Information Notice 1979-35, Control of Maintenance & Essential Equipment
| ML031180205 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 12/31/1979 |
| From: | NRC/OI |
| To: | |
| References | |
| IN-79-035, NUDOCS 7910250510 | |
| Download: ML031180205 (10) | |
UNITED STATES SSINS No.: 6870
NUCLEAR REGULATORY COMMISSION Accessions Mo.:
OFFICE OF INSPECTION AND ENFORCEMENT 7910250510
WASHINGTON, -D.C. 20555 December 31, 1979 IE Information Notice No. 79-35
CONTROL OF MAINTENANCE AND ESSENTIAL EnUIPMENT
Description of Circumstances
Enclosed is a copy of a recent enforcement action against Duquesne Light Company.
A coDy of this action is being forwarded to all utilities with a power reactor
operating license or a construction permit. This is being done to apprise you of
a serious condition which revealed an apparent weakness in facility control of
maintenance and essential equipment.
You should review your existinq procedures and control for independent verification
of operability of redundant counterpart equipment when an essential component, subsystem, or system is determined inoperable. Operability is defined as follows:
A system, subsystem, train, component or device shall be OPERABLE or have
OPERABILITY when it is capable of performing its specified functionts).
Implicit in this definition shall be the assumption that all necessary
attendant instrumentation, controls, normal and emergency electrical power
sources, coolinq or seal water, lubrication or other auxiliary equipment
that are required for the system, subsystem, train, component or device
to perform its function(s) are also capable of performing their related
support function(s).
If you have any Questions reqardina this matter, please contact the Director of
the NRC Regional Office in which your facilities are located. No written response
to this IE Information Notice is required.
Enclosures:
1. Letter to Duguesne Light Company
from V. Stello, Jr., dtd. 12/5/79
2. Recently Issued IE Information
Notices
IE Information Notice No. 79-35 Enclosure
December ,31 1979
RECENTLY ISSUED
IE INFORMATION NOTICES
Information Subject Date Issued To
Notice No. Issued
79-34 Inadequate Desiqn of 12/27/79 All holders of power reactor
Safety-Related Heat OLs and CPs
Exchangers
79-33 Improper Closure of 12/21/79 All power reactor facilities
Primary Containment holdinc OLs and CPs
Access Hatches
79-32 Separation of Electrical 12/21/79 All power reactor facilities
Cables for HPCI and ADS holding OLs and CPs
79-31 Use of Incorrect Amplified 12/13/79 All holders of power reactor
Response Spectra (ARS) OLs and CPs
79-30 Reportinq of Defects and 12/6/79 All power reactor facilities
Noncompliance, 10 CFR Part 21. holding OLs and CPs and
vendors inspected by LCVIP
79-29 Loss of NonSafety-Related 11/16/79 All power reactor facilities
Reactor Coolant System holding OLs or CPs
Instrumentation During
Operation
79-28 Overloading of Structural 11/16/79 All power reactor facilities
Elements Due to Pipe Support with an OL or CP
Loads
79-27 Steam Generator Tube 11/16/79 All power reactor facilities
Ruptures At Two PWR holdinq OLs and CPs
Facilities79-12A Attempted Damane To New 11/9/79 All Fuel Facilities, Fuel Assemblies research reactors, and
power reactors with an
79-26 Breach of Containment 11/5/79 All power reactor facilities
79-25 Reactor Trips At Turkey 10/1/79 All power facilities with
Point Units 3 And 4 an nL or a CP
Docket No. 50-334 December 5, 1979
Duquesne Light Company
ATTN: Mr. Stanley G. Schaeffer
President
435 Sixth Avenue
Pittsburgh, Pennsylvania 15219
Gentlemen:
On November 27, 1979, the Beaver Valley Power Station, Unit 1, was operated
for about two (2) hours in a condition which exceeded the Limiting Conditions
for Operation.
This matter was brought to the attention of our inspector at your facility in
a timely fashion, and your subsequent action to correct the condition was
expeditious. Nevertheless, this condition rendered a part of the emergency
core cooling system (ECCS) unavailable for automatic start and injection of
coolant into the reactor coolant system (RCS) if the need had occurred concur- rent with the loss of offsite power (the design basis). This unavailability
of ECCS constitutes a serious matter which reveals an apparent weakness in
your control of maintenance and essential equipment. Therefore, we propose
to impose a civil penalty for the item of noncompliance set forth in Appendix A
to this letter in the amount of $5,000. Appendix B is a Notice of Proposed
Imposition of Civil Penalties. You are required to respond to this letter and
in preparing your response, you should follow the instructions in Appendices A
and B.
