ML20236K437

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Responds to NRC Re Violations Noted in Insp Rept 50-412/87-20.Corrective Actions:Revised Method of Work Control Placed Into Effect & All Const Work Presently Authorized & Controlled Through Work Package Sys
ML20236K437
Person / Time
Site: Beaver Valley
Issue date: 07/24/1987
From: Sieber J
DUQUESNE LIGHT CO.
To: Johnston W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
2NRC-7-179, NUDOCS 8708070119
Download: ML20236K437 (4)


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? 1+' -2NRC-7-179 July 24, 1987

'Af5 Ducluesne@

Be Vall o. 2 Unit Project Organization Telecopy (41 ) 64 2 Ext.160 P.O. Box 328 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region I 631 Park Avenue

. King of Prussia, PA 19406 ATTN: Mr. Wiiliam V. Johnston, Acting Director Division of Reactor Safety

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-20

REFERENCE:

1) Letter dated June 16, 1987, (W. V. Johnston to J. J. Carey)

Gentlemen:

The above referenced letter transmitted a Notice of Violation as Appendix A. Attachment 1 of this letter provides Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Violation. As requested in your letter, our response focuses on corrective actions taken to avoid similar problems in the future.

DUQUESNE LIGHT COMPANY By AILk

// J. D. Sieber

(/ Vice President Nuclear DLC/ijr NR/DLC/IR/8720 Attachments AR/NAR cc: Mr. P. Tam, Project Manager (w/ a/s)

.Mr. J. Beall, NRC Sr. Resident Inspector (w/a/s)

Mr. L. Prividy, NRC Resident Inspector (w/ a/s)

INP0 Records Center (w/a/s)

NRC Document Control Desk (w/a/s) 8708070119 s70724 PDR ADOCK 05000412 O PDR um

United States Nuclear Regulatory Commission Mr. William V. Johnston, Acting Director Inspection Report 50-412/87-20 Page 2 bcc: J. J. Carey - w/ attachment C. E. Ewing - w/ attachment J. A. Hultz - w/ attachment-R. J. Druga - w/ attachment i K. D. Grada - w/ attachment T. P. Noonan - w/ attachment I M. J. O'Neill - w/ attachment I S. C. Fenner - w/ attachment C. Richardson (S&W)(5) - w/ attachment J. Sutton (S&W) - w/ attachment A. A. Dasenbrock, SWEC - w/ attachment R. Anstey, SWEC - w/ attachment R. Wittschen, SWEC - w/ attachment l - w/ attachment i J. M. Grigsby (~W)

C. ' Maj umd ar - w/ attachment BV-2-NCD-SEG/ Phase II PUC Audit - w/ attachment Distribution PDR-378 (4)

Inspection 87-20 File - w/ attachment NCD File - w/ attachment

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L ATTACHMENT 1 VIOLATION 87-20-01 The Notice of Violation states, in part:

1 10CFR50, Appendix B, Criterion X states in part "A program for inspection of activities affecting quality shall be established and implemented by or for the organization performing the activity to verify con 7ormance with the documented instructions procedures, and drawings for accomplishing the activity. . . .

During the NRC inspection conducted between March 16 and 26, 1987 the following ex amples of failure to implement quality control procedures affecting safety related inspections were identified. . .

. . . . This is a Severity Level V Violation.

Response

As noted in Mr. W. V. Johnston's letter which accompanied the report, the 12 examples of minor problems identified by the NRC were corrected during the course of the inspection.

We concur with the NRC assessment that several of these problems may possibly be the result of unauthorized rework. In this regard, we wish to state that, with the onset of the Operational Phase, a revised method of controlling work'has been placed into effect.

All construction work is presently authorized and controlled through a work package system which defines the areas, and the items in those areas which may be worked. Based upon our experience with this method of controlling work at BV-1, we believe that the possibility for unauthorized rework is greatly reduced.

T h e Director of Quality Control has issued a memo to all QC personnel, via training update, in which the aspects of Violation 87-20-01 are discussed.

In this memo, the importance of maintaining diligence and attention to detail during inspections is emphasized. As it is the practice of DLC to engage QC inspectors who are certified in a number of activities, often in multi-disciplines, personnel have been directed to remain cognizant of their own limitations in recalling details applicable to a variety of inspection procedures. ,

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Procedure SQC-1.4, which provides instruction for the issue and control of QC procedures, . permits controlled copies of individual procedures to be issued to inspectors for reference in the field. Personnel have been l encouraged to use this program to frequently refer to the text of the inspection procedure during the course of each inspection.

Our QA Auditing Group has endeavored to be responsive to NRC comments and j suggestions which have been expressed during Inspections 86-47, 87-02, 87-03 and in the recent SALP Report.

In our response to the SALP Report, we outlined three plans of action  !

which are being implemented to improve our QA program.

Our development of recent audit p1ans has emphasized increased involvement l with the process and physical performance of the audited activity. It is our intention to maintain this emphasis and to continue to look for new ways to enhance and improve the effectiveness and benefits of our auditing program.

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