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Discusses Insp Repts 50-334/97-01,50-412/97-01,50-334/97-02 & 50-412/97-02 on 970209-0426 & Nov.Violations Involve Failure to Comply W/Ts Requirements for Surveillance Testing of Safety Equipment
	ML20141G991
Person / Time
Site:	Beaver Valley
Issue date:	07/03/1997
From:	Miller H; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J; DUQUESNE LIGHT CO.
Shared Package
ML20141G995	List: ML20141G991; ML20141G997;
References
	50-334-97-01, 50-334-97-02, 50-334-97-1, 50-334-97-2, 50-412-97-01, 50-412-97-02, 50-412-97-1, 50-412-97-2, EA-97-255, NUDOCS 9707140222
	Download: ML20141G991 (5)
	v • d • e

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July 3, 1997' [

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l EA 97-255

Mr. J. E.' Cross, President '

Generation Group i

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Duquesne Light Company (DLC)

Post Office Box 4 l

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Shippingport, Pennsylvania 15077 j

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SUBJECT: NOTICE OF VIOLATION l

(NRCinspection Report Nos. 50-334/97-01,50-412/97-01,50-334/97 02, and !

50-412/97-02) i

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Dear Mr. Cross: l

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This letter refers to the NRC inspections conducted between February 9,1997, and April 26,

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 March 27 and May 7,1997. During

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

NRC inspection report sent to you with our letter, dated May 23,1997. In a telephone

, conversation between you and Mr. Peter W. Eselgroth of my staff on May 21,1997, Mr.

! Eselgroth indicated that it was not necessary to conduct a predecisional' enforcement

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conference (conference) in order to enable the NRC to make an enforcement decision.

However, you stated your preference to have a conference. On June 13,1997, a conference

was conducted with Mr. Ron L. LeGrand and other members of your staff to discuss the

l violations, their causes, and your corrective actions.

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

[ during the conference, six violations are being cited and are described in the enclosed Notice

l of Violation. The violations involve the failure to comply with Technical Specification (TS).

requirements for surveillance testing of safety equipment, namely (1) emergency diesel

generators (EDGs); (2) reactor coolant system (RCS) pressure isolation valves (PlVs); (3)

, hydrogen recombiners; (4) reactor protection system (RPS) and engineered safety feature

l actuation system (ESFAS) logic and interlocks; (5) control room emergency bottled air

pressurization subsystem (CREBAPS) discharge trip valves; and (6) boron injection flowpaths, i

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The large number of inadequate surveillance tests identified within a relatively short period of l

time indicated weaknesses in your surveillance test program, particularly in the areas of

scheduling, coordination, and procedural development. For example, a combination of

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procedural deficiencies and scheduling errors led to the failure to properly verify the integrity l

! of the hydrogen recombiner heater circuitry. Additionally, after the improper testing was

j identified, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period allowed by TSs for completion of the missed testing was

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Duquesne Light Company 2

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exceeded due to poor communications and coordination between operations, maintenance and

engineering and a plant shutdown had to be initiated. At the enforcement conference, your

staff acknowledged that inadequate management oversight and control of the TS surveillance

program was the root cause of the violations, and that weaknesses in procedures, scheduling,

coordination, and communications were contributing factors. 1

Surveillance testing requirements are designed to detect inoperable safety equipment and

ensure the proper operation of the equipment within expected tolerances. Although all of the

affected safety equipment was found to be operable during subsequent testing, the number l

of inadequate tests identified, as well as the program weaknesses that led to the inadequacies,

l represent a significant regulatory concern because surveillance tests and the interval for l

conducting them are designed, based on risk,to ensure thatinoperable or degraded equipment

is promptly identified. Given this potentially significant lack of attention toward licensed

responsibilities, the violations have been classified in the aggregate as a Severity Level lli

problem in accordance with the " General Staternent of Policy and Procedure for NRC

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

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

considered for a Severity Levellli violation or problem. Your facility has been the subject of

escalated enforcement actions within the last 2 years'; therefore, the NRC considered

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whether credit was warranted for Identification and Corrective Action in accordance with the

civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is

warranted for identification because the violations were identified by your staff. Important in

this regard is the improved questioning attitude demonstrated by your staff in identifying these

violations, most of which were longstanding issues, and some of which were subtle in nature.

Credit is also warranted for corrective actions. In all cases, prompt action was taken to retest

the affected equipment and, while the staff found that your initial root cause analyses for

some of the individual violations were narrowly focused and did not adequately assess

, programmatic weaknesses, ultimately your corrective actions were comprehensive. These

l actions included, but were not limited to: (1) performing an assessment of TS surveillance

sequencing; (2) reviewing existing surveillance test procedures to assure they adequately

implement TS and other requirements; (3) ensuring that all new test procedures and procedure

revisions are reviewed by the system and performance engineering department; (4)

establishing a single point of contact for coordination and scheduling of surveillances; and (5)

reemphasizing operations department accountability and ownership of the surveillance test

program.

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.

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' e.g., a Notice of Violation was issued to Duquesne Light Company on March 24,1997,

for a Severity Level lli problem related to configuration control (EA 97-76).

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Duquesne Light Company 3

l You are required to respond to this letter and should folic,e tile instructions specified in the

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

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determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

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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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l Sincerely, '

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Hu ert J. Mi er '

Regional Administrator 6

l Docket Nos. 50-334; 50-412

l License Nos. DPR-66; NPF-73

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Enclosure: Notice of Violation

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Duquesne Light Company 4 ;

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cc w/ encl: f

l S. Jain, Vice President, Nuclear Services >

! R. LeGrand, Division Vice President, Nuclear Operations ;

W. Kline, Manager, Nuclear Engineering Department '

B. Tuite, General Manager, Nuclear Operations Unit ' ;

K. Ostrowski, Manager, Quality Services Unit

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l J. Arias, Director, Safety and Licensing Department

M. Clancy, Mayor ,

Commonwealth of Pennsylvania !

State of Ohio

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! Duquesne Light Company ;

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DISTRIBUTION:

PUBLIC

SECY

CA

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l LCallan, EDO

j EJordan, DEDO

l .JLieberman, OE

l HMiller, RI :'

l FDavis, OGC

l SCollins, NRR i

RZimmerman, NRR i

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Enforcement Coordinators

j Rl, Ril, Rlli, RIV

i BBeecher, GPA/PA

l GCaputo, 01

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DBangart, OSP !

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HBell, OlG ;

l Dross, AEOD

l DNelson, OE .

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

l NUDOCS

l DScrenci, PAO-RI

l NSheehan, PAO-Rl

! Nuclear Safety Information Center (NSIC) ;

l Resident inspector - Beaver Valley ;

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, To receive a copy of this document, indicate in the box: "C" - Copy without

I attachment / enclosure "E",- Copy with attachment /enclostre "N" - No c_opy

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0FFICE RI:0RA /t /]/ RI:DRP, _ l RI:RC #(,&1 RI:F/y//z I

NAME TWalker/mfc 7 CHehl A/ U M / BFewel'1JV HM K gr' 'V

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DATE D /$3/97 7 / / /97 7 / 1 /974 q /3 /97

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ML20141G991

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