ML20198K464
| ML20198K464 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/06/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| Shared Package | |
| ML20198K469 | List: |
| References | |
| 50-334-97-07, 50-334-97-08, 50-334-97-7, 50-334-97-8, 50-412-97-07, 50-412-97-08, 50-412-97-7, 50-412-97-8, EA-97-517, NUDOCS 9801150003 | |
| Download: ML20198K464 (5) | |
See also: IR 05000334/1997007
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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. KING oF PRUSSIA, PENNSYLVANIA 19406-1415
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January 6, 1990
EA 97 517
Mr. J. E. Cross, President
Generation Group
Duquesne Light Company (DLC)
Post Office Box 4
Shippingport, Pennsylvania 15077
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$55,000
(NRC Inspection Report Nos. 50-334/37-07;50-412/97-07 & 50-334/97-08;
50 412/97-08)
Dear Mr. Cross:
This letter refers to the NRC inspection conducted between August 31,1997, and
October 4,1997, at the Beaver Valley Power Station, Units 1 & 2, the findings of which were
discussed with you and members of your staff during an exit meeting on October 14,1997.
During the inspection, an apparent violation of NRC requirements was identified involving the
failure to take adequate action to correct a significant condition adverse to quality at the
facility. The specific adverse condition involved voiding in the high head safety injection
(HHSI) suction lines which could lead to gas binding of the HHSI pumps and consequent failure
to operate. ' The related NRC inspection report was sent to you on November 7,1991.
This also' refers to an NRC inspection conducted between October 5,1997, and
November 15,1997, the findings of which were discussed wi+h you and members of your
staff during an exit meeting on November 21, 1997. During that inspection, the NRC
documented a related unresolved item with respect to whether the venting of the HHSI pumps
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immediately prior to its surveillance test invalidated the test causing a violation of NRC
requirements.- On December 10, 1997, a Predecisional Enforcement Conference was
conducted with you and members of your staff to discuss the apparent violation, its causes,
and your corrective actions, as well as the related unresolved item.
Based on the iriformation developed during the inspections,- and the information provided
during the conference, one violation is being cited and is described in the enclosed Notice of
Violation and Proposed imposition of Civil Penalty (Notice). The violation involves your f ailure
to take adequate action to correct this significant condition adverse to quality regarding gas
binding of the HHSI pumps. This condition was identified at Unit 2 on September 12,1997
when operators observed that the differential pressure for one of the Unit 2 HHS
below its Technical Specification limit. Previously, your staff had encountered repeatad
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instances of gas binding of this specific HHSI pump. However, on each occasion, adequate
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corrective actions were not taken, as more fully described herein. These repeated instan::es
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of gas binding of the pump likely caused the degradation of the pump below Technical ;
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Specification differential pressure limits.
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9901150003 990106
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This finding is significant because the gas binding of the pump created the potential for'
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interruption of HHSI flow to the reactor during design basis accident conditions.; The violation
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t is particularly risk significant because the issue affected both units over a long duration and
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affected the only safety related high pressure source of injection to the reactor vessel for ~
several accident scenarios. _' At.the conference, you recognized the seriousness of this
problem,' noting that in not taking adequate corrective actions sooner, you operated outside-
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the design basis for the facDity.- You also indicated that the failure of your staff to dieplay a
more questioning attitude on this matter was'one of the root causes of the problem.; This was
evident during testing of the pump in August 1997 when indications of degraded pump
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performance were not fully evaluated following surveillance testing on August 20 and after
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extensive venting on August 28, or prior to returning the pump to operability following the
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' August 28 gas binding event,
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,This finding is also significant because the prior indications of gas binding of this pump -
. provided clear opportunities to correct this condition sooner. In March 1988, your staff -
discovered excessive gas accumulation on a Unit 2 HHSI pump. This gas accumulation was
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large enough to prohibit the pump from operating. Your investigation in 1997 has shown that
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the corrective actions taken from 1988 to 1997 for Unit 1 and Unit 2 were ineffective to
prevent possible gas binding events due to inadequate engineering evaluations and a f ailure
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to evaluate the effectiveness of the corrective actions. For example, you attributed the gas
binding of a Unit 2 HHSI pump (the same pump that failed in September 1997)in June 1993
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to the accumulation of excessive gas because of inadequate manual venting of the charging
lines to the volume control tank (VCT). Although corrective actions were pisnned to install
a continuous venting design, this action was never implemented and the item was closed in'
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your tracking system, in addition, in November 1996, that same pump again experienced gas
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binding. While the planned corrective action at that time was to modify the vent path to
improve the manual venting of the system, this action was not scheduled for completion until-
January 15,1998, and there were no interim actions taken to prevent recurrence of gas
binding. - Further, in August 1997, the pump again experienced gas binding even after the lines
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had been vented for over three hours, which was much longer than the normal venting period -
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of less than 10 minutes.
