ML20147F127
| ML20147F127 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20147F113 | List: |
| References | |
| EA-96-462, EA-96-540, NUDOCS 9703200045 | |
| Download: ML20147F127 (5) | |
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ENCLOSURE F
NOTICE OF VIOLATION AND l
PROPOSED IMPOSITION OF civil PENALTIES Duquesne Light Company (DLC)
Docket Nos. 50-334; 50-412 Beaver Valley Power Station License Nos. DPR-66; NPF-73 EAs 96-462: 96-540 i
i During NRC inspections conducted between September 29 and December 21,1996, and for which exit meetings were held on November 29,1996, and January 2,1997, violations of l
3 NRC requirements were identified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions, NUREG-1600, the NRC proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are j
set forth below:
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VIOLATIONS RELATED TO DEFICIENCIES IN REACTOR HEAD VENT SYSTEM LEAK SEALANT REPAIRS A.
10 CFR Part 50, Appendix B, Criterion 11, Quality Assurance Program, requires, l
in part that the quality assurance program provide control over activities y
affecting the quality of structures, systems, and components, to an extent consistent with their importance to safety.
i Contrary to the above, on or about December 2,1996, the licensee did not l
provide control of activities affecting the quality of the reactor head vent system (HVS) in that quality control oversight and hold points to verify key parameters prior to implementation of the leak sealant repairs of the reactor i
head vent system, were inadequate. The specific parameters that were not verified were the quantity and injection pressure of the leak sealant material, as i
well as the leak sealant injection port location. As a result, the amount of leak sealant materialinjected into the valve was twice the amount specified in the j.
maintenance work package. Failure to monitor these parameters contributed to the migration of leak sealant to unintended portions of the system, including the seat to disc interfaces on HVS flow control valves 2RCS-HCV-250A and
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250B. Valve 2RCS-HCV-250A subsequently became bound and failed to fully i
stroke. (01013)
B.
10 CFR Part 50, Appendix B, Criterion lil, Design Control, requires, in part that measures be established for the selection and review for suitability of materials j
and processes that are essentia: to the safety-related functions of structures, systems, and components.
Contrary to the above, on or about December 2,1996, the licensee did not i
provide adequate measures to verify the selection of suitable leak sealant material for use in a leak repair of the safety-related reactor head vent system.
Specifically, licensee engineers specified an incorrect repair location i
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Enclosure 2
temperature, in engineering memorandum 113494. This error led to the j-selection of an improper sealant material that failed to harden, as required, at the HVS temperature that existed at the time of the injection. As a result, the sealant material migrated to unintended portions of the system, thereby i
adversely affecting the operability of the HVS system. (01023) i C.
Technical Specification 6.8.1 requires that written procedures be properly established and implemented covering activities recommended in Appendix A to NRC Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements (Operation)." Section 9 of Appendix A to Regulatory Guide 1.33 specifies that maintenance that can affect the performance of safety related 4.
equipment be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Beaver Valley j
procedure NPDAP 2.15, " Administrative Controls", Revision 2, specifies -
requirements for control of vendor services, including maintenance activities.
Contrary to the above, on or about December 2,1996, the licensee failed to assure that maintenance affecting the performance of the reactor head vent system was properly performed in accordance with written procedures and
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instructions in that:
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The licensee did not assure that adequate controls for the leak sealant quantity and injection pressure, as specified in Maintenance Work j
Request 059169 and supporting Engineering Memorandum 113494, were prescribed in written procedures.
2)
The licensee did not assure that vendor-performed maintenance activities associated with the reactor HVS leak sealant repair were properly conducted ur: der procedural controls commensurate with the safety importance of the work and as would be required if licensee personnel performed the work. Specifically, the licensee failed to properly oversee vendor work during injection gun loading, the drill and tap location used, the injection pressure used, and accountability for the amount of leak sealant materialinjected. (01033)
D.
Technical Specification (TS) 6.8.2 requires each procedure specified in TS 6.8.1 to be reviewed by the Onsite Safety Committee (OSC) and be approved by the General Manager, Nuclear Operations or a predesignated alternate.
I Contrary to the above, vendor engineering repair procedures NP 2110 and NP-2139, used for two safety related leak injection repairs on December 1 and December 2,1996, respectively, were not properly reviewed by the OSC and approved by the General Manager, Nuclear Operations, or a predesignated alternate. (01043)
These four violations are classified in the aggregate as a Severity Level lil problem (Supplement 1).
Civil Penalty - $110,000.
a Enclosure 3
II.
VIOLATION RELATED TO POWER OPERATED RELIEF VALVE (PORV) BLOCK VALVES 10 CFR Part 50, Appendix B, Criterion XVI requires, :n part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, since 1983, a condition adverse to quality existed at Unit 1 involving two PORV block valves being in the closed position, and this condition adverse to quality was not identified and corrected until October 8,1996. Two of the three PORV block valves were shut in 1981 as a temporary measure to address PORV leakage, as well as seismic concerns related to NRC Bulletin 79-14. While Section 4.2.2.7 of the licensee's UFSAR and the bases for TS 3.4.11 indicate that the block valves are normally open, TS 3.4.11 permits the block valves to be closed in the event of inoperable PORVs. Although piping modifications were completed in 1981 to address the seismic concerns, and PORV leakage was resolved in 1983, the block vdves were not reopened at that time and the unit continued to operate with the j
valves in the closed position until the valves were opened on October 8,1996, following questioning by the NRC. Leaving the valves closed for approximately 13 years after the leakage and seismic concerns had been resolved, constitutes the condition adverse to quality that was not identified and corrected by licensee staff, despite multiple opportunities to do so, as evidenced by the following examples.
1.
The PORV block valve configuration and power supply train separation were specifically evaluated by licensee engineers during Appendix R Fire Protection Program reviews performed between 1986 and 1990. Engineers incorrectly concluded that the PORV block valves should remain shut to mitigate the consequences of a fire due to power supply separation concerns. The licensee should have determined that the train separation concern had been procedurally addressed by isolating power to the valves in the event of a fire, but failed to do so.
2.
During IPE evaluations and submittals between 1990 and 1995, the licensee had opportunities to identify and correct this condition, which differed from the UFSAR configuration, but failed to do so.
3.
When submitting a Technical Specification amendment in 1994 (supplemented in 1995) in response to NRC Generic Letter 90-06, the licensee should have identified and corrected this condit: ore because the bases of the TS amendment submittal clearly stated that the PORV.) lock valves are normally open, but failed to do so. (02013)
This is a Severity Level ill violation (Supplement 1).
Civil Penalty - $50,000.
Enclosure 4
Pursuant to provisions of 10 CFR 2.201, Duquesne Light Company (DLC)is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed imposition of Civil Penalties (Not'ce). This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (b the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.
Under the authoriN of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalties proposed above, or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civi; penalties will be issued. Should the Licenseo elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition
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to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answerin accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the'10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee
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is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties.
Upon failure to pay any civil penalties due that subsequently have been determined in j
accordance with the applicable provisions of 10 CFR 2.205, this mattermay be referred to the i
Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.
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Enclosure 5
The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852 2738, with a copy to the Regional Administrator, U.S.
Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident inspector at the facility that is the subject of this Notice.
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Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the pmprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.
3 Dated at King of Prussia, Pennsylvania j
this 10th day of March 1997 1
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