Information Notice 1979-35, Control of Maintenance & Essential Equipment

Control of Maintenance & Essential Equipment

ML031180205
Person / Time
Site:	05000000
Issue date:	12/31/1979
From:	NRC/OI
To:
References
IN-79-035, NUDOCS 7910250510
Download: ML031180205 (10)

UNITED STATES SSINS No.: 6870 NUCLEAR REGULATORY

COMMISSION

Accessions

Mo.: OFFICE OF INSPECTION

AND ENFORCEMENT

7910250510

WASHINGTON, -D.C. 20555 December 31, 1979 IE Information

Notice No. 79-35 CONTROL OF MAINTENANCE

AND ESSENTIAL

EnUIPMENT Description

of Circumstances:

Enclosed is a copy of a recent enforcement

action against Duquesne Light Company.A coDy of this action is being forwarded

to all utilities

with a power reactor operating

license or a construction

permit. This is being done to apprise you of a serious condition

which revealed an apparent weakness in facility control of maintenance

and essential

equipment.

You should review your existinq procedures

and control for independent

verification

of operability

of redundant

counterpart

equipment

when an essential

component, subsystem, or system is determined

inoperable.

Operability

is defined as follows: A system, subsystem, train, component

or device shall be OPERABLE or have OPERABILITY

when it is capable of performing

its specified

functionts).

Implicit in this definition

shall be the assumption

that all necessary attendant

instrumentation, controls, normal and emergency

electrical

power sources, coolinq or seal water, lubrication

or other auxiliary

equipment that are required for the system, subsystem, train, component

or device to perform its function(s)

are also capable of performing

their related support function(s).

If you have any Questions

reqardina

this matter, please contact the Director of the NRC Regional Office in which your facilities

are located. No written response to this IE Information

Notice is required.Enclosures:

1. Letter to Duguesne Light Company from V. Stello, Jr., dtd. 12/5/79 2. Recently Issued IE Information

Notices

IE Information

Notice No. 79-35 December ,31 1979 Enclosure RECENTLY ISSUED IE INFORMATION

NOTICES Information

Notice No.Subject Date Issued Issued To 79-34 79-33 79-32 79-31 79-30 79-29 79-28 Inadequate

Desiqn of Safety-Related

Heat Exchangers

Improper Closure of Primary Containment

Access Hatches Separation

of Electrical

Cables for HPCI and ADS Use of Incorrect

Amplified Response Spectra (ARS)Reportinq

of Defects and Noncompliance, 10 CFR Part 21.Loss of NonSafety-Related

Reactor Coolant System Instrumentation

During Operation Overloading

of Structural

Elements Due to Pipe Support Loads Steam Generator

Tube Ruptures At Two PWR Facilities

Attempted

Damane To New Fuel Assemblies

Breach of Containment

Integrity Reactor Trips At Turkey Point Units 3 And 4 12/6/79 All power reactor facilities

holding OLs and CPs and vendors inspected

by LCVIP 11/16/79 All power reactor facilities

holding OLs or CPs 11/16/79 All power reactor facilities

with an OL or CP 11/16/79 All power reactor facilities

holdinq OLs and CPs 11/9/79 All Fuel Facilities, research reactors, and power reactors with an OL or CP 12/27/79 All holders of power reactor OLs and CPs 12/21/79 All power reactor facilities

holdinc OLs and CPs 12/21/79 All power reactor facilities

holding OLs and CPs 12/13/79 All holders of power reactor OLs and CPs 79-27 79-12A 79-26 79-25 11/5/79 10/1/79 All power reactor facilities

holdina OLs and CPs All power facilities

with an nL or a CP

Docket No. 50-334 December 5, 1979 Duquesne Light Company ATTN: Mr. Stanley G. Schaeffer President 435 Sixth Avenue Pittsburgh, Pennsylvania

15219 Gentlemen:

On November 27, 1979, the Beaver Valley Power Station, Unit 1, was operated for about two (2) hours in a condition

which exceeded the Limiting Conditions

for Operation.

This matter was brought to the attention

of our inspector

at your facility in a timely fashion, and your subsequent

action to correct the condition

was expeditious.

Nevertheless, this condition

rendered a part of the emergency core cooling system (ECCS) unavailable

for automatic

start and injection

of coolant into the reactor coolant system (RCS) if the need had occurred concur-rent with the loss of offsite power (the design basis). This unavailability

of ECCS constitutes

a serious matter which reveals an apparent weakness in your control of maintenance

and essential

equipment.

Therefore, we propose to impose a civil penalty for the item of noncompliance

set forth in Appendix A to this letter in the amount of $5,000. Appendix B is a Notice of Proposed Imposition

of Civil Penalties.

You are required to respond to this letter and in preparing

your response, you should follow the instructions

in Appendices

A and B.In addition to the civil penalty, we are issuing the enclosed Order (Appendix

C)effective

Immediately.

