ML20198Q877
| ML20198Q877 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/12/1998 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| 50-334-97-07, 50-334-97-7, 50-412-97-07, 50-412-97-7, NUDOCS 9801230159 | |
| Download: ML20198Q877 (2) | |
See also: IR 05000334/1997007
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January 12, 1998
Mr. J. E. Cross
President
Generation Group
Duquesne Light Company
Post Office Box 4
Shippingport, Pennsylvania 15077
SUBJECT:
INSPECTION REPORT NOS. 50-334;412/97-07- REPLY
Dear Mr. Cross:
This letter refers to your December 8,1997, correspondence, in response to our
November 7,1997, letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions wil be *pmined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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Peter W. Eselgroth, Chief
Project Branch 7
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Division of Reactor Projects
Docket Nos.50-33e. , 50-412
cc:
Sushil C. Jain, Vice President, Nuclear Services
R. LeGrand, Division Vice President, Nuclear Operations Group & Plant Manager
W. Kline, Manager, Nuclear Engineering Department
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B. Tuite, General Manager, Nuclear Operations Unit
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M. Pergar, Acting Manager, Quality Services Unit
J. Arias, Director, Rafety F. Licensing Department
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J. MacDonald, Manager, System and Performance Engineering
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M. Clancy, Mayor
Commonwealth of Pennsylvania
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State of Ohio
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State of West Virginia
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Mr. J. E. Cross
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Distribution:
Region i Docket Room (with concurrences)
PUBLIC
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
W. Axelson, DRA (irs)
P. Eselgroth, DRP
D. Haverkamp, DRP
N. Perry, DRP
A. Linde, DRP
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W. Dean, OEDO
R. Correia, NRR
F. Talbot, NRR
DOCDESK
Inspecti,n Program Branch, NRR (IPAS)
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- DOCUMENT NAME: G:\\ BRANCH 7\\BV9707. REP
T3 receive a copy of this document. Indicato in the box: 'C' = Copy without attachment / enclosure
- E' = Copy with attachment / enclosure
- N" = No
copy
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OFFICIAL RECORD COPY
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Beavet Vaney Power Station
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SNppingport. PA 15077 0004
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(412) 393 6512
(Mason Yke Presiders
December 8,1997
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U. S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555 0001
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 50-334/97-07 and 50-412/97-07
Reply to Notice of Violation
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5 response to NRC correspondence dated November 7,1997, and in accordance
with .0 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with
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C subject inspection report,
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If there are any questions concerning this response, please contact Mr. J. Arias at
(412)393-5203.
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Sincerely,
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Sushil C. Jain
Attachment
c:
Mr. D. S. Brinkman, Sr. Project Manager
Mr. P. W. Eselgroth, Chief, Reactor Projects Branch No. 7, Region I
Mr. C. W. Hehl, Director, Division of Reactor Projects
Mr. D. M. Kern, Sr. Resident Inspector
Mr. H. J. Miller, NRC Region I Administrator
BEllVERING
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Q U A L I T4
EllER-G'Y
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DUQUESNE LIGHT COMPANY
Nuclear Power Division
Beaver Valley Power Station, Unit Nos. I and 2
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Reply to Notice of Violation
Integrated Inspection Report 50-334/97-07 and 50-412/97-07
Letter Dated November 7,1997
VIOLATION (Severity Level IV, Supplement I)
Description of Violation (50-334(412)/97-07-02)
10 CFR 50.54(a)(3) requires, in part, that changes to the quality assurance program
description that reduce the commitments (in the program description previously accepted
by the NRC) be submitted to the NRC and receive NRC approval prior to
implementation.
Contrary to the above, in April 1994 the licensee changed the quality assurance program,
resulting in a reduction in commitments in the quality assurance program description
previously accepted by the NRC without prior NRC approval. Specifically, the licensee
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realigned the Quality Control receipt inspectors from the Quality Services Unit to the
procurement department. This organizational change reduced the authority and
organizational freedom of the quality control organization performing procureme it
receipt inspections.