In addition to the civil penalty, we are issuing the enclosed Order (Appendix C)
effective Immediately. This Order requires that your administrative control
of licensed activities involving operating and maintenance of safety equipment
verifies availability of all required equipment when a counterpart is removed
from an operable status. This Order further requires that you formally review
and report your actions to prevent recurrence: It also requires that you meet
publicly on January 25, 1980, with the Director, Office of Inspection and
Enforcement, at a location near the Beaver Valley Power Station, to discuss
your evaluation of this conditon and your corrective actions to prevent
recurrence. We will inform you of the location and time of the meeting.
Duquesne Light Company -2 -
In accordance with Section 2.790 of the NRC's "Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures
will be placed in the Commission's Public Document Room.
Sincerely, Victor Stello, Jr.
Director
Office of Inspection
and Enforcement
Enclosure:
1. Appendix A, Notice of Violation
2. Appendix B, Notice of Proposed
Imposition of Civil Penalties
3. Appendix C, Order Modifying License
cc: C. N. Dunn, Vice President, Operations Division
F. Bissert, Technical Assistant Nuclear
R. WIashabaugh, QA Manager
J. Werling, Station Superintendent
G. Moore, General Superintendent, J. J. Carey, Nuclear Technical Assistant
R. Martin, Nuclear Engineer
APPENDIX A
NOTICE OF VIOLATION
Duquesne Light Company Docket No. 50-334 Pittsburqh, Pennsylvania 15219 License No. DPR 66 This refers to the inspection conducted by the NRC Resident Inspector at the
Beaver Valley Power Station, Unit 1, of activities authorized by NRC License
No. DPR 66.
During the inspection conducted on November 27, 1979, the following item of
noncompliance was identified.
Technical Specification 3.5.2 states that with the plant in Mode 1 (Power
Operation), two separate and independent ECCS subsystems shall be operable, and
further states in section 3.5.2.c that each subsystem shall include an operable
flow path caoable of taking suction from the refueling water storage tank upon
initiation of a safety injection signal.
Technical Specification 1.6 defines "operable" to include the assumption that all
necessary attendant instrumentation, controls, electric power, cooling or seal
water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable
of performing their related safety function(s).
Contrary to the above, on November 27, 1979, from approximately 8:30 a.m. to
10:30 a.m., maintenance activities rendered both ECCS subsystems inoperable in
that a) refueling water storage tank isolation valve MOV-CH-115D was closed and
incapable of automatic opening in response to a safety injection signal, and
b) refueling water storage tank isolation valve MOV-CH-115B, in the redundant
subsystem, was closed, had no emergency power available, and thus was incapable
of automatic opening In response to a safety injection signal if there had been
a condition of loss of offsite power.
This violation had the potential for causing or contributing to an occurrence
related to health and safety (Civil Penalty $5,000).
APPENDIX B
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES
Duquesne Light Company nocket No. 50-334 Pittsburgh, Pennsylvania 15219 License No. DPR-66 This office has considered the enforcement options available to the MRC
including administrative actions in the form of written notices of violation, civil monetary penalties, and orders pertaining to the modification, suspension
or revocation of a license. Based on these considerations, we propose to
impose civil penalties pursuant to Section 234 of the Atomic Energy Act of
1954, as amended, (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount
of Five Thousand Dollars ($5,000) for the specific items of noncompliance set
forth in Appendix A to the cover letter. In proposing to impose civil penal- ties pursuant to this section of the Act and in fixing the proposed amount of
the penalties, the factors identified in the Statements of Consideration
published in the Federal Register with the rule-making action which adopted
10 CFR 2.205 (36 FR 16894) August 26, 1971, and the "Criteria for Determining
Enforcement Action," which was sent to NRC licensees on December 31, 1974, have been taken into account.
Duquesne Light Company may, within twenty (20) days of the receipt of this
notice pay the civil penalties in the cumulative amount of Five Thousand
Dollars ($5,000) or may protest the imposition of the civil penalties in whole
or in part by a written answer. Should Duquesne Light Company fail to answer
within the time specified, this office will issue an order imposing the civil
penalties in the amount proposed above. Should Duquesne Light Company elect
to file an answer protesting the civil penalties, such an answer may (a) deny
the items of noncompliance listed in the Notice of Violation in whole or in
part, (b) demonstrate extenuating circumstances, (c) show error in the Notice
of Violation, (d) show other reasons why the penalties should not be imposed.
In addition, to protesting the civil penalties in whole or in part, such
answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR 2.205 should be set forth
separately from the statement or explanation in reply pursuant to 2.201, but
may incorporate by specific reference (e.g., giving page and paragraph numbers)
to avoid repetition.
