ML20236X863

Notice of Violation from Insp on 980426-0627.Violation Noted:During Period of 980428-0608,licensee Failed to Implement Procedures as Evidenced by Listed Examples

ML20236X863
Person / Time
Site:	Beaver Valley
Issue date:	08/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236X857	List: IR 05000334/1998003 ML20236X856 ML20236X863 ML20236X866
References
50-334-98-03, 50-334-98-3, 50-412-98-03, 50-412-98-3, NUDOCS 9808100328
Download: ML20236X863 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Duquesne Light Company Docket Nos. 50-334,50-412 8eaver Valley Power Station 1 & 2 License Nos. DPR-66, NPF-73 During an NRC inspection conducted from April 26'to June 27,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, Rev.1, the violation is listed below:

Technical Specification 6.8.1.a requires that, " written procedures shall be established, implemented and maintained covering ... the applicable procedures recornmended in Appendix "A" of Regulatory Guide 1.33, " Quality Assurance

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Program Requirements," Rev. 2, February 1978." Appendix "A" of Regulatory Guide 1.33 recommends procedures for surveillance testing, operation, and control i of maintenance work (including clearances) for safety related equipment. l l

Contrary to the above, during the period April 28 through June 8,1998, the l licensee failed to implement procedures as evidenced by the following examples:

1. Procedure 20ST-30.13A," Train A Service Water System Full Flow Test,"

Rev. 8, requires that the service water system be returned to the desired configuration as directed by the nuclear shift supervisor / assistant nuclear shift supervisor. The procedure was not properly implemented, in that on May 29, after conducting the service water test, operators failed to properly restora service water to the "A" high head safety injection pump. The "A" high head safety injection pump was improperly considered operable and was thus improperly credited as part of an operable boration flow path from June 2 to Jane 8. On June 8, a licensed operator identified that service water was adgned to the "C" high head safety injection pump and not the "A" pump.

2. Procedure 1/2 OM-48.1.D, " Operations Shift Rules of Practice," Rev. 25, requires that if an instrument provides an apparent improper indication, the operator should believe the instrument and respond conservatively to prevent damage to station equipment unless the instrument indication is demonstrated to be f alse by checking against at least two redundant instruments. The procedure was not properly implemented,in that on May 22, operators did not respond conservatively when the branch flow line flow data for the high head full flow test indicated pump runout conditions.

l Testing continued without proper assessment of the indication of runout flow l and the potential adverse effects on the high head safety injection pump.

3 Procedure NPDAP 3.4, " Clearance /Tagout Procedure," Rev. 9, requires a senior reactor operator to verify that the tagout is properly prepared. The procedure was not properly implemented,in that on June 3, the clearance for exhaust fan 222-B was not properly prepared and was posted. The j

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l 2 j clearance deenergized fan 222-B; however, the clearance also disabled the two emergency diesel generator room ventilation fans, which was not recognized. Subsequently, the licensee identified EDG 2-2 inoperability when operators attempted to start an emergency ventilation fan and it failed to l start. EDG 2-2 was inoperable for approximately four hours.

4. Procedure 2MSP-1.14B-l," Train B Reactor Trip and Bypass Breaker Time Response Test," Rev.1, step K.1.b requires the removal of the jumper that i disabled the Unit 2 general warning trip. The procedure was not properly implemented, in that on May 10, operators discovered that the jumper was l stillinstalled in the solid state protection system. The technicians failed to '

remove the jumper on April 28 as required in the procedure, despite requirements for double verification.

These four examples constitute a Severity Level IV violation (Supplement 1). 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 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 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 correspondence adequately addresses the required response, if an adequate reply is not received within the time speJfied 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, consideration will be given to extending the response time.

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

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 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 and a redacted copy of your response that deletes such information. If you request withholding of such material, you rnust 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 l

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

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I information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

' Dated at King of Prussia, PA titis 5th day of August 1998 i

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