ML20234C486
| ML20234C486 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/15/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8707060502 | |
| Download: ML20234C486 (6) | |
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'Af Telephone (412) 393-6000 Nuclear Group SnippSnlp' ort, PA 15040004 June 15, 1987 U.
S. Nuclear Regulatory Commission Region 1 631 Park Avenue King.of' Prussia, PA 19406 ATTENTION:
Mr. William T. Russell Regional Administrator
Reference:
Beaver Valley Power Station, Units No. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-66 Systematic Assessment of Licensee Performance (SALP) Report Nos. 50-334/85-98 & 50-412/86-99
Dear Mr. Russell:
This letter provides Duquesne Light Company comments on the Systematic Assessment of Licensee Performance for Beaver Valley Units 1
and 2 (Reports 50-334/85-98 and 50-412/86-99).
We have thoroughly reviewed both reports arid enrefully considered NRC comments discussed at the SALP meeting conducted on June 5, 1987.
In
- general, we find the facts presented in both reports to be accurate except for five areas noted later in this response.
- Further, we have considered the ratings and recommendations contained in the reports, and we plan to take appropriate remedial actions for those areas where further improvements are indicated.
We share the NRC's concern that our Quality Assurance Program should be more aggressive, and we plan to take additional measures to improve the usefulness of the Quality Assurance Unit as a management tool.
Notwithstanding deficiencies in the effectiveness of the Quality Assurance
- program, we believe that it is important to emphasize that the attitude of the workforce and supervision toward quality is
- good, that Unit 2 is a well constructed plant with high quality components and workmanship, and that Unit 1 is operated and
-maintained in'such a way as to indicate our organization's dedication to quality.
Our specific comments on each of the reports are included as an attachment to this letter.
Very tru y yours, pfj7060502870615 G
ADOCK 05000334-PDR Carey Senior Vice President Nuclear Group I Cr 40 l{g
F I
ATTACHMENT I SALP Report No. 50-334/85-98 and 50-412/86-99 Beaver Valley Units 1 and 2 The following are Duquesne Light Company's comments on the above-captioned reports.
Radiological Controls, Page 12, first paragraph - Contrary to the statement in the referenced paragraph, there has been a full-time person assigned to coordinate and perform activities associated with the ALARA program.
An additional person was assigned to ALARA duties during refueling outages.
In
- addition, Beaver Valley was cited as the PWR having the best worker radiation exposure record in the country in 1985.
Additionally, declining exposure rates, overall, are indicative of management involvement.
Aggressive person-rem budgets were established for 1985 and 1986.
The budgets and actual dose data are shown below:
Budget (rem)
Actual (rem) 1985 70 (non-outage) 60.5
-13.6%
1986 570 (outage) 627.0
+10%
During the 1986
- outage, approximately 100 rem was expended on unplanned tasks, i.e.,
o 100% Eddy current 3 steam generators - 40 rem o
MOV-RC-591A Valve repair - 20 rem o
Tube expansion "A" Steam Generator - 20 rem o
Increased Secondary Steam Generator Inspection - 20 rem Extensive ALARA planning reduced overall total dose for the unplanned tasks.
Excluding the dose received from the unplanned
- tasks, the 1986 actual dose would have been 527 rem or 7.5% under budget.
Radiological Controls, Page 13, first paragraph - The shipment of two drums discussed in this paragraph did not contain radwaste as indicated, but contained contaminated
- tools, which were being shipped off site to a vendor's facility for decontamination and return to the site for further use.
Surveillance, Page 19, 4th paragraph, line 3 - The reference to
" Quality Control" personnel should be changed to
" Quality Assurance" personnel.
ATTACHMENT I Page 2 Licensing, Pages 33 and 34 - We have reviewed the performance of our licensing effort during this SALP report period.
While our overall goals of operating Unit 1 safely and reliably and the completion and startup of Unit 2 required the reassignment of two key licensing personnel, we believe that our performance in this area was consistent with performance during prior SALP periods.
Our records indicate that there was increased activity in the licensing
- area, as indicated by the increase in the number of Technical Specification amendments prepared and submitted and substantial progress in the closecut of I and E open items.
We further believe that work on the Unit 2
draft technical specifications and the review associated with the control room wall removal required the expenditure of substantial additional time and effort on the part of Unit 1 licensing personnel, providing an additional burden on the limited resources available at that time.
