ML20137F359

Discusses Insp Repts 50-334/96-10 & 50-412/96-10 on 961222- 970208 & Forwards Nov.Violation Involved Failure by Staff on Numerous Occasions to Follow Procedures & Implement Appropriate Work Practices & Controls

ML20137F359
Person / Time
Site:	Beaver Valley
Issue date:	03/24/1997
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J DUQUESNE LIGHT CO.
Shared Package
ML20137F363	List: ML20137F359 ML20137F392
References
EA-97-076, EA-97-76, NUDOCS 9704010086
Download: ML20137F359 (4)

See also: IR 05000334/1996010

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EA 97-076

Mr. J. E. Cross, President *

j Generation Group  !

] Duquesne Light Company (DLC)

! Post Office Box 4

l Shippingport, Pennsylvania 15077

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SUBJECT

NOTICE OF VIOLATION

{ (NRC Inspection Report Nos. 50-334/96-10,50-412/96-10)

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. Dear Mr. Cross:

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j This letter refers to the NRC inspection conducted between December 22,1996, and February

8,1997 at the Beaver Valley Power Station facility, the findings of which were discussed with

{ you and members of your staff during exit meetings on February 18 and 19,1997. During

the inspections, apparent violations of NRC requirements were identified, as described in the

NRC inspection report sent to you with our letter, dated February 21,1997. On March 7,

!- 1997, a Predecisional Enforcement Conference was conducted with you and members of your

staff to discuss the violations, their causes, and your corrective actions. 3

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l Based on the information developed during the inspections, and the information provided  !

] during the conference, three violations are being cited and are described in the enclosed Notice

- of Violation. The violations involve (1) the failure by your staff, on numerous occasions, to

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follow procedures and implement appropriate work practices and controls, resulting in

, numerous valves and switches being in an other than normal position; (2) operators

l inadvertently deenergizing the waste gas decay tank (WGDT) oxygen analyzers because of

, operator error in that the operators misoperated the oxygen analyzer control switches, and  ;

also failed to monitor oxygen concentration when running the degassifier to the WGDT; and i

(3) failure to take appropriate corrective action, despite numerous configuration control

j deficiencies being identified in 1995, to ensure that the general problem of configuration

control, was adequately corrected. l

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j The NRC recognizes that the numerous 1997 examples of mispositioned valves and switches l

! were identified by your staff, and that you have demonstrated a low threshold for identifying

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component misconfigurations at Beaver Valley which have contributed to these findings.

Nonetheless, the NRC is concerned that broader corrective actions were not taken in 1995 to

! preclude recurrence of components being mispositioned. One of the recent findings of

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particular concern was the fact that operators and chemistry technicians were not properly

1 implementing station procedures when repeatedly depressurizing' the Unit 2 residual heat  !

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removal (RHS) system from January 23 to January 30,1997, resulting in the mispositioning

i of a RHS system sample valve. In that case, chemists also entered multiple procedures in

i parallel, each of which specified different positions for a specific component, which was not

1 permitted by station procedures. In another case, operators failed to properly implement

i station procedures when securing a component cooling water (CCR) pump in January 1997. I

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9704010086 970324

PDR ADOCK 05000334

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Specifically, the operators did not shut a CCR pump discharge valve and did not annotate  ;

system configuration drawings and procedures to reflect this change. Both of these examples

3 are of additional significance given that licensed personnel were involved in not adhering to ,

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station procedures. (

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At the enforcement conference, you acknowledged that inadequate work practices, not j

i implementing existing procedures, not implementing appropriate work controls, inadequate

j communications among the operations staff at shift turnovers, and procedural inadequacies

! contributed to these violations. Also, at the conference, you discussed a memorandum from '

l your Vice-President Operations, dated February 13,1997, entitled " Plant Valve -  ;

) Manipulation's," which informed your staff of the importance of precluding and correcting such

problems, noting that the improper valve manipulations are precursors to events which could

i lead to major plant problems. The NRC agrees. Given the number of recent examples of not 1

i maintaining appropriate configuration control at Beaver Valley, the repetitive nature of this  !

j- concern, and the inadequate work practices and work controls that contributed to these

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l problems, the violations collectively represent a potentially significant lack of attention toward  ;

r licensed responsibilities and therefore, have been classified in the aggregate as a Severity  ;

l Level 111 problem in accordance with the " General Statement of Policy and Procedure for NRC  ;

4 Enforcement Actions" (Enforcement Policy), NUREG-1600.

The violations are cited to emphasize the importance of strict adherence to procedural l

requirements to ensure components are in their proper position. _The violations also reveal the +

1 need for greater technical!nquisitiveness among your staff and the need for greater sensitivity

j to maintaining configuration control and promptly identifying and correcting when such control

is not maintained. With respect to identification, the NRC does commend the actions of the

operator who, while performing a tour of the facility, identified problems with an emergency ,

diesel generator governor cooling water outlet ball valve being in the wrong position. If not

i for his inquisitiveness, this problem likely would have remained undetected and uncorrected. l

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You should continue to encourage similar inquisitiveness by all your staff.

