ML20198K476

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:Between 1988 & 970912, Condition Adverse to Quality Existed at Unit 1 & 2,when Excessive Gas Accumulated in HHSI Pumps Suction Lines

ML20198K476
Person / Time
Site:	Beaver Valley
Issue date:	01/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198K469	List: ML20198K464 ML20198K476
References
EA-97-517, NUDOCS 9801150006
Download: ML20198K476 (3)

Text

- . . - .. -.- .

4 4

ENCLOftURE NOTICE OF VIOLATION AND-PROPOSED IMPOSITION OF CIVIL PENALTY Duquesns Ught Company (DLC) Docket Nos. 50 334;50-412 Beaver Valley Power Station License Nos DPR-66; NPF 73 EA 97 517 -

During an NRC inspection conducted between August 31,1997, and October 4,1997, for which an exit meeting was held on October 14,1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose a civil penalty 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 violation and associated civil penalty are set forth below:

10 CFR Part 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures _ shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition.

Contrary to the above, between 1988 and September 12,1997, a condition adverse to quality existed at Unit 1 and Unit 2, when excessive gas accumulation in the HHSI pumps suction lines resulted in the potential operation of both units outside the design basis. The excessive gas accumulation resulted in repeated gas binding of the Unit 2 high head safety injection (HHSI) pump 2CHS-P21C. During that time, measures were net established to ensure that the condition adverse to quality was promptly identified and corrected until after September 12,1997, when the differential pressure for the pump was observed to be at 2341 psid which was below the limit of 2437 listed in Technical Specifications 4.1.2.4.1 and 4.5.2.b.1. Specifically,

1. In March 1988, the licensee discovered excessive gas accumulation on the .

HHSI Pump 2CHS-P21 A. This gas accumulation was large enough to prohibit the pump from operating. The licensee identified that Unit 1 also experienced gas accumulation in the HHSI system. Corrective actions taken in 1988 to 1990 to install manual venting systems and establish ventir$g frequencies were inadequate to prevent possible gas binding events due to inadequate engineering evaluations and failure to evaluate the effectiveness of the corrective actions.

L 1

l l

9001150006 990106 l PDR ADOCK 05000334 G PM

4 l

Enclosure 2

2. In June 1993, HHSI Pump 2CHS-P21C experienced gas binding which the licerisee attributed to an accumulation of excessive gas due to inadequate venting of the charging lines to the volume control tank. While the corrective actions stated in response to this event were to install the design for continuous venting, this action had not been implemented as of September 12,1997 even though tha item had been closed in the licensee's tracking system.

3. In November 1996, HHSI Pump 2CHS P21C again experienced gas binding which was again attributed to inadequate venting of the charging lines to the VCT. While the corrective action stated in response to that event was to modify the vent path to improve the manual venting of the system, this action was not scheduled for completion before January 15,1998, and there were no interim actions taken to prevent recurrence of gas binding.

4. In August 1997, HHSI Pump 2CHS-P21C again experienced gas binding due to s

^

inadequate venting of the charging lines. However, corrective actions taken prior to the pump start and following that event were deficient in that indications of degraded pump performance were not fully evaluated following surveillance testing on August 20 and after the extensive venting on August 28, or prior to declaring the pump operable following the August 28 gas binding I

event. (01013)

This violation is classified at Severity Level 111 (Supplement 1).

Civil Penalty - $55,000.

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 Penalty (Notice). This reply should ce 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, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that havo 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 roply 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 nnt 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 authority of Section 182 of the Act, 42 U.S.C. 2232, tras 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 penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic trancier payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty, 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 civil

^

3~; +

7 Enclosu e _  % 3-penalty will be issued. Should the Licensee elect to file ~an answer in accordance with:10 CFR

= 2.205 protesting the civil penalty, 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 wN16or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to

_ protesting the civil penalty lin whole or in part, such answer may request remission or ?

mitigation of the penalty. .

In requesting mitigation of the proposed penalty, the factors addressed in Sec. tion VI.B.2 of the Enforcement Policy should be addressed.? Any written answer in 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 pads 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

- is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalty.

Upon f ailure to pay any civil penmity due that subsoouently.has been determined in accordance

- with the applicable provisions of 10 CFR 2.205, this marer may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by- -

civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty,

,and Answer to a Notice of Violation) should be addressed to:- James Lieberman, Director, 5 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.

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 proprietary, 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.

Dated at King of Prussia, Pennsylvania this- 6th day of January 1998-

__