendix C (Enforcement Policy) (1987), the apparent deviation is set forth below:

NRC Generic Letter 82-33 (GL 82-33) identified basic requirements for upgrading tLeir emergency response capabilities. Duquesne Light Company responded to one of the hsic requirements of GL 82-33, upgrading of their Emergency Operating Procedures, in letters dated June 28, 1934 and April 8, 1937. In these letters Duquesne Light Company committed to using an NRC approved Procedures Generation Package (PGP) for upgrading their E0Ps. The NRC approved PGP contains detailed instructions for the preparation of the Emergency Operating Procedures and Background Information.

Contrary to the above, as of February 5, 1933, many of Emergency Operating Procedures aid the Background Information did not adhere to the guidelines in the the PGP. Some examples of this daviation are as follows:

1. Contrary to PGP Appendix A Saction V.E.4.e, Step 7 of E0P ECA-0.0 uses the logic term IF NOT without speci fying a first condition by the use of an IF statement.

2. Contrary to PGP Appendix A Section V.H.2, Step 23 of E0P E-0 requires two transitions in the same step and uses "complete" to transition to other steps rather than the recommended term "G0 T0".

3. Centrary to PGP Appendix A Section V.F.1 and 6, E0P E-0 page 23 contains a "CAUTION" which lacks identification of the hazard and includes an action statement.

4. Contrary to PGP Appendix A Section V.B.1, Step 5.C of E0P E-3.1 uses two i ccmplex sentences which deal with more than one task in an action statement rather than using concise steps which deal with only one task.

5. Contrary to PGP Appendix B Section IV. A.4.e, the Step Description Tables in the Background Information do not include the benchboard identification of the instruments to be used.

Further examples are detailed in the attached inspection report (50-334/83-02).

This condition has been classified as a Deviation (10 CFR 2, Appendix C) applicable to CPR-66.

8804250312 080414 PDR ADOCK 05000334 O DCD

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Pursuant to the provisions of 10 CFR 2, Appendix C, paragraph E(2), Duquesne Light Company is hereby requested to submit to this of fice within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further deviations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending

this response time.

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