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in accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is

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considered for that Severity Level lli violation' or problem. Your facility has been the subject

j of escalated enforcement actions within the last 2 years (for example, a Severity Level 111

violation without a civil penalty was issued on September 11,1996,for failure to comply with

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10 CFR 50.62(c)(1), in that, the ATWS Mitigation System Circuitry (AMSAC) had not been

designed to perform its function in a reliable manner (EA 96-244)). Therefore, the NRC

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considered whether credit was warranted for /dentification and Corrective Action in

! accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement

l Policy. Credit is warranted for identification because the violations were identified by your

j staff. Credit is also warranted for corrective actions. Important in this regard are steps you

have taken to strengthen station corrective action processes to address broader performance

! issues. These actions include establishing a lower threshold for identifying and documenting

j problems, strengthening self-assessment efforts, and increasing management involvement in

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' On November 12,1996, the base civil penalty amounts for Severity Level 111 violations

j or problems changed from $50,000 to $55,000. Since these violations occurred after

l November 12,1996, the base amount for this Severity Levelill problem is $55,000.

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Duquesne Light Company 3

verifying effectiveness of corrective actions. Other actions, specific to the configuration

control violation, included, but were not limited to: (1) enhancing the number of system

lineups to be performed to assure appropriate positioning of the valves; (2) having your ISEG

group perform a review of the identified deficiencies to evaluate performance trends; (3)

issuing a memorandum to all staff emphasizing the importance of appropriate adherence to

procedures, as well as providing an additional letter to operations personnel for further

emphasis; (4) reviewing all valves to ensure proper positioning and immobilizing certain valves;

(5) instituting a process for discussion of all Condition Reports at the routine morning

meetings; (6) revising procedures and logs to ensure oxygen concentration is monitored when -

sending gas to the WGDT; (7) initiating a procedure validation project to ensure procedures

return components to their normal position or effectively track exceptions; and (8) evaluating

work around activities at the station to determine areas where components are particularly

vulnerable to inadvertent operation.

Therefore, to encourage prompt and comprehensive identification and correction of violations,

I have been authorized, after consultation with the Director, Office of Enforcement, not to

propose a civil penalty in this case. However, significant violations in the future could result

in a civil penalty. The NRC did consider whether to exercise discretion and issue a civil

penalty in this case, given the involvement of licensed staff in some of these findings.

However, the NRC has decided not to exercise such discretion in light of your aggressive

corrective actions, and in recognition of the broader changes ongoing at Beaver Valley to more

aggressively identify problems and improve overall performance. The NRC recently issued a

$160,000 civil penalty to you on March 10,1997, for, in part, a violation that involved a

valve being in the wrong position for several years despite prior opportunities to identify and

correct th;s condition. Similar findings of inadequate configuration control in the future could

result in additional enforcement action.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, and

its enclosure, and your response, will be placed in the NRC Public Document Room (PDR).

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Sincerely, ~

H ert J. Miller

Regional Administrator

Docket Nos. 50-334; 50-412

License Nos. DPR-66; NPF-73

Enclosure: Notice of Violation

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!. Duquesne Light Company 4 l

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ec w/ encl-

i S. Jain, Vice President, Nuclear Services  !

R. LeGrand, Vice President, Nuclear Operations l

L. Freeland, Manager, Nuclear Engineering Department  !

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B. Tuite, General Manager, Nuclear Operations Unit

i K. Ostrowski, Manager, Quality Services Unit

R. Brosi, Manager, Nuclear Safety Department i

M. Clancy, Mayor -

Commonwealth of Pennsylvania  ;

State of Ohio

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Duquesne Light Company

DISTRIBUTION:

PUBLIC

SECY

CA

LCallan, EDO

EJordan, DEDO

JLieberman, OE

HMiller, R1

FDavis, OGC

SCollins, NRR

RZimmerman, NRR

Enforcement Coordinators  !

Rl, Ril, Rill, RIV

BBeecher, GPA/PA

GCaputo, Ol

DBangart, OSP

HBell, OlG

Dross, AEOD

RPedersen, OE

OE:EA (2 copies) (Also by E-Mail)

NUDOCS

DScrenci, PAO-RI

NSheehan, PAO-RI ,

Nuclear Safety information Center (NSIC) j

Resident inspector - Beaver Valley i

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