This Order requires that your administrative

control of licensed activities

involving

operating

and maintenance

of safety equipment verifies availability

of all required equipment

when a counterpart

is removed from an operable status. This Order further requires that you formally review and report your actions to prevent recurrence:

It also requires that you meet publicly on January 25, 1980, with the Director, Office of Inspection

and Enforcement, at a location near the Beaver Valley Power Station, to discuss your evaluation

of this conditon and your corrective

actions to prevent recurrence.

We will inform you of the location and time of the meeting.

Duquesne Light Company-2 -In accordance

with Section 2.790 of the NRC's "Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures

will be placed in the Commission's

Public Document Room.Sincerely, Victor Stello, Jr.Director Office of Inspection

and Enforcement

Enclosure:

1. Appendix A, Notice of Violation 2. Appendix B, Notice of Proposed Imposition

of Civil Penalties 3. Appendix C, Order Modifying

License cc: C. N. Dunn, Vice President, Operations

Division F. Bissert, Technical

Assistant

Nuclear R. WIashabaugh, QA Manager J. Werling, Station Superintendent

G. Moore, General Superintendent, J. J. Carey, Nuclear Technical

Assistant R. Martin, Nuclear Engineer

APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Pittsburqh, Pennsylvania

15219 License No. DPR 66 This refers to the inspection

conducted

by the NRC Resident Inspector

at the Beaver Valley Power Station, Unit 1, of activities

authorized

by NRC License No. DPR 66.During the inspection

conducted

on November 27, 1979, the following

item of noncompliance

was identified.

Technical

Specification

3.5.2 states that with the plant in Mode 1 (Power Operation), two separate and independent

ECCS subsystems

shall be operable, and further states in section 3.5.2.c that each subsystem

shall include an operable flow path caoable of taking suction from the refueling

water storage tank upon initiation

of a safety injection

signal.Technical

Specification

1.6 defines "operable" to include the assumption

that all necessary

attendant

instrumentation, controls, electric power, cooling or seal water, lubrication

or other auxiliary

equipment

that are required for the system, subsystem, train, component

or device to perform its function(s)

are also capable of performing

their related safety function(s).

Contrary to the above, on November 27, 1979, from approximately

8:30 a.m. to 10:30 a.m., maintenance

activities

rendered both ECCS subsystems

inoperable

in that a) refueling

water storage tank isolation

valve MOV-CH-115D

was closed and incapable

of automatic

opening in response to a safety injection

signal, and b) refueling

water storage tank isolation

valve MOV-CH-115B, in the redundant subsystem, was closed, had no emergency

power available, and thus was incapable of automatic

opening In response to a safety injection

signal if there had been a condition

of loss of offsite power.This violation

had the potential

for causing or contributing

to an occurrence

related to health and safety (Civil Penalty $5,000).

APPENDIX B NOTICE OF PROPOSED IMPOSITION

OF CIVIL PENALTIES Duquesne Light Company nocket No. 50-334 Pittsburgh, Pennsylvania

15219 License No. DPR-66 This office has considered

the enforcement

options available

to the MRC including

administrative

actions in the form of written notices of violation, civil monetary penalties, and orders pertaining

to the modification, suspension

or revocation

of a license. Based on these considerations, we propose to impose civil penalties

pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 USC 2282), and to 10 CFR 2.205 in the cumulative

amount of Five Thousand Dollars ($5,000) for the specific items of noncompliance

set forth in Appendix A to the cover letter. In proposing

to impose civil penal-ties pursuant to this section of the Act and in fixing the proposed amount of the penalties, the factors identified

in the Statements

of Consideration

published

in the Federal Register with the rule-making

action which adopted 10 CFR 2.205 (36 FR 16894) August 26, 1971, and the "Criteria

for Determining

Enforcement

Action," which was sent to NRC licensees

on December 31, 1974, have been taken into account.Duquesne Light Company may, within twenty (20) days of the receipt of this notice pay the civil penalties

in the cumulative

amount of Five Thousand Dollars ($5,000) or may protest the imposition

of the civil penalties

in whole or in part by a written answer. Should Duquesne Light Company fail to answer within the time specified, this office will issue an order imposing the civil penalties

in the amount proposed above. Should Duquesne Light Company elect to file an answer protesting

the civil penalties, such an answer may (a) deny the items of noncompliance

listed in the Notice of Violation

in whole or in part, (b) demonstrate

extenuating

circumstances, (c) show error in the Notice of Violation, (d) show other reasons why the penalties

should not be imposed.In addition, to protesting

the civil penalties

in whole or in part, such answer may request remission

or mitigation

of the penalties.

Any written answer in accordance

with 10 CFR 2.205 should be set forth separately

from the statement

or explanation

in reply pursuant to 2.201, but may incorporate

by specific reference (e.g., giving page and paragraph

numbers)to avoid repetition.