This type of violation is similar to the failure to correct a condition adverse to quality at Unit
1 involving the operation of the reactor with two of the three pressurizer power operated relief
valve (PORV) block valves shut for an extended period of time (from 1981 until 1996). As
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. you know, on March .10,1997, the NRC issued to Duquesne Light Company a Notice of
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Violation and Proposed imposition of Civil Penalty in the amount of $160,000 for, in part, the -
f ailure to correct that adverse condition related to the PORV block valves. In that case, your
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staff also missed several opportunities to identify and correct the incoNect valve lineup.
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Given the risk significance of the failure to correct the HHSI gas binding phenomena, despite
the prior opportunities to do so, the violation has been classified at Severity Level lli in
accordance with the " General Statement of Policy and Procedures for NRC Inforcement
Action, (NUREG 1600)(Enforcement Policy).
In accordance with the Enforcement Policy, the base civil penalty amount for this Severity
Level til violation is $55,000. Your facility has been the subject of escalated enforcement
actions within the last two years, as already noted herein; therefore, the NRC considered
whether credit was warranted for identi// cation and Corrective Action h accordance with the
civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is not
warranted for identification since the violation was identified as a result of an event, and it
should have been identified coor.er given the prior opportunities. Credit is warranted for
corrective action because your corrective actions, which were described during the
conference, were considered prompt and comprehensive after the Soptember 12,1997 event.
Those actions included, but were not limited to: (1) initiation of a multi-discipline team to
review events leading to the pump's failure to meet the technical specification; (2) plans to
install six 22-stage recirculation line orifices in order to eliminate the vart majority of the
generation of hydrogen gas; (3) plans to perform more frequent ultrasonic measurements to
determine gas accumulation; (4) detailed engineering evaluations and establishment of gas
accumulation limits for Unit 1 and Unit 2; (5) conduct of safety culture training to focus on
improving questioning attitude; and (6) plans to establish a Critique Process to promote earlier
identification and resolution to deviant conditions.
Therefore, to emphasize (1) the importance of a questioning attitude to ensure prompt and
comprehensive identification and ccrrection of conditions adverse to quality when they exist,
and (2) aggressively looking for and pursuing anomalous conditions at the facility, I have been
authorized, after consultation with the Director, Office of Enforcement, to propose a $55,000
civil penalty in this case Given the high risk significance of this condition, as well as the
period of time it existed, I considered exercising discretion to increase the civil penalty.
However, I have decided not to do so in view of the overall comprehensiveness of your
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corrective actions,
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With respect to the unresolved item discussed during the second inspection, the NRC is still
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evaluating this matter and resolution will be handled by ceparate correspondence at a later
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date.
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You are required to raspond to this letter and should follow the instructions specificd in the
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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
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regulatory requirements.
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Duquesne Light Company
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in accordance wiih 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 PubCc Document Room (PDR).
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Sincerely,
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.Hubert J. Miller
Regional Administr tor M
Docket Nos. 50 334;50'412
Enclosure: Notice of Violetion and Proposed imposition of Civil Penalty
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- cc w/ encl:
S. Jain, Vice President, Nuclear Services
R. LeGrand, Division Vice President, Nuclear Operations Group & Plant Manager
W. Kline, Manager, Nuclear Engineering Department
B. Tuite, General Manager, Nuclear Operations Unit
M. Perg'ur, Acting Manager, Quality Services Unit
J. Arias, Director, Safety & Licensing Department
J. MacDonald, Manager, System and Performance Engineering
M. Clancy, Mayor
Commonwealth of Pennsylvania
State of Ohio
State of West Virginia
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Duquesne Light Company
DISTRIBUTION:
.
. PU8LIC
SECY
CA
LCallan, EDO
. AThadani, DEDO
JUeberman, OE
HMiller, RI
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FDavis, OGC
SCollins, NRR
RZimmarman, NRR
Enforcement Coordinators
Rl, Ril, Rill, RIV
BBeecher, GPA/PA
GCaputo, 01
DBangart, OSP
HBell, OlG
TMartin, AEOD
OE:Chron
OE:EA
'NUDOCS
DScrencl, PAO RI
NSheehan, PAO RI
Nuclear Safety Information Center (NSIC)
Resident inspector - Beaver Valley
LTremper, OC
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