We believe that the Technical Specification review activities for Unit 2
caused an increase in work load and a diversion of resources which taxed our ability to resolve the many unique and complex issues which arose during this period.
We further believe that the technical content of our submittals have been of high quality even though a few submittals have been more timely.
We further believe that as Unit 2 receives its full power license and licensing activities for both units are consolidated under one licensing organization, that sufficient resources will be available to conduct licensing activities properly in the future.
Therefore, it is our opinion that the " Declining" rating is not warranted.
We
- will, however, monitor this program to assure th&t performance improves in this area.
Training and Qualification Effectiveness, Page 36, Recommendation Duquesne Light Company will review the content and quality of our operator candidate screening process, our pre-license audit examinations and NRC licensing and requalification examinations to determine if appropriate and consistent standards are applied throughout the operator training program.
Assurance of Quality
- References to quality assurance are made in several sections of both SALP reports; however, the comments are summarized in the cover letter by the statement
- that,
.... quality assurance is not being effectively used as a
management tool to enhance performance.
As discussed at the SALP
- meeting, Quality Assurance is actively involved in many areas of both Beaver Valley units.
Some of the areas in which Quality Assurance has been involved are listed on Attachment II to this letter.
j
ATTACHMENT I Page 3 Assurance of Quality (continued)
In order to more effectively utilize Quality Assurance, Duquesne Light is proposing three additional action plans which will be implemented to improve this area:
1.
A full-time QA surveillance program has been developed and implemented (effective 5/1/87) for BV-1.
The present QA surveillance program for BV-2 will be continued into the operating phase.
2.
A review of programs, in addition to the 10CFR50 Appendix B quality assurance
- program, has been initiated to determine where improvements can be made and what additional programs can be implemented to improve plant reliability.
The results of this review will be submitted to management for their review and approval by August 31, 1987.
3.
A Management Quality Review
- Program, similar to the BV-2 Quality Improvement Management Program will be initiated, which will review quality performance indicators, assess causes for adverse performance trends and institute appropriate corrective action for performance improvement.
This program will be implemented by November 30, 1987.
ATTACHMENT II Special Projects, Audits or' Investigations 1.
Performed independent evaluation of reactor trips on Beaver Valley Unit No. 1 2.
Study of accessibility of plant areas during emergencies.
3.
Conducted investigation into "C" Reactor Coolant Pump cover problem for Beaver Valley Unit No. 2.
4.
Provided independent observers for EPP drills.
5.
Provided member for Appendix R Task Force.
6.
Conducted 100%
surveillance of Beaver Valley Unit No. 1 split pin replacement.
7.
Presently performing a
review of Beaver Valley Unit No. 2-Technical Specification surveillance.
8.
Coordinated Beaver Valley Unit No. 2 investigation of Joseph Oats Regenerative HX problem.
9, Evaluated records storage facility compliance to N45.2.9 requirements.
10.
Participated in Radwaste Packaging and Shipping Task Force.
11.
Coordination of Cooperativo Management Audit Program.
12.
Review inspection, surveillance and audit aspects of IE Notice 85-19.
13.
Investigate cause of damage to MSIV.
14.
Records Task Force.
15.
Audit of ECORAM activities BV-2 SG Eddy Current Test of rerolled tubes and sample of shot peened tubes.
16.
Audit of Detroit Edison for procurement of electrical cable.
17.
Audit of personnel background checks at solid Waste I
Management Services.
18.
Audit Power Piping (Donora) for weld filler metal control (S&W did not have a TL available).
19.
Quality Concern (hotline) DCP documentation review.
20.
Audit of QCR Program.
21.
ORRT - DSB co-member.
' ATTACHMENT II.
Page 2 22.
Audit of DCP 766, Control Room Wall Removal.
23.
QA Manual review of Buffalo Forge for NERU to justify waiving requirement for approval of the manual as specified L
(Copy of S&W Spec.)
{
24.
Quality Concern Response - Unit #1 Battery Room.
j i
25.
Chlorine Detector - documentation problem.
l 26.
Develop QA "NRC Assessment of Quality - BV-2" for the NRC Operating License.
27.
Control Room Design review audits - 1984, 1985 28.
Review and assessment of RIs and their use - 1983.
29.
Assessment of Victoreen Instrument Company - 1983.
30.
Random Sampling Program Monitoring and Auditing.
31.
Audit of Security Prior to BV-2 Lockdown.
.