ML20153G397
| ML20153G397 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/28/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sieber J DUQUESNE LIGHT CO. |
| Shared Package | |
| ML20153G399 | List: |
| References | |
| EA-88-083, EA-88-83, NUDOCS 8805110224 | |
| Download: ML20153G397 (4) | |
See also: IR 05000334/1988012
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April 28, 1988
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Docket No.
50-334
License.No. DPR-66
EA 88-83
Duquesne: Light Company
ATTN:
Mr.. .J. D. Sieber
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Vice President
Nuclear Group
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Post Office Box 4
Shippingport, Pennsylvania 15077
Gentlemen:
SUBJECT: NOTICE OF VIOLATION
(NRC Inspection Report No. 50-334/88-12)
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This refers to the NRC special safety inspection conducted on March 3-8, 1988
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at the Beaver Valley Power Station, Unit 1, to review the circumstances
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' associated with a violation of a technical specification limiting condition for
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operation which was identified by your staff and reported to the NRC. The
inspection report was sent to you on March 10, 1988. During the inspection, a
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failure to meet a commitment made in the Final Safety Analysis Report (FSAR)
was also identified. On March 24, 1988, an enforcement conference was conduc-
ted with Mr. J. Sieber and other members of your staff to discuss the violation
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and deviation, their caures, and your corrective actions.
The violation, which is described in the enclosed Notice, involved the inoper-
ability (for approximately eight days while the reactor was in either the hot
shutdown, startup or operations mode) of two of four channels used to actuate
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the Containment Spray Systems and Phase B Containment Isolation whenever high
containment pressure setpoints were exceeded. The channels were inoperable in
that their associated bistables were in the bypassed position, and therefore,
not capable of performing the intended automatic safety function. The bistables
were left in this condition after completion of maintenance surveillance tests
performed on February 22, 1988. As a result, although the safety function
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remained available throughout the period since the other two channels were
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operable, the "built-in" redundancy for automatic actuation of these systems
was lost. At the time the tests were performed, the reactor was in the cold
shutdown mode and being prepared for startup.
The procedure used to perform the maintenance surveillance test specified that
if the reactor was in the cold shutdown or refueling modes, the bistables were
to be returned to the bypassed position upon completion of the test. Apparently,
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it was envisioned that the startup checklist performed prior to entering the
hot shutdown condition would identify this bypassed condition and return the
bistables to the proper position prior to startup. However, the startup
che:klist had been performed approximately six hours prior to the performance
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OFFICIAL RECORD COPY
DUP CP PKG BEAVER VALLEY 88-83 - 0001.0.0
04/27/88
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8805110224 880428
ADOCK 05000334
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Duquesne Light Company
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of the maintenance surveillance test for those two channels. As a result, the
bistables were not placed in the bypassed position until after the startup
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checklist had been completed.
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The NRC notes that a similar maintenance surveillance test on the other two
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channels had been performed just prior to performance of the startup checklist,
and those channels were left in the bypassed position, in accordance with the
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-procedure, upon e mpletion of the test. However, those two channels were
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returned to the normal position when identified during the performance of that
startup checklist.
If the checklist had been performed but a few hours
earlier, all four bistables could have been left in the bypassed position,
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which would have rendered all four channels inoperable.
The NRC is concerned that the specific maintenance survei'llance test pre-edure,
although requiring that the operations department be notified when the surveil--
lance was completed did not require that the operations department be informed
that the equip e nt was left, at the completion of the test, in a configuration
other than existed at the beginning of the surveillance.
If the operations
department had been notified of this condition, additional cFecks could have
been performed at that time to ensure restoration of the bi, table to the normal
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position prior to entering the hot shutdown mode.
Furthermore, when these
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channels were in the bypassed position, there was no indication in the control
room of this condition, contrary to a commitment in the FSAR. Apparently,
although there was control room indication at the time the commitment was made
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in the FSAR, this indication capability was lost during a modification made at
the facility in 1980. A change to the FSAR was never made.
The failure to
satisfy this commitment, which is described in the associated inspection
report, is also of concern since the violation could have been prevented if
control room indications existed.
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In accordance with the "General Statement of Policy and Procedure for NRC
Enfnecement Actions," 10 CFR Part 2, Appendix C (1987), the violation described
in the enclosed Notice has been classified at Severity Level III
A civil
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penalty is considered for a Severity Level III violation.
However, after
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consultation with the Director, Office of Enforcement and the Deputy Executive
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Director for Regional Operations, I have decided that a civil penalty will not
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be proposed in this case because (1) the violation was identified by your staff
and promptly reported to the NRC, and (2) your "root cause" analysis of this
event was very thorough, and corrective actions taken sutaequent to that
analysis were unusually prompt and extensive. By this action, the NRC does not
minimize the significance of the violation.
Rather, your actions in response
to the violation and described in the enforcement conference demonstrate that
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you recognize the significance of this violation.
It is clearly not accept 6ble
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to operate in a condition where the loss of one additional channel could defeat
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initiation of containment spray and automatic containment isolation. The NRC
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emphasizes that any similar violations in the future will result in additional
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enforcement actions.
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OFFICIAL RECORD COPY
DUP CP pKG BEAVER VALLEY 88-83 - 0002.0.0
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04/28/88
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Duquesne Light Company
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You are required to respond to this letter and should follow the instruc-
tions specified in the enclosed Noticas when preparing your response.
In
your response, you should document the specific actions taken and any addi-
tional actions you plan to prevent recurrence.
In addition, you should
describe the actions taken or planned to assure that FSAR commitments are
met, or if changed, are changed in accordance with the requirements of 10 CFR 50.59 and 50.71. After reviewing your response to this Notice, including
your proposed corrective actions and the results of future inspections, the
NRC will determine whether further NRC enforcement action is necessary to
ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Reoulations, a copy of this letter and its enclo-
sure will be placed in the Nk? Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL No.96-511.
Sincerely,
Originn.1 Sicnnd By
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Y. ..J:ZLL
William T. Russell
Regional Administrator
Enclosure:
cc w/ encl:
J. J. Carey, Executive Vice President, Operations
J. O. Crockett, General Manager, Corporate Nuclear Services
W. S. Lacey, General Manager, Nuclear Operations
N. R. Tonet, Manager, Nuclear Engineering
T. P. Noonan, Plant Manager
C. E. Ewing, QA Manager
K. D. Grada, Manager, Nuclear Safety
Public Document Room (PDR)
local ?ublic Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
0FFICIAL RECORD COPY
DUP CP PKG BEAVER VALLEY 88-83 - 0003.0.0
04/27/88
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Duquesne Light Company
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bec w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
DRP Section Chiof
Robert J. Bores, DRSS
SECY
J. Taylcr, DEDR0
J. Lieberman, OE
J. Allan, RI
D. Holody, RI
J. Goldberg, OGC
Enforcement Directors, RII-III
Enforcement Officers, RIV-V
T. Murley, NRR
F. Ingram, PA
J. Bradburne, CA
E. Jordan, AE00
B. Hayes, OI
S. Connelly, 0IA
P. Robinson, OE
R. Cunningham, NMSS
D.Nussbaumer, 0GP/SP
OE File (3 copies = ltrhd)
EDO Rdg File
R. B(nedict, NRR
B. Clayton, EDO
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0FFICIAL RECORD COPY f
DUP U PKG BEAVER VALLEY 88-83 - 0004.0.0
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04/27/88
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