Reason for the Violation
In January 1994, prior to the Quality Control personnel who were perfonning receiving
inspections being reassigned to Nuclear Procurement, the Quality Services Unit (QSU)
performed a review of the QA Program description contained in Unit 2 UFSAR, Sectim
17.2 and determined that a 10 CFR 50.54(a)(3) evaluation was not required. Tids was
based on the Unit 2 UFSAR Section 17.2 not containing any details identifying to whom
the inspectors performing receiving inspections reported and the proposed change not
requiring any rewordi6g of that section.
- This Unit 2 UFSAR section contained the QA Program description applicable for both
Units 1 and 2, which was submitted to the NRC in 1988 for approval. The proposed
chang did not require any rewording of this QA Program description for the Beaver
Valley Power Station contained in the Unit 2 UFSAR Section 17.2. It was QSU's
understanding that only actual wording changes to this Unit 2 UFSAR section or to the
UFSAR positions on QA related Regulatory Guides needed to be reviewed for potential
reductions to the QA Program description commitments under 10 CFR 50.54(a)(3). It
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Reply to Notice of Violation
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Inspection Report 50-334/97 07 and 50-412/97-07 '
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. was not believed that a change to the Unit 2 UFSAR Chapter 13 could reduce the QA
Program description commitments.
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Corrective Actiom Taken and the Results Achieved
1The QSU performed a 10 CFR 50.54(a)(3) evaluation regarding the reassignment of the
Quality Control receiving inspection function from QSU to the Nuclear Procurement
Depaitment, which occurred in April 1994. This evaluation was completed on~ October :-
10,1997, and concluded that this reassignment of personnel was a reduction in
commitments to the NRC Following this determination,' and also on October 10,1997,
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the Vice President, Nuclear Services issued a letter (NPDSVP:7934) which effective .
immediately and until further notice, functionally reassigned the Quality Control -
receiving inspection function to the Manager, QSU.
Corrective' Actions to Prevem Funher Violations
The following additional corrective actions wiu be implemented:
The root cause evaluation for this event will be reviewed with the Quality Services
Unit personnel responsible for performing 10 CFR 50.54(a)(3) evaluations. This will
be completed by December 22,1997.
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.'A review of organizational changes related to the Quality Assurance Program,
including transfer of personnel or responsibilities from QSU to otlar organizations,
which occurred after January 1994 will be performed. This is the period when--
certain changes to QA processes were implemented to more effectively utilize
resources. - This review will identify if any additional 10 CFR 50.54(a)(3) evaluations
are required and will be completed by February 28,1998.
A'dditional reviews of UFSAR sections (other than the Unit 2 UFSAR, Section 17.2)
will be ' performed to determine if there are other instances 'vhere changes to those
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- sections could potentially result in a reduction in commitments in the Quality
- Assurance Program description. These reviews will be completed by March-31,
1998. Should any additional instances be identified Condition Reports will be
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written.
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e J R' vise procedure NPDAP 7.3, " Annual Final Safety ' Analysis Report Update" to
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ensure the question of whether a proposed change to the UFSAR can result in a
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reduction in commitments in'the_ Quality ' Assurance Program description is addressed.
5This revision will be completed by May 29,- 1998.
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- Reply to N:: ice of Violati:n
Inspection Report 50-334/97-07 and 50-412/97-07
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Develop and implement a process tc review organizational changes prior to
implementation to ensure licensing documents and commitments are not affected.
- This will be completed by June 30,1998.
Date When Full Compliance Will Be Achieved
With the reassignment of the Quality Control receiving inspection function to the
Manager, QSU on October 10,1997, the issue of the requirement to submit a 10 CFR 50.54(a)(3) evaluation to the NRC was resolved and full compliance was achieved.
No other issues of non-compliance have been identified.- If the additional corrective
actions identify any new issues of potcntial non-compliance, appropriate corrective
- actions will be implemented.
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