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

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 Enclosure

December ,31 1979

RECENTLY ISSUED

IE INFORMATION NOTICES

Information Subject Date Issued To

Notice No. Issued

79-34 Inadequate Desiqn of 12/27/79 All holders of power reactor

Safety-Related Heat OLs and CPs

Exchangers

79-33 Improper Closure of 12/21/79 All power reactor facilities

Primary Containment holdinc OLs and CPs

Access Hatches

79-32 Separation of Electrical 12/21/79 All power reactor facilities

Cables for HPCI and ADS holding OLs and CPs

79-31 Use of Incorrect Amplified 12/13/79 All holders of power reactor

Response Spectra (ARS) OLs and CPs

79-30 Reportinq of Defects and 12/6/79 All power reactor facilities

Noncompliance, 10 CFR Part 21. holding OLs and CPs and

vendors inspected by LCVIP

79-29 Loss of NonSafety-Related 11/16/79 All power reactor facilities

Reactor Coolant System holding OLs or CPs

Instrumentation During

Operation

79-28 Overloading of Structural 11/16/79 All power reactor facilities

Elements Due to Pipe Support with an OL or CP

Loads

79-27 Steam Generator Tube 11/16/79 All power reactor facilities

Ruptures At Two PWR holdinq OLs and CPs

Facilities79-12A Attempted Damane To New 11/9/79 All Fuel Facilities, Fuel Assemblies research reactors, and

power reactors with an

OL or CP

79-26 Breach of Containment 11/5/79 All power reactor facilities

Integrity holdina OLs and CPs

79-25 Reactor Trips At Turkey 10/1/79 All power facilities with

Point Units 3 And 4 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.