Duquesne Light Company's

attention

is directed to the other provisions

of 10 CFR 2.205 regarding, in particular, failure. to answer and ensuing orders;answer, consideration

by this office, and ensuing orders; requests for hearings, hearings and ensuing orders; compromise, and collection.

Upon failure to pay any civil penalty due which has been subsequently

determined

in accordance

with the applicable

provisions

of 10 CFR 2.205, the matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected

by civil action pursuant to Section 234.c of the Atomic Energy Act of 1954, as amended (42 USC 2282).

APPENDIX C UNITED STATES OF AMERICA NUCLEAR REGULATORY

COMMISSION

In the flatter of )DUOUESNE LIGHT COMPANY Docket No. 50-334 (Beaver Valley Power Station, Unit 1) )ORDER MODIFYING

LICENSE EFFECTIVE

IMMEDIATELY

I The Duquesne Light Company (the "licensee")

is the holder of Operating

License DPR-66 (the "license")

which authorizes

operation

of the Beaver Valley Power Station, Unit 1, at steady state reactor core power levels not in excess of 2652 megawatts

thermal (rated power). The license was issued on January 30, 1976. The facility consists of a pressurized

light water moderated

and cooled reactor (PWR), located at the licensee's

site in Beaver County, Pennsylvania, on the southern shore of the Ohio River.It On November 27, 1979, from about 6:30 AM to 1:20 PM while the reactor was operating

at about 30% of rated power, Emergency

Diesel Generator (EDG) 1 was out of service for routine maintenance.

This EDG supplies emergency

power to suction valve, MOV-CH-115B, in the line from the refueling

water storage tank (RWST) to the High Pressure Safety Injection

System (HPSIS) pumps. In addition to the EDG being out of service, resulting

in loss of one Emergency

Core Cooling System (ECCS) flow path, as described

above, the redundant

suction valve, MOV-CH-115D, was removed from service for maintenance

which resulted in loss of the redundant

ECCS flow path from the RWST from 8:30 a.m. to 10:30 a.m.During this time the facility was operated in noncompliance

with the Limiting Condition

for Operation

specified

in Technical

Specification

3.5.2.c. This condition

resulted from inadequate

control of maintenance

activities

and its

Appendix C-2 -occurrence

suggests that the licensee has not adopted appropriate

controls to assure that maintenance

activities

do not defeat required safety features.This in turn undermines

the basis for determining

that there is reasonable

assurance

that redundant

safety features will function under design basis conditions.

In view of the significance

to safety of adequate controls to assure that maintenance

activities

do not defeat required safety features, I have deter-mined that the public health, safety, or interest requires, effective

immediately, modification

of License No. DPR-66 as stated in Part III of this Order.III Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Commission's

regulations

in 10 CFR Parts 2 and 50, License DPR-66 is modified as follows: (1) Administrative

Procedures

shall be adopted and implemented

to require redundant

independent

verification

of the operability

of the remaining engineered

safety features whenever any safety system, or subpart thereof, is intentionally

removed from service.(2) A detailed review of existing procedures

and controls shall be performed to assure that limiting conditions

for operation

are not defeated by maintenance

or other activities.

(3) A report of the administrative

procedures

required by paragraph

(1) above and the detailed review required by paragraph

(2) above shall be submitted by January 11, 1980, to the Director of NRC's Region I office.

Appendix C-3 -(4) The licensee shall meet with the Director, Office of Inspection

and Enforcement, on or before January 25, 1980, in a meeting open to the public in the vicinity of the Beaver Valley site to describe how the above requirements

will be implemented.

The Director, Region I, will inform the licensee at least one week in advance of the specific time and location of the meeting.IV The licensee, or any other person who has an interest affected by this Order, may, within twenty-five

days of the date of this Order, request a hearing. A request for a hearing shall be addressed

to the Director, Office of Inspection

and Enforcement, U.S.N.R.C., Washington, D.C. 20555. If a hearing is requested by the licensee or an interested

person, the Commission

will issue an Order designating

the time and place of hearing. Such a request for hearing SHALL NOT STAY THE IMMEDIATE

EFFECTIVENESS

OF THIS ORDER.Resumption

of operation

on terms consistent

with this Order is not stayed by the pendency of any proceeding

on this Order. In the event that a need for further enforcement

action becomes apparent, either in the course of any proceeding

on this Order or at any other time, the Director will take appro-priate action.V In the event the licensee or any other interested

person requests a hearing as provided above and a hearing is held, the issues to be considered

at such a hearing shall be:

Appendix C -4 -(1) whether the facts set forth in Part II of this Order are correct;and, (2) whether this Order should be sustained.

FOR THE NUCLEAR REGULATORY

COW2IISSION

Victor Stello, Jr.Director Office of Inspection

and Enforcement

Dated at Bethesda, Maryland this 5th day of December, 1979.