Duquesne Light Company's attention is directed to the other provisions of
10 CFR 2.205 regarding, in particular, failure. to answer and ensuing orders;
answer, consideration by this office, and ensuing orders; requests for
hearings, hearings and ensuing orders; compromise, and collection.
Upon failure to pay any civil penalty due which has been subsequently determined
in accordance with the applicable provisions of 10 CFR 2.205, the matter may
be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section
234.c of the Atomic Energy Act of 1954, as amended (42 USC 2282).
APPENDIX C
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
In the flatter of )
DUOUESNE LIGHT COMPANY Docket No. 50-334 (Beaver Valley Power Station, Unit 1) )
ORDER MODIFYING LICENSE
EFFECTIVE IMMEDIATELY
I
The Duquesne Light Company (the "licensee") is the holder of Operating License
DPR-66 (the "license") which authorizes operation of the Beaver Valley Power
Station, Unit 1, at steady state reactor core power levels not in excess of
2652 megawatts thermal (rated power). The license was issued on January 30,
1976. The facility consists of a pressurized light water moderated and cooled
reactor (PWR), located at the licensee's site in Beaver County, Pennsylvania, on the southern shore of the Ohio River.
It
On November 27, 1979, from about 6:30 AM to 1:20 PM while the reactor was
operating at about 30% of rated power, Emergency Diesel Generator (EDG) 1 was
out of service for routine maintenance. This EDG supplies emergency power to
suction valve, MOV-CH-115B, in the line from the refueling water storage tank
(RWST) to the High Pressure Safety Injection System (HPSIS) pumps. In addition
to the EDG being out of service, resulting in loss of one Emergency Core
Cooling System (ECCS) flow path, as described above, the redundant suction
valve, MOV-CH-115D, was removed from service for maintenance which resulted in
loss of the redundant ECCS flow path from the RWST from 8:30 a.m. to 10:30 a.m.
During this time the facility was operated in noncompliance with the Limiting
Condition for Operation specified in Technical Specification 3.5.2.c. This
condition resulted from inadequate control of maintenance activities and its
Appendix C -2 -
occurrence suggests that the licensee has not adopted appropriate controls
to assure that maintenance activities do not defeat required safety features.
This in turn undermines the basis for determining that there is reasonable
assurance that redundant safety features will function under design basis
conditions. In view of the significance to safety of adequate controls to assure
that maintenance activities do not defeat required safety features, I have deter- mined that the public health, safety, or interest requires, effective immediately, modification of License No. DPR-66 as stated in Part III of this Order.
III
Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the
Commission's regulations in 10 CFR Parts 2 and 50, License DPR-66 is modified
as follows:
(1) Administrative Procedures shall be adopted and implemented to require
redundant independent verification of the operability of the remaining
engineered safety features whenever any safety system, or subpart
thereof, is intentionally removed from service.
(2) A detailed review of existing procedures and controls shall be performed
to assure that limiting conditions for operation are not defeated by
maintenance or other activities.
(3) A report of the administrative procedures required by paragraph (1) above
and the detailed review required by paragraph (2) above shall be submitted
by January 11, 1980, to the Director of NRC's Region I office.
Appendix C -3 -
(4) The licensee shall meet with the Director, Office of Inspection and
Enforcement, on or before January 25, 1980, in a meeting open to the
public in the vicinity of the Beaver Valley site to describe how the
above requirements will be implemented. The Director, Region I, will
inform the licensee at least one week in advance of the specific time and
location of the meeting.
IV
The licensee, or any other person who has an interest affected by this Order, may, within twenty-five days of the date of this Order, request a hearing. A
request for a hearing shall be addressed to the Director, Office of Inspection
and Enforcement, U.S.N.R.C., Washington, D.C. 20555. If a hearing is requested
by the licensee or an interested person, the Commission will issue an Order
designating the time and place of hearing. Such a request for hearing SHALL
NOT STAY THE IMMEDIATE EFFECTIVENESS OF THIS ORDER.
Resumption of operation on terms consistent with this Order is not stayed by
the pendency of any proceeding on this Order. In the event that a need for
further enforcement action becomes apparent, either in the course of any
proceeding on this Order or at any other time, the Director will take appro- priate action.
V
In the event the licensee or any other interested person requests a hearing as
provided above and a hearing is held, the issues to be considered at such a
hearing shall be:
Appendix C -4 -
(1) whether the facts set forth in Part II of this Order are correct;
and,
(2) whether this Order should be sustained.
FOR THE NUCLEAR REGULATORY COW2IISSION
Victor Stello, Jr.
Director
Office of Inspection and
Enforcement
Dated at Bethesda, Maryland
this 5th day of December, 1979.