ML20216E807

Notice of Violation from Insp on 980105-0212.Violations Noted:On 971218 Dl Implemented Change to Temporary Operating Procedure to Allow Operators to Control Cooldown & Heatup Rate of Reactor Coolant by Mean Other than by Regulating

ML20216E807
Person / Time
Site:	Beaver Valley
Issue date:	03/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216E791	List: ML20216E787 ML20216E807 ML20216E819
References
50-334-98-80, 50-412-98-80, NUDOCS 9803180167
Download: ML20216E807 (3)

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t NOTICE OF VIOLATION Duquesne Light Company Docket Nos. 50-334,50-412 Beaver Valley Power Station 1 & 2 License Nos. DPR-66, NPF-73 During an NRC inspection conducted from January 5,1998, through February 12,1998, violations of NRC requirements were identified. In accordance with 6n " General

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( Statement of Policy'and Procedure for NRC Enforcement Actions," iv) REG-1600,the l violations are listed below:

i 1. 10 CFR 50, Appendix B, Criterion XVI (Corrective Action), requires, in part, that meawes shall be established to assure that conditions adverse to quality, such as 3 failures, deviations, defective material and equipment, and nonconformances are j I

promptly identified and corrected.

! Contrary to the above, conditions adverse to quality were not promptly corrected in that from January 1995, to January 23,1998, Duquesne Light Co. failed to

- promptly correct defective equipment, i.e., residual heat removal (RHR) system flow l - control valve MOV-RH-758, which had been identified via a maintenance work request in January 1995 to have excessive leakage (more than 1000 gallons per l

minute).

This is a Severity Level IV violation (Supplement 1).

2. 10 CFR 50.59, " Changes, tests and experiments," in part, permits the licensee to make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report without prior Commission approval, provided the change does not involve a change in the technical specifications or an Unreviewed Safety Question (USO). The licensee shall maintain records of changes in the facility and these records must  ;

include a written safety evaluation which provides the bases for the determination i that the change does not involve a USQ. l l

Section 9.3 of the Beaver Valley Unit 1 UFSAR states that "the cooldown rate of l the reactor coolant is controlled by rc.gulating the reactor coolant flow through the tube side of the RHR heat exchangers."

Contrary to the above, on December 18,1997, Duquesne Light Co. implemented a change to temporary operating procedure (1 TOP-97-28)to allow operators to control the cooldown and heatup rate of the reactor coolant (a procedure described in the safety analysis report) by a means other than by regulating reactor coolant flow through the tube side of the RHR heat exchangers and no safety evaluation was performed. Specifically, the change allowed operators to regulate reactor coolant cooldown and heatup rates by throttling the component cooling water flow through the shell side of the RHR heat exchangers. ,

i This is a Severity Level IV violation (Supplement I). l I

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Notice of Violation 2 1

3. 10 CFR 50.59, " Changes,1ests and experiments," in part, permits the licensee to l make changcc to its facility and procedures as described in the safety analysis i- report without prior Commission approval, provided the change does not involve a change in the technical specifications or an unreviewed safety question (USQ). The 7

licensee shall maintain records of changes in the facility and these records must include a written safety evaluation which provides the bases for the determination that the change does not involve a USO.

l- Contrary to the above, in December 1994 Duquesne Light Company made a change to allow storage of propane next to the auxiliary intake structure building without I performing a safety evaluation that was adequate to determine that the change did not involve a USO. Specifically, the modification added three 1000 gallon propane storage tanks adjacent to the auxiliary river intake structure, which contains l systems that provide the alternate heat sink requirements for the Beaver Valley l

units. (The Unit 1 auxiliary river water system and the Unit 2 standby service water system, which are described in Unit 1 UFSAR, Section 9.16, and Unit 2 UFSAR, Section 9.4, are located inside the auxiliary river intake structure.) The safety .

analysis was deficient, in that, it did not evaluate the potential hazards or impact on -

equipment associated with the storage of large quantities of liquid propane next to the auxiliary river intake structure. Additionally, instead of three 1000 gallon propane tanks, Duquesne Light Co. actually stored 4000 gallons of propane in a tanker trailer truck adjacent to the auxil'ary intake structure building without performing an evaluation of the larger an.ount or the change in storage methods.

Without these evaluations, there was insuficient bases to determine that the change did not involve a USQ.

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR'2.201, Duquesne Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional i Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps

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i that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your ,

response may reference or include previous docketed correspondence, if the -l correspondence adequately addresses the required response. If an adequats 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. Where good cause is shown,

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l consideration will be given to extending the response time.

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If you contest this enforcement action, you should also provide a copy of your response to I the Director, Office of Enforcement, United States Nuclear Regulatory CommisMon, Washington, DC 20555-0001.

Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

l Because your response 'will be placed in the NRC Public Document Room (PDR), to the I

! extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected i and a redacted copy of your response that deletes such information. If you request j withholding of such material, you mE specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of I personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of

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protection described in 10 CFR 73.21.  !

Dated at King of Prussia, PA this 91May of March,1998 i

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